Mar. 20, 2023
Dear SEC, I am writing to express my enthusiastic support for File No. S7-30-22, Release No. 34-96494, regarding the Regulation NMS. The proposed tick size regime is a much-needed step towards ensuring transparency and fairness in the US financial markets, like shining a flashlight into the murky waters of Wall Street. However, I urge the Commission to implement clear and unambiguous language in the rule structure to avoid any confusion or litigation. It is crucial to eliminate the potential for trading for the sake of volume, like a race to the bottom that harms investors and undermines market integrity. The establishment of a zero or very low fee structure in lieu of rebates and other inducements in the marketplace is a necessary step towards promoting fair and transparent pricing across trading venues. The implementation of a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks would level the playing field and promote transparency, like opening the windows in a dark room to let in fresh air. While reducing the access fee caps is a positive development, the complete elimination of exchange rebates would further enhance transparency and fairness in the market. The acceleration of the revised round lot definition and odd lot dissemination on the SIP is a much-needed enhancement to reporting efficiency and reduces delays, like a well-oiled machine that runs smoothly and accurately. It is important to highlight the significance of these steps in regaining public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement of rules and regulations is crucial to ensuring a fair and just market for all, like the police patrolling the streets to deter criminals. I fully support higher fines, bigger penalties, and actual consequences for those who break the law. Investors should be willing to pay an additional 0.64 cents per share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government, like avoiding a tainted restaurant with a long record of health code violations. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. The harmonization of tick sizes across all exchanges is essential to ensuring fair competition and preventing monopolistic behavior in the market, like ensuring that all players follow the same set of rules on the playing field. I recommend that the definition of tick-constrained should apply to as much of the market as possible to ensure everyone trades and provides quotes according to the same rules. Rebates and other inducements in the marketplace are simply payment for order flow by another name and should be strongly discouraged, like putting lipstick on a pig. I recommend reducing the fees to zero, but if not feasible, then a very low fee of .001 would suffice. The inclusion of odd-lot information in the SIP is crucial to promoting transparency and fairness in the market, like shining a light on the corners of the room that are often neglected. It is important to make it clear that odd lots should impact the NBBO and have a concrete effect on both price and broker's duty of best execution. In conclusion, I urge the SEC to take bold action towards ensuring transparency, fairness, and competition in the US financial markets. Thank you for considering my views. Kindly, Anthony