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

Mar. 31, 2023

 


To whom it may concern, 


      The SEC needs more significant fines to serve as a deterrent, the current practices are minor obstacles for brokerages and other market participants to keep violating rules as the relative cost is not great to them. 


      Consistent violations by the same brokerages/broker-dealers needs to have enforcement practices involving the suspension of the brokerages themselves. Those firms consistently violated rulings are going to keep doing so as long as the fines are not significant with respect to the funds gained by violating the rules. 


      Commision orders should be reinstated as wholesalers have on going history of flouting the law and obfuscating market operations in their favor. 


      Tick sizes should be harmonized across all exchanges, some exchanges are leveraging the disparities and are forming monopolies in some of the markets. All exchanges must quote and trade in the same increments. These practices require SEC intervention to promote market competition and fair operation to all market participants. 
Rebates and other inducements are similar to PFOF and need to be mitigated. 


      Furthermore, language that is broad is difficult for enforcement, and transparent and precise language regarding the tick size ruling must be included. 


      I support the inclusion of odd lot information in the SIP, and applaud the Commission's efforts to provide individual investors with more information with which to make better investing decisions - especially concerning which firms are allowed to handle our orders. Two years ago, the majority of trades in the markets were odd lots Why are the bids and offers of so many orders kept invisible?