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

Mar. 18, 2023

 


Dear Securities and Exchange Commission, 

I am writing to express my concerns regarding the enforcement of rules in the securities industry. In my opinion, the effectiveness of any rule passed by the SEC is only as good as the enforcement behind it. To this end, I would like to see higher fines that serve as a real deterrent, and I believe that some broker-dealers should lose their licenses instead of receiving fines that amount to nothing more than a cost of doing business. 

As an investor, I am willing to pay more to avoid being routed through wholesalers that have been charged multiple times by the United States government, such as Citadel Securities. I strongly support the harmonization of tick sizes across all exchanges, as I believe that granting certain exchanges special treatment leads to monopolistic control of parts of the market that counteract the positive benefits of competition. I also oppose the presence of rebates and other inducements in the marketplace, as they are simply payment for order flow by another name. 

Furthermore, I support the tick size regime proposed by the Commission and any structure that is clear and unambiguous. Loose language in the rules makes enforcement difficult and wastes taxpayer dollars on needless litigation time. I also believe that the inclusion of odd lot information in the SIP is crucial for providing individual investors with more information to make better investing decisions. Excluding odd lots from the NBBO is a problem as odd lots are now the majority of trades in the markets, and I urge the Commission to find a way to fairly and proportionately include odd lots in the calculation of the NBBO. 

Thank you for your attention to these important matters. 

Sincerely, 

Alex Scharfe