Mar. 19, 2023
Dear Securities and Exchange Commission, As a household investor, I am writing to express my support for the Commission's proposed rule on Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders in the stock market. I strongly believe that this proposed rule would promote fair and transparent pricing across trading venues and eliminate any unfair advantage that some market participants may have. I recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. It is also important to establish a zero or very low fee structure to eliminate the potential for trading for the sake of volume, instead of allowing rebates and other inducements in the marketplace. Furthermore, I fully support the implementation of a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks. This will ensure that all market participants can trade at sub-penny intervals, eliminating any unfair advantage that some may have. 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. I also recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. It is crucial to take these steps to regain public confidence and trust in the market, especially after recent events like the GameStop controversy. I fully support the enforcement of these rules with higher fines, bigger penalties, and actual consequences. Investors should not be routed through wholesalers with a long record of flouting the law like Citadel Securities. I believe that investors will gladly pay commission to avoid being routed through such wholesalers, and the price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. I support the harmonization of tick sizes across all exchanges, without any exceptions or vague language. It is essential to ensure that no exchange has an unfair advantage over others, as it leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets should be fair, and it is necessary to make them so. Lastly, I 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. 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 your attention to this matter. Sincerely, Dylan McGrath