Mar. 22, 2023
Re: SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22) I support the proposed tick size regime by the SEC but believe it should have clear and unambiguous rules to prevent firms from circumventing them. Vague language leads to litigation and wastes taxpayer money, so I prefer a clear language structure. To enforce the rules, I recommend that the SEC imposes higher fines that serve as a significant deterrent and revokes licenses for broker-dealers who break the rules instead of just paying the fines as a cost of doing business. As a household investor, I think all exchanges should have to quote and trade in the same increments, and I support the harmonization of tick sizes across all exchanges. It is not fair for some exchanges to get special treatment and use it to gain monopolies in certain market areas, as it counteracts the positive benefits of competition. Additionally, I dislike the presence of rebates and other inducements in the marketplace, as they are just payment for order flow by another name. I think access fees should be reduced to zero to avoid any "take." I applaud the SEC's efforts to provide individual investors with more information to make better investing decisions, especially concerning which firms are allowed to handle our orders. I support the inclusion of odd lot information in the SIP, as it represents the majority of trades in the markets. The exclusion of odd lots from the price of a stock amounts to the exclusion of most individual investors, which is a problem. Therefore, I think odd lots should be proportionately included in the calculation of the NBBO to ensure fairness. Thanks, - Household Investor