Mar. 19, 2023
Dear Securities and Exchange Commission, I am writing to express my strong support for the proposed Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders. While I applaud the Commission's efforts to promote fair and transparent pricing across trading venues, I believe that unambiguous language in the rule structure is necessary to avoid any confusion or litigation. I strongly recommend the establishment of a zero or very low fee structure to eliminate the potential for trading for the sake of volume. Rather than allowing rebates and other inducements in the marketplace, this would promote fair trading practices and improve market transparency. Additionally, I urge the Commission to implement a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks. This would further promote fair pricing and transparency in the market, ensuring that all participants have access to the same information and opportunities. While reducing access fee caps is a step in the right direction, I believe that eliminating exchange rebates would further enhance transparency and fairness in the market. We must take these steps to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Investors should not be forced to route orders through wholesalers with a record of disregarding the law. I suggest that investors are willing to pay an additional 0.64 cents per share to avoid routing through these wholesalers (https://files.brokercheck.finra.org/firm/firm_116797.pdf). The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. I fully support the harmonization of tick sizes across all exchanges. Clear rules and clear language are necessary to prevent any unfair advantages and to promote fair competition in the market. Enforcement is also a crucial component of market regulation. I strongly recommend higher fines, bigger penalties, and actual consequences for those who violate market regulations. Enforcement must be harsh enough to disincentivize these actors from continually breaking the law, otherwise, they will view it as the cost of doing business. In addition, I urge the Commission to ensure that the definition of tick-constrained applies to as much of the market as possible. Everyone must trade and provide quotes according to the same rules to maintain market fairness. Lastly, I strongly support the inclusion of odd-lot information in the SIP. Odd lots are a majority of trades and should have a greater impact on price. Odd lots must impact the NBBO and have a concrete effect on both price and the broker's duty of best execution. Thank you for your attention to these important matters. I urge the Commission to take action to promote fair and transparent pricing and to restore public confidence in the market. Sincerely, Hussain Shahabuddin Citation: https://files.brokercheck.finra.org/firm/firm_116797.pdf