Subject: Re: SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22)
From: Christopher Van Kleeck
Affiliation:

Mar. 26, 2023

  


I appreciate the opportunity to provide a perspective on this proposal. First- I believe the fees which have been levied against rulebreakers have been far too lenient. Too often in modern business fees and fines become a cost of doing business. Fees need to scale with the amount of profit that was derived from an infraction, and the fee needs to exceed that profit if it is ever going to be a meaningful part of the decision making process for market makers.  


I believe a rule could go even further, and revoke or suspend operating licenses for infractions, but I recognize that without intermediary plans in place that would heavily impact a market made fragile by heavy centralization. 


As a member of retail, I would much rather pay a per share fee than have my orders collected and sold off. Some traders may prefer the current structure, in which case I'd suggest the option for any investor to see their buy or sale order reach the public market and effect price discovery. I am also supportive, therefore, of odd lots seeing inclusion in future NBBO calculations. The more raw data which reaches a public order book, the more information is available to retail investors to make calculated and careful personal decisions. The markets should reflect the sentiments of those using it, in totality, rather than the opaque structure currently in place.