Subject: S7-30-22: WebForm Comments from Richard Pasquali
From: Richard Pasquali
Affiliation: DDS

Mar. 16, 2023



 March 16, 2023

 It is no secret that the way financial institutions and market makers are able to pick and choose which orders see lit exchanges, which go to dark pools, and which are internalized is borderline criminal.

Improving the parameters around this is a necessity. Creating more transparency by improving tick sizes and requiring the amount of all fees and rebates by a national securities exchange is vital. Defining best odd-lot buy/sell orders and early adoption of odd/round lot information will also help with transparency in the markets.

This is even more important when you consider the fact that household investors make up the bulk of odd lot orders. Not enforcing these rules and improving the execution prices and the routing of these orders will be a step towards helping household investors actually have an effect on price discvoery and their effect on what is supposed to be the free market.