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

Mar. 30, 2023

 





Dear fellow American, 

     I am writing to express my support for the proposed tick size regime, variable minimum pricing increment model, and revised round lot definition. These measures are critical to promoting fair and transparent pricing across trading venues. I fully endorse the harmonisation of tick sizes across all exchanges and the elimination of rebates and other inducements in the marketplace. It is essential to establish a zero or very low fee structure to prevent trading for the sake of volume. I 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 of these rules is crucial, and I strongly recommend higher fines, bigger penalties, and actual consequences for those who break the rules. I believe that 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.
I also support the inclusion of odd-lot information in the SIP, as odd lots represent a majority of trades and should have a more significant impact on price. It is vital that odd lots impact the NBBO and have a tangible effect on both price and the broker's duty of best execution. I suggest that the definition of tick-constrained should apply to as much of the market as possible to avoid dilution of the rule.
In conclusion, I believe that these proposed measures will help to restore public confidence and trust in the market, especially in light of recent events such as the GameStop controversy. It is essential to ensure that the markets are fair and transparent for all participants, and I strongly urge the SEC to implement these rules in a clear and unambiguous manner to avoid confusion or litigation.
Thank you for considering my views on this important issue.
Sincerely,
Kyle Thornton, a real, actual person and not a bot.