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: Lee Cunningham
Affiliation:

Mar. 19, 2023

Hello Ms. Countryman, 

I am writing in support of this rule to adjust minimum pricing increments and to reduce rebates and I encourage the SEC to not allow the language of this rule to be watered down by entrenched interests that currently benefit from the asymmetry being appropriately addressed in this proposed rule. 

With the prevalence of high frequency trading there is no reason to incentivize high volume trading. Rebates and other inducements should be disallowed and fees should be zero. This change would be very impactful in regaining a robust and transparent market. 

I fully support the equalization of tick size rules applied across the market. There is no reason for some participants to have access to smaller ticks than others. It promotes wash trading and creates unfair advantage for chosen participants. Tick-constraint and other rules should be applied equally to as much of the market as possible. Individual firms should not be given special advantages and ability to bend and break rules. Markets thrive on transparency and competition, not chosen winners and losers. 

I also fully support odd lots impacting the NBBO and being included in SIP. These proposed changes would make significant headway in improving transparency efficiency and improving trust in the market. These rule changes should be passed with strong and clear language and enforced strictly. I would feel more confident using the market with these rules enforced and I think others would as well. 


Thank you, 

Lee Cunningham