Mar. 9, 2023
Dear SEC, I am writing in response to the SEC proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22). Firstly, I strongly believe that every rule the SEC passes is only as good as the enforcement that backs it. To this end, I want to see higher fines that actually serve as a significant deterrent. Additionally, I think some broker-dealers should lose their licenses instead of receiving fines that amount to nothing more than a cost of doing business. It is imperative that we ensure that ill-gotten gains obtained through "honest mistakes" are outweighed by the penalties incurred. Secondly, I would gladly pay 12 cents more a share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. I am deeply concerned about the actions of certain broker-dealers and the impact they have on the market. In particular, I would prefer to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. Thirdly, I fully support the harmonization of tick sizes across all exchanges. It is unfair that some exchanges get special treatment and are able to leverage that special treatment to build monopolies in some areas of the market. All exchanges should have to quote AND trade in the same increments. It is my belief that this will lead to a more fair and just market for all. Fourthly, I dislike the presence of rebates and other inducements in the marketplace. These are simply payment for order flow by another name. I would prefer the reduction of access fees to zero and an end to all "take.". I believe that the elimination of these incentives will help to promote a more transparent and fair market. Fifthly, I support the tick size regime proposed by the Commission, and would also support any structure that is clear and does not rely on vague language. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Please do not include vague language in the application of your rules, as this makes enforcement difficult or impossible, and wastes taxpayer dollars on needless litigation time. Finally, I support the inclusion of odd lot information in the SIP. This will provide individual investors with more information with which to make better investing decisions, especially concerning which firms are allowed to handle our orders. As the majority of trades in the markets are odd lots, I believe that this information is critical for ensuring a more fair and just market. In conclusion, I urge the SEC to consider my views on this matter carefully. I am deeply committed to ensuring that the U.S. (and all) markets are transparent, fair, and just for all. Thank you for your attention to this matter. Sincerely, Denny Milk