Mar. 24, 2023
Dear SEC, I am writing to express my concern about File No. S7-30-22. I believe that enforcement matters immensely, and without sufficient enforcement, rules mean nothing. I urge you to impose higher fines, bigger penalties, and actual consequences to deter bad actors from breaking the rules. I believe repeated offenders should have their licenses revoked. I want to make it clear that I would gladly pay 0.64 cents more per share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. I also believe that paying a commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities, would be worth it. I fully support the harmonization of tick sizes across all exchanges with no exceptions and no vague language. Some exchanges should not be granted an unfair advantage over others. The markets are supposed to be fair, so make them fair. I suggest that the definition of tick-constrained should apply to as much of the market as possible to avoid watering down the rule. It is important that everyone trades and provides quotes according to the same rules. I strongly dislike the presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name. I would prefer the fees to be reduced to zero, but .001 will do. No higher. I also support the inclusion of odd-lot information in the SIP. Odd lots are a majority of trades and should have a greater impact on price. I believe that odd lots should impact the NBBO and have a concrete effect on both price and broker's duty of best execution. Finally, I firmly oppose the insertion of any vague language into this or any other rule. We can see directly what Citadel is trying to do here - they abuse the "reasonable" language in the naked shorting exception. Let's avoid any loopholes that allow bad actors to circumvent the rules. Thank you for your attention to these important matters. Sincerely, Samuel Cressy Mishawaka, IN