Mar. 26, 2023
Vanessa Countryman, Secretary, U.S. Securities and Exchange Commission, 100 F Street, N.E, Washington, D.C. 20549 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: 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. We strongly support the harmonisation 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. We 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 we strongly recommend higher fines, bigger penalties, and actual consequences for those who break the rules. We believe 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. We 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. 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 conclusion, we believe that these proposed measures will help to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. It is crucial to ensure that the markets are fair and transparent for all participants, and we strongly urge the SEC to implement these rules in a clear and unambiguous manner to avoid confusion or litigation. Please find the following ensemble of points I would like you to consider within the implementation and enforcement of the aforementioned rule. I strongly support the Commission's proposed tick size regime, and recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. Instead of allowing rebates and other inducements in the marketplace, establish a zero or very low fee structure to eliminate the potential for trading for the sake of volume. Implement a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks to promote fair and transparent pricing across trading venues. While reducing the access fee caps is a step in the right direction, completely eliminating exchange rebates would further enhance transparency and fairness in the market. Recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. Highlight the importance of taking these steps to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement matters. We want higher fines, bigger penalties, actual consequences. Investors to support additional 0.64 cents more a share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government (https://files.brokercheck.finra.org/firm/firm_116797.pdf). The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. Investors will gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. I fully support the harmonisation of tick sizes across all exchanges. No exceptions, no "reasonable" vague language. Clear rules, clear language. Some exchanges shouldn’t be granted an unfair advantage over others. It leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets are supposed to be fair - so make them fair. Suggest that the definition of tick-constrained, whatever it is, should apply to as much of the market as possible. The rule would be watered down if the definition is too narrow. The important thing is that everyone trades and provides quotes according to the same rules. Make it clear you very much dislike the presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name. We'd prefer the fees were reduced to zero, but .001 will do. No higher. I 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 want odd lots to impact the NBBO and have a concrete effect on both price and broker's duty of best execution. Thank you for your consideration. Household Investor.