Mar. 7, 2023
To the SEC, Every time the SEC passes a rule, it comes up short with enforcement. There is no reason or logic passing rules that are not or only sporadically enforced. In order to try and mitigate this little conundrum I would suggest increase the fines significantly (talking about factor x10) to serve more as a deterrent and even looking into the possibility of fining X% of the annual revenue of the perpetrator and confiscating no less than 100% of the calculated profits that were obtained by breaking this rule. Broker-dealers that are repeatedly breaking these rules should lose their license for no less than 1 fiscal year instead of receiving fines that amount to nothing more than a cost of doing business - a cost that is often outweighed by the ill-gotten gains obtained through “honest mistakes” and gladly paid if it means all profits can be kept. Furthermore, I as a consumer and household investor would gladly pay 12 cents more a share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government (<a href="https://files.brokercheck.finra.org/firm/firm_116797.pdf)">https://files.brokercheck.finra.org/firm/firm_116797.pdf)</a> all for breaking SEC rules that weren't enforced. I would gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. I fully support the harmonization of tick sizes across all exchanges. I was shocked to learn that some exchanges get special treatment and are able to leverage that special treatment to build monopolies in some areas of the market. All exchanges should have to quote AND trade in the same increments. Some exchanges shouldn’t be granted an unfair advantage over others. It leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets are supposed to be fair and at this moment this is not a level-playing field. The SEC is failing in its duties to protect household investors by non-enforcement of it's own rules and tipping the scales for the wholesalers.I dislike the presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name. I would prefer you reduce access fees to zero; no "take". A market-maker that is supposed to give the best price allowing to profit from my trades is a huge conflict of interest and at this point in time it's frankly ridiculous it is still allowed. Get rid of it and level the playing field.I wholeheartedly support the tick size regime proposed by the Commission, and would also support any structure that is clear and does not rely on vague language. For example, some funds and firms might request language like "has a reasonable amount of liquidity at the NBBO", which translates to "I can ignore the rule if I feel my lawyers can help me get away with it". Loose language makes enforcement difficult or impossible, and wastes taxpayer dollars on needless litigation time. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Please do not include vague language in the application of your rules. Make it concise, precise and enforceable.I support the inclusion of odd lot information in the SIP, and 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 <a href="https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-f77dc4f1603bb602&q=1&e=e2ef0777-2917-40a4-bc96-896ef5a1f6dc&u=https%3A%2F%2Faltered.mwginternal.com%2Fhttps%3A%2F%2Fbettermarkets.org%2Fnewsroom%2Fkey-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing%2F%29.">https://altered.mwginternal.com/https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing/).</a> 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. More information for everyone, everyone treated equally. Level the playing field.I believe the exclusion of odd lots from the NBBO is a serious 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 household investors - most of the voting public. Please look into a way to fairly and proportionately include odd lots in the calculation of the NBBO.Market information should be open to all and not reserved for a select few. Reign in the market-makers and have them do what they are supposed to d; provide the best possible price in the market for any investor, not merely internalize it and profit from it in the guise of “providing liquidity”.Sincerely,A very disillusioned individual household investor