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. 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 is one of the first steps to regain public confidence enforcement matters. We want higher fines, bigger penalties, actual consequences. 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 equaling the tick sizes across all exchanges. No exceptions, no "reasonable" vague language. Clear rules, clear language. Some exchanges shouldn’t be granted an unfair advantage over others. It leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. Make the markets fair. The definition of tick-constrained, whatever it is, should apply to as much of the market as possible. The rule would be watered down if the definition is too narrow. The important thing is that everyone trades and provides quotes according to the same rules. The current presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name which opens up an avenue to fraud and abuse. Odd lots must also impact the NBBO and have a concrete effect on both price and broker's duty of best execution.