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

Mar. 07, 2023

When rules are passed what makes them have merit is the enforcement and penalty when an entity breaks them. Creating a “cost of doing business” environment is unacceptable and you might as well not even have the rule to begin with. So the penalties need to be so severe that it would bankrupt them or cost broker-deals their licenses. 


If you have an entity with over 70 charges for breaking rules/laws they should not have the ability to route any trades. If that means an extra cost then so be it.  Example being Citadel Securities, how could you let crime keep on repeating this many times and do nothing?  This is unacceptable and costs you all your integrity each day the more people find out about this and in markets, “Integrity is king.” 


I support the harmonization of tick sizes across all exchanges.  Monopolies are bad and if we sat down and talked about it in person you would agree yet you allow this to currently happen.  Exchanges should have to quote and trade in the same increments.  Competition should not be pushed away. 


Anything cloned to be like payment for order flow I disagree with. 


The tick size regime proposed by the Commission I agree with and support.  Any language that comes out as vague needs to be shut down and laughed at.  We shouldn’t need lawyer speak to even get involved and if it sounds like it then it’s a big red flag.  Everything should be clear all around. 


The inclusion of odd lot information in the SIP I support. 


Odd lots being excluded from the NBBO is not good.  Some stocks that have higher prices as an example would be filled with odd lots which is more than likely individual investors which is a large portion of the voting public. Please fairly do the right thing with odd lot calculations in the NBBO.