Mar. 19, 2023
Dear SEC, I am writing to express my strong support for the Commission's proposed tick size regime and to recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. Additionally, I suggest implementing a zero or very low fee structure instead of allowing rebates and other inducements in the marketplace to eliminate the potential for trading for the sake of volume. It is also important to implement a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks to promote fair and transparent pricing across trading venues. While reducing the access fee caps is a step in the right direction, I believe that completely eliminating exchange rebates would further enhance transparency and fairness in the market. Moreover, I recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. These steps are crucial to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Furthermore, I strongly believe that enforcement matters and we need higher fines, bigger penalties, and actual consequences. Investors should support additional 0.64 cents more a share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. Investors will gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. In addition, I fully support the harmonization of tick sizes across all exchanges, with no exceptions or vague language. Clear rules and language are essential to prevent some exchanges from gaining an unfair advantage over others, which can lead to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. I suggest 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. Finally, I urge for the inclusion of odd-lot information in the SIP as odd lots are a majority of trades and should have a greater impact on price. 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. Thank you for considering my recommendations. I believe that implementing these measures will improve market transparency and fairness, leading to a healthier and more trustworthy marketplace. Best regards, Sony