Mar. 18, 2023
Hello, I am an investor and I thank you for the opportunity to comment on this rule. Firstly and perhaps most importantly, we know that the SEC's rules are only as good as the enforcement that backs them. Without meaningful consequences, businesses continue to see the rare miniscule fines as simply a cost of doing business. This has not been an effective deterrent. Higher fines would be a start but serious enforcement means penalties that are double the profits, revoking licenses, and criminal charges when needed. In case SEC needs more funding, enforcing higher fines is even more critical. If the SEC feels it does not have the authority to enforce their rules, the U.S. Department of Justice and Federal Bureau of Investigations have been effective partners in the past. There are solutions if the SEC wants to enact better protections for investors. As for this rule, I fully support the harmonization of tick sizes across all exchanges. No exchanges should be granted an unfair advantage over others, and especially not ones with a long record of flouting the law like Citadel Securities (https://files.brokercheck.finra.org/firm/firm_116797.pdf). Personally, I would strongly prefer to pay commission to avoid being routed through these questionable repeat offenders. A simpler solution is to just remove the special treatments, of course. Exploiting investors by making them pay for the privilege of opting out just shifts the problem. Tangentially, I also strongly object to rebates and other inducements in the marketplace that are still plainly payment for order flow, rebranded. I support the tick size regime proposed by the Commission, and urge you to ensure the rule is structured tightly and does not rely on vague language. We have seen funds and firms requesting purposefully vague language like "has a reasonable amount of liquidity at the NBBO". This is not the place for ambiguity. Let the rule set expectations in stone. Loose language only makes enforcement more difficult or impossible, wasting taxpayer's time and money. Please do not include vague language in the application of your rules. I support the inclusion of odd lot information in the SIP, to provide individual investors with the transparency they need to make fair investing decisions. Two years ago, the majority of trades in the markets were odd lots (55%; from https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing/). For certain tickers, this proportion is even more skewed. There is no reason why such a large volume of bids and offers should be kept invisible; it puts individual investors at a huge disadvantage. I truly believe that knowledge is power, and the only fair market is a transparent one. Thank you again for considering my sincerest response to proposed rule No. S7-30-22. I appreciate any opportunity to participate and have my personal interests represented at the SEC. Kindly, J. Campbell Canadian, Investor