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

Mar. 12, 2023

 


To whom it might concern, dear SEC rule committee, 


As a household investor, I expect that every rule passed by the SEC is enforced in full. In the past years there have been numerous reports of market disorder made possible by intentionally or unintentionally disregarding said rules. Significantly higher fines and the possibility to strip the license of broker-dealers continuously exploiting current market mechanics would further discourage breaking SEC rules.  



I am absolutely willing to pay a few cents more per share to avoid being routed through a wholesaler like Citadel Securities that has been charged by the US government on numerous occasions already (https://files.brokercheck.finra.org/firm/firm_116797.pdf).  


To my surprise, tick size is not harmonized across all exchanges, which I believe can lead to abuse and formation of monopolies in the market. Quotes and trades should be in the same increments across the board. Thus I fully support the harmonization of tick size as proposed by the Commission. 


Market participants might appeal to amend the text of said rule using vague language, I.e. „A reasonable amount of liquidity…“. I strongly suggest that vague language should be avoided wherever possible to guarantee the rules effectiveness.  


Further, I support the inclusion of odd lot information in the SIP and the calculation of the NBBO, to assure  best prices for all traders, including household investors.  


Thank you so much for considering my suggestions.  


Sincerely, 
JPS