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

Mar. 8, 2023



Good morning!

I applaud the Commission's efforts to provide individual investors with more information with which to make better investing decisions - especially concerning which firms are allowed to handle our orders. Two years ago, the majority of trades in the markets were odd lots (55%; from https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-c3dca0577c2a56c1&q=1&e=ce65fab0-e8a6-4dc8-8b50-1afd96da154e&u=https%3A%2F%2Fbettermarkets.org%2Fnewsroom%2Fkey-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing%2F). For certain tickers, this proportion is certainly much higher. Why are the bids and offers of so many orders kept invisible? If the Commission were to remove odd lot information from this rule, my faith in the U.S. markets would become even more damaged than it already is. We need price discovery. The amount of suppression evident by the crazy amount of FTD's is a clear sign of something going wrong or corruption.

I believe the exclusion of odd lots from the NBBO is a problem. Odd lots are now a majority of trades in the markets. Within some stocks, they are the vast majority. The exclusion of odd lots from the price of a stock amounts to the exclusion of most individual investors - most of the voting public. Please look into a way to fairly and proportionately include odd lots in the calculation of the NBBO.

Sincerely,

Best regards,

Hector Herrand