Mar. 30, 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 suggested changes to tick size, minimum pricing increment model, and round lot definition are crucial for promoting equitable and transparent pricing on trading platforms. We fully endorse the standardization of tick sizes and the removal of rebates and other incentives in the market. It is essential to establish a zero or low-fee structure to discourage trading for the sake of volume. Additionally, we support expediting the implementation of revised round lot definitions and odd lot dissemination on the SIP to improve reporting efficiency and minimize delays. Enforcement is critical, and we strongly recommend imposing higher fines, bigger penalties, and real consequences for violators of the rules. We believe that investors would be willing to pay an additional 0.64 cents per share to avoid routing through unscrupulous wholesalers like Citadel Securities, whose minimal price improvement is outweighed by their potential harm to the market. We also support including odd-lot information in the SIP as it constitutes the majority of trades and should have a significant impact on pricing. It is crucial to ensure that odd lots influence the NBBO and have a tangible effect on both price and the 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 prevent any dilution of the rule. In conclusion, we believe that implementing these measures will restore public confidence and trust in the market, particularly in the wake of recent controversies such as the GameStop debacle. It is crucial to ensure fairness and transparency for all market participants, and we strongly urge the SEC to implement these rules clearly and unambiguously to prevent confusion or litigation. I hope you seriously consider the passing of; File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders. Thank you, Max Knaus