Mar. 13, 2023
I am writing in support of this rule. It is refreshing to see significant efforts by the agency to improve the integrity of our markets. But there are still some changes I would like to propose. The effectiveness of every SEC rule depends on its enforcement, which is why I advocate for higher fines that act as a significant deterrent. In my opinion, some broker-dealers should lose their licenses instead of receiving fines that merely serve as a cost of doing business, which often pale in comparison to the profits made through "honest mistakes." I am willing to pay more cents per share to avoid being routed through a wholesaler that has faced over 70 charges from the United States government, as listed in their BrokerCheck report. Given the long history of law-breaking by Citadel Securities, I support paying a commission to avoid being routed through them or any other such wholesalers. I fully support the standardization of tick sizes across all exchanges, as it is unjust that certain exchanges are granted special treatment, which they can leverage to create monopolies in specific areas of the market. All exchanges should quote and trade in the same increments, with no exchange receiving an unfair advantage over others. Such practices undermine the positive effects of competition and run counter to the fair nature of the markets. I strongly dislike the presence of rebates and other incentives in the marketplace, as they are essentially just another form of payment for order flow. Instead, I would prefer that access fees be reduced to zero, with no "take." I fully support the tick size regime proposed by the Commission, and would also support any structure that is transparent and avoids vague language. Some firms may request language that is too loose and ambiguous, such as "has a reasonable amount of liquidity at the NBBO," which essentially means "I can ignore the rule if I think I can get away with it." Such language makes enforcement difficult and costly. Therefore, clear and unambiguous language and tick size rules are necessary, and vague language should not be included in the rules. I applaud the Commission's efforts to include odd lot information in the SIP, which provides individual investors with more information to make better investment decisions, particularly regarding which firms are handling their orders. Two years ago, odd lots accounted for the majority of trades in the market, with a proportion of 55%, and in some stocks, the proportion is even higher. Therefore, it is imperative that the bids and offers of many orders are not kept invisible. The exclusion of odd lot information from this rule would further erode my faith in the US markets. I believe that the exclusion of odd lots from the NBBO is problematic, as odd lots are now the majority of trades in the market and are often the preferred method of trading for individual investors. Excluding odd lots from the price of a stock effectively excludes most individual investors, who are the majority of the voting public. Thus, I urge the Commission to consider a way to include odd lots in the calculation of the NBBO in a fair and proportional manner.