Mar. 19, 2023
I strongly support the SEC's proposed tick size increment and I should also add that there should be no vague or ambiguous language used in the structure of this rule. There should be at the same time no confusion about the implementation of this new regime but also no room for wrongdoing left for nefarious actors. Tick sizes should be equal on all exchanges and for everyone. No exceptions, no unfair advantages for certain participants because of (insert shady reason). Again I cannot stress this enough. These rules need to be concise and applied to every single participant. Reducing the access fee cap on rebates is a good first step but eliminating rebates altogether would promote transparency and fairness in the market. Establishing a low fee structure for inducement would serve the same purpose and eliminate the purpose of trading with the intent of boosting volume. These inducements are nothing more than the middlemen funneling trades towards them using false promises. Most investors worth their salt would gladly pay trading fees rather than trade through these conflicts of interest were they educated properly on the subject. I also fully support adding old lot data in the SIP. These are the majority of trades on many securities and therefore should have a sizable influence on the price. Odd lots should have an effect on the NBBO and therefore be included in the broker's duty of best execution. Again, all of this is for nought if these rules aren't enforced properly or if the consequences of breaking these rules are only a cost of doing business. Chris Pelletier