Mar. 31, 2023
Rebates and other inducements in the marketplace are simply payment for order flow by another name. They lead to trading for the sake of volume. I'd prefer the fees were reduced to zero, but .001 will do. No higher. I support establishing a variable minimum pricing increment model that would apply to both the quoting and trading of NMS stocks, which are stocks listed on a national securities exchange, regardless of trading venue. The proposed amendments to Rule 610 would reduce the level of the access fee caps, which limit the fees that can be charged for trading against the best priced quotations displayed in any market. This is a start, but I’d like to see exchange rebates completely eliminated. I support the tick size regime proposed by the Commission, and would also support any structure that is clear and does not rely on vague language. For example, some funds and firms might request language like "has a reasonable amount of liquidity at the NBBO". Loose language makes enforcement difficult or impossible, and wastes taxpayer dollars on needless litigation time. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Please do not include vague language in the application of your rules. I’d like to strongly recommend accelerating implementation of the revised round lot definition, and the odd lot dissemination on the SIP, as contained in the Commission’s Market Data Infrastructure Rule (“MDIR”). This should already be implemented and it’s shocking how long things take in terms of reporting, especially when this Industry is known to do whatever it takes to ensure that trades can occur in nanoseconds. I think it’s imperative that the Commission take these steps in order to start gaining back confidence and trust from the public, and to meet their purpose as regulators. Witnessing what happened with the exteme volatility surrounding Gamestop in early 2021 (and what has continued to happen to a less obvious to the public degree) eroded Investor Confidence so much that Investors have been taking their shares out of the system to hold them with the Transfer Agent directly. I have full faith that my letter will be carefully considered, and my concers will be given due weight. With that, I'd like to again thank you for the opportunity to comment.