Subject: Re: SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22)
From: Billy Blum
Affiliation:

Mar. 07, 2023

I am concerned with any use of the term “reasonable” while evaluating the tick size rule as this can create a grey area which will make enforcement more difficult.

Any rebates or inducements are completely unacceptable and should be banned similarly to payment for order. Access fees should be “no take” and reduced to zero.

Odd lots must be included in the NBBO otherwise price discovery for individual investors is limited and are put at a disadvantage.

The tick size harmonization is a true head-scratcher, to learn that an exchange could be getting away with this type of skullduggery for this long is beyond a disgrace and should be permanently and swiftly banned.

I would gladly pay more (small % of share value - not per share) if those who are fined repeatedly such as Citadel would also contribute to a fund that could subsidize a true and fair price discovery and order routing system.

Please enforce and increase the fines for the egregious behavior of the current payment for order flow market makers.

With regards,
1 Individual Investor