Mar. 27, 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 measures of the tick size regime, variable minimum pricing increment model, and revised round lot definition are essential to promote fair and transparent pricing across trading venues. We support the harmonization of tick sizes across all exchanges and the removal of rebates and other incentives in the marketplace. Establishing a zero or low fee structure is crucial to prevent trading for the sake of volume. The acceleration of the revised round lot definition and odd lot dissemination on the SIP will increase reporting efficiency and reduce delays. Enforcement is crucial, and we recommend higher fines, larger penalties, and actual consequences for those who violate the rules. To avoid being routed through a wholesaler with a history of breaking the law like Citadel Securities, investors would be willing to pay an additional 0.64 cents per share. The price improvement offered by these wholesalers is minimal and not worth the potential damage they could bring to the market. We support the inclusion of odd-lot information in the SIP as odd lots make up the majority of trades and should have a greater impact on price. Odd lots must affect the NBBO and have a concrete effect on both price and broker's duty of best execution. We 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 are necessary to regain public confidence and trust in the market, particularly in light of recent events such as the GameStop controversy. The markets must be fair and transparent for all participants, and we urge the SEC to implement these rules clearly and unambiguously to avoid any confusion or litigation. Met vriendelijke groet / with kind regards, Eege Klop Oprichter