Mar. 07, 2023
Please find below my comments on the SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22). I have found current comments by large hedge funds, market markers, and investment firms to fail to understand the spirit of a free trade market. While these entities claim to have the interest of retail investors in mind, I believe it is clear by their actions and practices that they only wish to exploit the retail market. Any rule enacted by the SEC is only valuable if it is enforced. I want to see meaningful fines enforced upon bad actors. This should serve as a deterrent yet currently only serves as a minor annoyance and is considered a cost of doing business. Please enforce fines proportional to the impact of the violating action. I would happily pay a small per-share-fee to ensure that my trades are not being routed through a wholesaler that has had over 70 Regulatory Events (https://files.brokercheck.finra.org/firm/firm_116797.pdf). I do not believe this is a legitimate or ethical company. I do not believe this company represents or understands the best interests of the retail market and individual investors. I am happy to pay commission to avoid my trades being routed through an entity that clearly has no qualms about breaking the laws. I support the harmonization of tick sizes across all exchanges. It is appalling that specific exchanges get special treatment that allows them to monopolize areas of the market. I do not believe this represents the concept of a free market. All exchanges should be required to quote and trade in the same increments/units. No exchanges should be granted unfair advantages as this leads to an unfair market controlled by those with the most money. I do not support rebates and other inducements in the marketplace as they are only a thinly veiled vehicle for payment for order flow which is illegal in most exchanges. I would prefer access fees reduced to zero with no "take". I support the tick size regime proposed by the SEC. I support any structure that relies on clear, concise, and coherent language. There are many instances of vague language such as "has a reasonable amount of liquidity at the NBBO." This is unacceptable to me and ultimately meaningless as "reasonable" is subjective and undefined. This leads to abuse of interpretation and prevents laws from being enforced as litigious companies with large financial resources will always be able to out-maneuver government entities who have limited legal resources to defend their laws. Loose wording only leads to the more powerful being able to interpret it as they desire. Please ensure that clear, well-defined language is used when defining the tick size rule structure. Avoid vague language. I support the inclusion of odd lot information in the SIP. I applaud the SEC's efforts to provide individual investors with greater transparency and more information about which firms are handling our orders. Two years ago, the majority of trades in the markets were odd lots (55%; from https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing/). For certain tickers, this proportion is certainly much higher. It is unclear and disturbing that bids and offers of many orders are kept invisible. This reduces retail investor faith in the US markets. If the SEC removes odd lot information from this rule my faith in the market, along with many other retail investors, would become even further damaged. I believe exclusion of odd lots from the NBBO is a serious problem as odd lots are the majority of trades in the markets. With certain stocks they are a vast majority. This adversely impacts price discovery and ensures lower participation and confidence from individual retail investors - the citizens that vote. Please devise a fair and proportionate way to include odd lots in the calculation of NBBO. Thank you for your hard work and diligence at making our markets fair and free from control of those who wish to manipulate our free market. Sincerely, Sean Mann Individual Retail Investor