Subject: Re: SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22)
From: Eileen Loh
Affiliation:

Mar. 19, 2023

Price “improvement” by wholesalers is minimal at best and certainly not worth the disruption of free and fair markets.

I would gladly pay more per share to avoid being routed through a wholesaler, especially one that has been charged more than 70x by the US government (aka Citadel Securities, which publicly opposes this rule).

I fully support the harmonization of tick sizes across all exchanges WITHOUT EXCEPTION. Furthermore, the definition of “tick constrained“ should be applicable to all players in the market.

I am against rebates and other inducements in the marketplace, as they are simply another version of payment for order flow.

I support the inclusion of odd-lot information in the SIP. I would like odd lots to impact the NBBO and have a concrete effect on both price and broker’s duty of best execution.

Sincerely,
Eileen Loh
New Orleans, La