Mar. 19, 2023
Dear SEC, As an investor, I am writing to express my strong support for the proposed tick size regime. I believe that clear and unambiguous language in the rule structure is necessary to avoid confusion and potential litigation. I strongly recommend that instead of allowing rebates and other inducements in the marketplace, a zero or very low fee structure should be established. This would eliminate the potential for trading for the sake of volume and promote fair and transparent pricing across trading venues. I urge the commission to implement a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks to promote fairness and transparency in pricing across trading venues. While reducing access fee caps is a positive step, I believe that completely eliminating exchange rebates would further enhance transparency and fairness in the market. 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. This would be a positive step in regaining public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement is critical, and I believe that higher fines, bigger penalties, and actual consequences are necessary to maintain market integrity. Investors should not have to pay the price for being routed through a wholesaler that has been charged over 70 times by the United States government. I urge investors to support paying an additional 0.64 cents per share to avoid being routed through such wholesalers. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. I fully support the harmonisation of tick sizes across all exchanges. No exceptions or vague language should be allowed. All exchanges should operate under the same rules to prevent monopolistic control of parts of the market, which could eventually kill the positive benefits of competition. I believe that the definition of tick-constrained should apply to as much of the market as possible, and the rule would be watered down if the definition is too narrow. It is important that everyone trades and provides quotes according to the same rules. I urge the commission to make it clear that rebates and other inducements in the marketplace are simply payment for order flow by another name. I would prefer that the fees were reduced to zero, but .001 will suffice. The aim is to promote fair and transparent pricing across all trading venues. Finally, 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 that odd lots impact the NBBO and have a concrete effect on both price and broker's duty of best execution. Thank you for your attention to these important issues. Sincerely, Leonard Ford