Mar. 07, 2023
March 7, 2023 I am writing to share my views on the current market structure and suggest some potential solutions to address certain issues. Firstly, I believe that the practice of offering rebates and other incentives in the marketplace, also known as payment for order flow, can lead to trading simply for the sake of volume, which is not beneficial for true price discovery. Therefore, I would prefer to see these fees reduced or eliminated altogether, with a maximum fee of 0.001. I support the establishment of a variable minimum pricing increment model for the quoting and trading of NMS stocks, regardless of trading venue, in order to reduce the access fee caps and limit the fees that can be charged for trading against the best priced quotations displayed in any market. However, I strongly believe that exchange rebates should be completely eliminated. I also support the Commission's proposed tick size regime, but I urge for clear and unambiguous language in the rule structure to avoid confusion and unnecessary litigation. I recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP, as outlined in the Commission's Market Data Infrastructure Rule, to improve transparency and restore investor confidence. It is crucial for the Commission to take these steps to regain the trust of the public, especially after recent events like the Gamestop controversy. I hope my suggestions are taken into careful consideration, and I appreciate the opportunity to provide my input. Best regards,