Mar. 19, 2023
Dear SEC, I am writing to express my strong support for the proposed tick size rule (File No. S7-30-22). The implementation of this rule is crucial for leveling the playing field in the financial markets and ensuring fair and transparent pricing across trading venues. I encourage the Commission to adopt clear and unambiguous language in the rule structure to avoid confusion or litigation. Instead of allowing rebates and other inducements in the marketplace, I recommend establishing a zero or very low fee structure to eliminate potential conflicts of interest and trading for the sake of volume. Implementing a variable minimum pricing increment model for both quoting and trading of NMS stocks is essential to promoting transparency and fairness. While reducing access fee caps is a step in the right direction, completely eliminating exchange rebates would further enhance market transparency and fairness. I also recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to improve reporting efficiency and reduce delays. Taking these steps is vital to regaining public confidence and trust in the market, especially in light of recent events like the GameStop controversy. Enforcement matters should be addressed with higher fines, bigger penalties, and actual consequences. Investors are willing to support additional costs to avoid routing through a wholesaler with a long record of flouting the law. I fully support the harmonization of tick sizes across all exchanges with clear rules and language, ensuring fairness and preventing monopolistic control. I strongly suggest that the definition of tick-constrained applies to as much of the market as possible to prevent a watered-down rule. The presence of rebates and other inducements in the marketplace should be minimized, as they are simply payment for order flow by another name. Lastly, I support the inclusion of odd-lot information in the SIP, which should have a concrete effect on both price and brokers' duty of best execution. Thank you for considering my input on this important matter. Sincerely, Robert Alexander Waelder from Gainesville Florida