Subject: S7-30-22: WebForm Comments from David Lee
From: David Lee
Affiliation:

Mar. 18, 2023



 March 18, 2023

 I am writing this comment in full support of proposed rule S7-30-22, but for some parts I feel we could go further.

Regarding minimum pricing increments, I do not believe that a handful of market participants should share an unfair advantage and be able to trade at multiple decimal points while the rest of the market participants are restricted to 2 decimal points.  Level the playing field and make the same rules apply to all - no exemptions.  I also feel that minimum pricing increments do not need to be watered-down.

Regarding access fees,  I am in full support of lowering the maximum to $0.001, and I think this should happen, but I feel it does not go far enough.  I feel that we should make access fees $0.000.

Regarding transparency of better priced orders,  I am in full support of this proposal.  Odd lots should be disseminated on the SIP, but I also feel that this proposal does not go far enough.  Odd lots should also affect the price.  According to recent studies, household investors add a combined total of $1.5 billion per day into our equities market - mostly in odd lots.  That is a lot of participation in our markets that is not affecting the price of equities, and this volume really should be taken into consideration.