Mar. 31, 2023
I am writing to express my strong support for the Commission's proposed tick size regime and to encourage the implementation of additional measures aimed at increasing transparency, fairness, and efficiency in the market. I would like to emphasize the importance of using clear and unambiguous language in the rule structure to prevent confusion or litigation. To further promote fair and transparent pricing, I recommend implementing a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks across trading venues. Instead of allowing rebates and other inducements in the marketplace, establishing a zero or very low fee structure would eliminate the potential for trading merely for the sake of volume. Reducing access fee caps is a step in the right direction, but completely eliminating exchange rebates would enhance transparency and fairness in the market even further. Additionally, I recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to improve reporting efficiency and reduce delays. Enforcement is crucial. Higher fines, bigger penalties, and tangible consequences must be put in place to deter violations. Investors are willing to pay an additional 0.64 cents per share to avoid being routed through wholesalers with a history of misconduct, such as Citadel Securities, who has been charged over 70 times by the United States government https://files.brokercheck.finra.org/firm/firm_116797.pdf The minimal price improvement provided by these wholesalers is not worth the damage they inflict on the market. I fully support the harmonization of tick sizes across all exchanges without exceptions or vague language. This approach will prevent unfair advantages and monopolistic control, ensuring a fair and competitive market. The definition of tick-constrained should be broad, applying to as much of the market as possible. i am also concerned regarding the presence of rebates and other inducements in the marketplace, which are, in essence, payment for order flow by another name. As a concerned investor, I firmly believe that the elimination of these practices is crucial for ensuring a fair and transparent market environment. I would prefer if the fees associated with these practices were reduced to zero, but I understand that may not be immediately feasible. In that case, I would like to see fees capped at no higher than $0.001 per share. This reduction would help level the playing field and discourage the potentially harmful effects of rebates and inducements on the market. Additionally, I wholeheartedly support the inclusion of odd-lot information in the Securities Information Processor (SIP). Considering that odd lots constitute a majority of trades, it is essential for them to have a more significant impact on price. I urge the SEC to ensure that odd lots affect the National Best Bid and Offer (NBBO) and have a concrete influence on both price and broker's duty of best execution. The implementation of these changes will contribute to a more transparent, fair, and competitive marketplace. By addressing the issue of rebates and inducements, as well as the inclusion of odd-lot information in the SIP, the SEC will take significant steps towards protecting investors and maintaining the integrity of our financial markets.