Subject: File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders
From: Scott Witte
Affiliation:

Mar. 26, 2023

  


Citadel has an unfair advantage where they can trade at sub-penny intervals on their single-dealer platform, while everyone else is limited to trading in penny increments. Unbelievable!
The proposed rule would level the playing field by allowing everyone to trade at sub-penny intervals, eliminating this unfair advantage. 
Additionally, the rule would reduce the rebates that can be paid, making payment for order flow much less useful. Although the rule wouldn't ban payment for order flow altogether, it would significantly minimise its impact toward a fair and transparent market. 




Thank you