Subject: RE: File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders
From: Venessa Myers
Affiliation:

Mar. 19, 2023

I strongly support the Commission's proposed tick size regime, and recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation.Instead of allowing rebates and other inducements in the marketplace, establish a zero or very low fee structure to eliminate the potential for trading for the sake of volume. 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, completely eliminating exchange rebates would further enhance transparency and fairness in the market.Recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. Enforcement matters. We want higher fines, bigger penalties, actual consequences. Investors 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. 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. I very much dislike the presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name. We'd prefer the fees were reduced to zero, but .001 will do. No higher.