Mar. 26, 2023
March 26, 2023 By Email Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 205499–1090 rule-comments@sec.gov File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders Dear Ms. Countryman, We fully support the proposed measures, including the variable minimum pricing increment model, tick size regime, and revised round lot definition. These steps are crucial in promoting transparent and fair pricing across all trading venues, and we strongly advocate for the harmonization of tick sizes and the elimination of rebates and inducements. To prevent trading for volume's sake, we believe that a zero or low fee structure should be established. We also support the acceleration of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and minimize delays. Enforcement is vital, and we recommend that higher fines, bigger penalties, and actual consequences be enforced for those who break the rules. We think that investors are willing to pay an additional 0.64 cents per share to avoid being routed through a wholesaler with a history of breaking the law, such as Citadel Securities. The minimal price improvement provided by these wholesalers is not worth the potential harm they bring to the market. Odd lots represent most trades, and we support the inclusion of odd-lot information in the SIP, ensuring that odd lots impact the NBBO and have a concrete effect on price and broker's duty of best execution. We 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 summary, we believe that implementing these measures will help to restore public confidence and trust in the market, especially considering recent events such as the GameStop controversy. It is crucial to ensure that the markets are transparent and fair for all participants, and we strongly urge the SEC to implement these rules in a clear and unambiguous manner to prevent confusion or litigation. Sincerely, Juan Corpus Small Business Owner