Mar. 30, 2023
Dear Ladies and Gentlemen, I consider this concern very important. The effectiveness of SEC rules relies heavily on the enforcement that supports them. I believe that fines should be increased to serve as a real deterrent, and some broker-dealers should have their licenses revoked instead of receiving fines that are just a cost of doing business. I would be willing to pay 12 cents more per share to avoid being routed through a wholesaler with a long history of charges by the US government, such as Citadel Securities. I strongly support the harmonization of tick sizes across all exchanges to prevent unfair advantages and monopolies, and the elimination of rebates and other inducements in the marketplace. A clear and unambiguous tick size regime is needed without vague language that can be exploited to avoid compliance. I also support the inclusion of odd lot information in the SIP, as odd lots represent a significant portion of trades in the markets, and their exclusion from the NBBO can exclude most individual investors. It is crucial to ensure that odd lots impact the NBBO and have a concrete effect on price and the broker's duty of best execution. I believe that these proposed measures will help to restore public confidence and trust in the market, particularly in light of recent events such as the GameStop controversy. Therefore, I urge the SEC to implement these rules in a clear and unambiguous manner without any vague language to avoid confusion or litigation. I believe that the proposed measures by the SEC to promote fair and transparent pricing across trading venues are important steps towards rebuilding public trust in the market. The elimination of rebates and other inducements in the marketplace and the harmonization of tick sizes across all exchanges are especially crucial. However, it is not enough to simply pass rules without adequate enforcement. The SEC must ensure that the fines imposed for breaking the rules are high enough to serve as a significant deterrent. Instead of receiving fines that are merely a cost of doing business, some broker-dealers should lose their licenses for their repeated violations of the law. I am willing to pay a premium of 12 cents per share to avoid being routed through a wholesaler that has a history of flouting the law, such as Citadel Securities. ( https://files.brokercheck.finra.org/firm/firm_116797.pdf ) Commission fees are preferable to being routed through such unscrupulous actors. The monopolistic control of parts of the market by certain exchanges that receive special treatment must also be addressed. All exchanges should quote and trade in the same increments to ensure fairness and prevent the negative effects of competition being nullified. Clear and unambiguous language is necessary in the application of the SEC's rules. Loose language that can be exploited by firms to circumvent the rules must be avoided to prevent needless litigation and waste of taxpayer dollars. Odd lot information must be included in the SIP to provide individual investors with more information to make better investing decisions. The exclusion of odd lots from the NBBO is problematic as odd lots represent the majority of trades in the markets. They should be included in the calculation of the NBBO to ensure fairness and proportionality. In conclusion, I urge the SEC to implement these proposed measures with strong enforcement and clear language to ensure fair and transparent pricing across trading venues. This is essential to restore public confidence and trust in the market. Sincerely, Marco Biesemann (Retail Investor)