Mar. 20, 2023
Dear, I am writing to express my strong support for the Commission's proposed tick size regime and to provide recommendations for further improvements in market structure. Recent events, such as the GameStop controversy, have highlighted the need to regain public confidence and trust in the market. It is vital that we take the necessary steps to promote transparency, fairness, and efficiency in the marketplace. The rule structure of the tick size regime should contain clear and unambiguous language to avoid any confusion or potential litigation. Additionally, establishing a zero or very low fee structure would effectively eliminate the potential for trading solely for the sake of volume, thus reducing the prevalence of rebates and other inducements. Implementing a variable minimum pricing increment model for both quoting and trading of NMS stocks will promote fair and transparent pricing across trading venues, while completely eliminating exchange rebates would further enhance transparency and fairness in the market. In order to enhance reporting efficiency and reduce delays, we recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP. Enforcement matters must be addressed by advocating for higher fines, bigger penalties, and actual consequences to deter and punish unlawful activities. Investors are willing to pay an additional 0.64 cents per share to avoid routing through wholesalers with a troubled history, like Citadel Securities, which have been charged over 70 times by the United States government (https://files.brokercheck.finra.org/firm/firm_116797.pdf). The minimal price improvement provided by these wholesalers does not outweigh the damage they bring to the market. We fully support the harmonization of tick sizes across all exchanges, with no exceptions or vague language. All exchanges should operate on a level playing field to prevent monopolistic control and preserve the benefits of competition. The definition of tick-constrained should apply to as much of the market as possible to avoid watering down the rule. All participants should trade and provide quotes according to the same rules. Reducing fees to zero or .001 is preferred, as we strongly dislike the presence of rebates and other inducements in the marketplace, which are essentially payment for order flow under a different name. Lastly, we support the inclusion of odd-lot information in the SIP, as odd lots represent a majority of trades and should have a greater impact on price. This will also help ensure brokers fulfill their duty of best execution. Taking these steps will not only enhance market efficiency but also restore public trust in our financial markets. Thank you for your attention to these matters, and I look forward to seeing the implementation of these recommendations. Sincerely,