Mar. 26, 2023
To whom it may concern, The proposed tick size regime, variable minimum pricing increment model, and revised round lot definition are important steps towards promoting fair and transparent pricing across trading venues. I strongly support the harmonization of tick sizes across all exchanges and the elimination of rebates and other inducements in the marketplace. It is imperative to establish a zero or very low fee structure to eliminate the potential for trading for the sake of volume. I also support the acceleration of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. Enforcement matters and I STRONGLY recommend much higher fines and consequences for those who break the rules. The current fines are swallowed as a “cost of doing business.” Not only do the fines have to be much higher, but the SEC needs to ban market participants who repeatedly break the rules. Three strikes, you’re out. I believe many investors would be willing to pay an additional 0.64 cents per share to avoid being routed through a wholesaler with a history of breaking the law like Citadel Securities. The price improvement provided by these wholesalers is minimal and not worth the potential damage they bring to the market. I support the inclusion of odd-lot information in the SIP as odd lots represent a majority of trades and should have a greater impact on price. It is important that odd lots impact the NBBO and have a concrete effect on both price and broker's duty of best execution. I also suggest that the definition of tick-constrained should apply to as much of the market as possible to avoid any watering down of the rule. In conclusion, I believe that these proposed measures will help to regain public confidence and trust in the market. It is crucial to ensure that the markets are fair and transparent for all participants, and I strongly urge the SEC to implement these rules in a clear and unambiguous manner. Thanks for your time, Tristan Henderson