Mar. 24, 2023
Dear Sir/Madam, I support this rule. I strongly advocate for the Commission's proposed tick size regime, and would urge the use of clear, precise language in the rule structure to prevent any misunderstanding or legal challenges. Instead of permitting rebates and other incentives in the market, institute a zero or very low fee structure to put an end to trading for the sake of volume. I’d like to see an introduction of a variable minimum pricing increment model for both quoting and trading of NMS stocks to ensure fair and transparent pricing throughout all trading venues. While reducing the access fee caps is a positive step, completely abolishing exchange rebates would bring greater transparency and equity to the market. I would also urge acceleration of the revised round lot definition and odd lot dissemination on the SIP to raise reporting efficiency and reduce delays. I would like to highlight the essentiality of taking these steps to restore public confidence and trust in the market, especially in light of events such as the GameStop saga. It is essential that enforcement is taken seriously, with higher fines, larger penalties, and real consequences. I would also support suggesting to investors adding an additional 0.64 cents a share to avoid being routed through a wholesaler that has been fined over 70 times by the United States government (https://files.brokercheck.finra.org/firm/firm_116797.pdf). The price improvement from such wholesalers is negligible and not worth the damage they bring to the market. Investors are willing to pay commission to avoid being routed through a wholesaler, especially ones with a long record of subverting or breaking the law. I would call for the harmonization of tick sizes across all exchanges. No exceptions, no "reasonable" or vague language. Clear rules, clear language. Certain exchanges should not be given an unfair advantage over others as it can lead to monopolistic control of the market that hinders and ultimately destroys the benefits of competition. The markets are meant to be fair - so make sure they are. I would also suggest that the definition of tick-constrained, whatever it is, should apply to as much of the market as possible. The rule would be rendered ineffective if the parameters are too narrow. The most important thing is that everyone trades and provides quotes under the same rules. I do not approve of rebates and other incentives in the marketplace - they are essentially payment for order flow by another name. Reduce fees to zero, but no higher than .001. Rather I would like to see the addition of odd-lot information in the SIP. Odd lots make up the majority of trades and should have a bigger impact on price. Odd lots should influence the NBBO and have a noticeable impact on price and broker's duty of best execution. Thank you for your consideration, ZK.