Mar. 23, 2023
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. 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