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

Mar. 18, 2023

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Hi, 


I fully support this rule, which should be implemented as quickly as possible. To make sure SEC rules are effective, robust enforcement is vital. Higher fines that act as a strong deterrent should be imposed. In cases where broker-dealers engage in misconduct, revoking their licenses could be a more effective solution. This way, we can ensure that all market participants are held accountable, ensuring a fair and transparent playing field. 


I fully support uniform tick sizes across all exchanges to prevent monopolistic control of market segments. It's crucial to require all exchanges to quote and trade in the same increments and prevent unfair advantages. This will promote fairness in the markets and ensure equitable opportunities for all participants. 



The exclusion of odd lots from the NBBO is a major concern, especially given that odd lots represent the majority of trades in the markets, and in some cases, the vast majority. This exclusion effectively excludes most individual investors, who make up a significant portion of the voting public. Therefore, it's important to explore ways to fairly and proportionately include odd lots in the calculation of the NBBO. 


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- Jonathan Shaner