Mar. 19, 2023
Dear members of the SEC, I am writing to express my strong support for File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders. I believe that the proposed tick size regime is a step in the right direction towards promoting fair and transparent pricing across trading venues. However, I urge the Commission to ensure that the rule structure is clear and unambiguous to avoid any confusion or potential for litigation. Additionally, I strongly recommend that the Commission 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 suggest implementing a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks to further promote fair and transparent pricing. While reducing the access fee caps is a positive step, I believe that completely eliminating exchange rebates would 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, particularly in light of recent events like the GameStop controversy. Additionally, I strongly believe that enforcement matters and urge the Commission to impose higher fines, bigger penalties, and actual consequences to deter bad actors from engaging in fraudulent or manipulative activities. Investors should also have the option to support an additional 0.64 cents per share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. I believe that 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 fully support the harmonization of tick sizes across all exchanges without any exceptions or vague language. Clear rules and clear language are necessary to prevent any unfair advantage over other exchanges. The markets are supposed to be fair, so it is essential to make them fair. I also suggest that the definition of tick-constrained should apply to as much of the market as possible to prevent any watering down of the rule. It is crucial that everyone trades and provides quotes according to the same rules. Lastly, I urge the Commission to include 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 time and consideration. I strongly believe that these recommendations will promote fairness and transparency in the market. Sincerely,