Subject: S7-30-22: WebForm Comments from Abraham
From: Abraham
Affiliation:

Mar. 14, 2023

March 14, 2023

 Dear Ms. Countryman,

As a household investor, I would like to express my gratitude for your efforts to promote competition and transparency in the market. Thank you for providing an opportunity to comment on the proposed changes.

The recommended enhancements are a significant overhaul to the U.S. equity market structure, possibly one of the most substantial changes since the implementation of Regulation NMS in 2005.

I believe that rebates and other incentives in the marketplace are essentially payment for order flow and encourage trading for the sake of volume. While I would prefer to see these fees reduced to zero, a fee of .001 would be acceptable as a compromise.

I am in favor of implementing a variable minimum pricing increment model for both quoting and trading NMS stocks listed on national securities exchanges, regardless of the trading venue.

While the proposed amendments to Rule 610 are a step in the right direction by reducing the level of access fee caps, I would like to see exchange rebates eliminated completely.

I support the Commission's proposed tick size regime and urge that any structure put in place should be clear and unambiguous, without relying on vague language. For instance, some funds and firms may request the use of phrases such as \"reasonable amount of liquidity at the NBBO,\" which can make enforcement difficult and costly. Clear language and a transparent tick size rule structure are preferred.

I strongly recommend expediting the implementation of the revised round lot definition and the odd lot dissemination on the SIP outlined in the Commission's Market Data Infrastructure Rule (MDIR). Given the fast-paced nature of this industry, the delay in reporting is unacceptable.

It is crucial for the Commission to take these measures to restore the public's confidence and trust. The GameStop incident severely eroded investor confidence, and many are opting to hold their shares with transfer agents.

Thank you for your attention to these matters.