Mar. 07, 2023
March 7, 2023 Dear SEC Commissioners, As a retail investor, I believe that the proposed variable minimum pricing increments are not an effective solution to address concerns related to tick-constrained stocks. Therefore, I support the implementation of a uniform minimum pricing increment of $0.001 or lower for all NMS stocks. The proposed minimum pricing increments are not appropriate because they vary based on the proposed Time Weighted Average Quoted Spreads, and this could create confusion, unnecessarily increase complexity in the market, and does less to narrow the advantage that some market participants with $0.0001 minimum increment hold over retail investors. I do not support modifying the minimum pricing increment on a quarterly basis, as this is a step towards better conditions for retail investors and a fairer market. There should not come a point where less fair and efficient markets are needed. I also support that the minimum quote increment is locked to the minimum price increment. The proposed average quoted spread thresholds for each proposed minimum pricing increment may not be appropriate for all NMS stocks since the minimum pricing increments could be economically significant for certain stocks that have the relevant Time Weighted Average Quoted Spread. Therefore, a uniform minimum pricing increment would be more appropriate since it would apply equally to all NMS stocks. I do not believe that the proposed OR uniform minimum pricing increments will cause flickering quotes or reduce displayed liquidity. Technical issues like these are not literally caused by the price increments, that is a failure of existing systems, which should at no point hinder crucial progress in market reform or development. I do not believe that the $0.0001 minimum pricing increment for quotes and orders priced less than $1.00 per share is appropriate. Instead, it should be increased to a uniform minimum pricing increment of $0.001 or lower. Tick-constrained stocks should not be the only ones to have a reduced minimum pricing increment. Instead, a uniform minimum pricing increment of $0.001 or lower should be applied to all NMS stocks. Furthermore, I do not believe that certain types of NMS stocks, such as ETFs or NMS stocks with smaller market capitalization, should have a different minimum pricing increment. All NMS stocks should be subject to the same uniform minimum pricing increment. Finally, I believe that there are no other means to categorize NMS stocks for determining a minimum pricing increment. A uniform minimum pricing increment of $0.001 or lower is the most efficient and effective solution to ensure fairness and efficiency in the market. Thank you for considering my comments. Sincerely, Matthew Gavyn Mutman