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

Mar. 18, 2023

 


I've been trading since before decimalization. If wholesale traders can trade between the pricing increments available to all traders, they can steal orders from other parties. They can buy marginally above bid and sell infinitesimally below ask.  I support the proposed rule change to minimum pricing increments. 


I also believe rebates (access fees) are just payment for order flow with extra steps. Just as I support the end of PFOF, I like the proposed rule change restraining rebates. 


I also like the language in the proposal concerning "odd lots". I'm not a rich man. Many of my orders are less than a stack. I like my buys and sells being recorded in national best bid / best offer. I just like it! Why shouldn't smaller orders push price? The exclusion of odd lots seem like a legacy inaccuracy from the days of paper settlements. I say, "do it!" 


Micah Ross