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

Mar. 27, 2023

 


To whom it may concern,

I am an individual investor and I would like to voice my STRONG support for this proposed rule. It is frankly ridiculous that firms can use any level of float precision for their trades that they want. It should be established in clear, unambiguous language what the minimum price increment should be, so that confusion can be avoided, so that loopholes can be preemptively closed, and so that litigation against it won’t have any legs to stand on. This will ensure fairness across the board. Specify precisely what the increment should be, as a decimal related to the active currency, and ensure that it applies to every exchange under your jurisdiction.

I would like to see a fee structure to eliminate the potential for trading for the sake of creating volume, rather than rebates or other inducements, which effectively act as Payment for Order Flow (PFOF). Reducing access fee caps is a good step, but eliminating them and the rebates entirely would be much better.

I fully support the idea of adding a fee to share transactions to ensure that those transactions are not routed through market makers and wholesalers who have a history of criminal activity as evidenced through their numerous fines.

The definition of “tick-constrained” should apply to as much of the market as possible. This should be spelled out in the regulation to avoid confusion and litigation.

I would like to see odd-lot information included in the SIP. These transactions make up the majority of trades, but because they are not included, they do not have as great an impact on price discovery. I would prefer to see them impact the NBBO as effectively as possible so that they have a tangible, concrete effect on both price and the broker’s duty of best execution.

Thank you for your time.

Regards,
-Joshua Curtis