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

Mar. 24, 2023

  


To whom it may concern, 


I am writing this email in support of rule changes that create a fair financial market for all participants. Currently there are market makers who are able to use vague rule language to create orders that are incrementally more appealing than their competitors. By abusing loopholes, they are able to execute orders at multiple decimals of a cent, which is a strategy completely unavailable to many other participants. In order to have a free market, we must all be bound by the same rules and have access to the same tools. The rule change proposed must be approved with clear, unambiguous language to enforce all participants to trade within a minimum pricing increment.  


If a model such as Payment for Order Flow (PFOF) must exist in the US markets, I would strongly suggest changing the structure of rebates surrounding wholesale trading. Ideally, I would like to see rebates removed entirely, and allow for very low fee structures that discourage high volume trading, especially that which can be internalized by market makers for their own advantage. Implementing these changes as soon as possible would be a huge step in regaining the investor's trust in the US financial markets.  


Kind regards, 


Chris Morrow