Mar. 18, 2023
The effectiveness of SEC rules depends on their enforcement, and higher fines should be imposed to serve as a real deterrent. Rather than paying fines that are merely a cost of doing business, some broker-dealers should have their licenses revoked for repeated violations. I am willing to pay more per share to avoid being routed through wholesalers with a history of government charges, such as Citadel Securities. I support the harmonization of tick sizes across all exchanges to prevent unfair advantages and monopolistic control. The presence of rebates and other incentives in the marketplace should be eliminated, and access fees should be reduced to zero. I agree with the proposed tick size regime and prefer clear and unambiguous rules without vague language, which wastes taxpayer dollars on needless litigation time. Including odd lot information in the SIP will provide individual investors with more information to make better investment decisions, and the exclusion of odd lots from the NBBO is a problem that needs to be addressed proportionately. A broker routing orders first to a wholesaler, who then passes them to the auction, which might route it back to the wholesaler, seems unnecessarily complex and also grants the wholesaler a profound information advantage against other market participants: they get to see orders well before anyone else. The Commission should address this unfair information advantage by having brokers first route to the auction and specify where the order should go if the auction is unsuccessful. That way the entire market has equal knowledge. I also support the inclusion of odd lot information in the SIP, as this will provide individual investors with more information to make better investment decisions. Excluding odd lots from the NBBO is a problem because it excludes most individual investors, who make up the majority of the voting public. It is important to find a way to include odd lots in the calculation of the NBBO proportionately. Sincerely, A Household Investor