Subject: Comment on File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders
From: Lars Wohlfahrt
Affiliation:

Mar. 23, 2023

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Dear Sir or Madame,

I am writing to express my strong support for File No. S7-30-22; Release
No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees,
and Transparency of Better Priced Orders. I believe that the proposed
rule will promote fair and transparent pricing across trading venues,
ultimately benefiting investors and strengthening the broader economy.

I strongly recommend clear and unambiguous language in the rule
structure to avoid any confusion or litigation. Additionally, I suggest
establishing a zero or very low fee structure to eliminate the potential
for trading for the sake of volume instead of allowing rebates and other
inducements in the marketplace. Implementing a variable minimum pricing
increment model that applies to both quoting and trading of NMS stocks
will promote fair and transparent pricing across trading venues.

While reducing the access fee caps is a step in the right direction, I
strongly believe that completely eliminating exchange rebates would
further enhance transparency and fairness in the market. Furthermore, I
recommend accelerating the implementation of the revised round lot
definition and odd lot dissemination on the SIP to enhance reporting
efficiency and reduce delays.

I strongly support the inclusion of odd-lot information in the SIP.
Given that odd lots constitute a majority of trades, they should have a
significant impact on the price of securities. Therefore, I urge the SEC
to ensure that odd-lots are reflected in the National Best Bid and Offer
(NBBO) and have a measurable effect on both price and the broker's duty
of best execution. I believe that this will enhance transparency and
fairness in the market, ultimately benefiting investors and promoting a
healthy economy.


I cannot emphasize enough the importance of taking these steps to regain
public confidence and trust in the market, particularly in light of
recent events like the GameStop controversy. Adopting the proposed rule
will promote fair and transparent pricing across trading venues,
ultimately benefiting investors and strengthening the broader economy.

Thank you for your attention to this important matter.

Sincerely,

Lars Wohlfahrt