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: Chris McBride
Affiliation:

Mar. 31, 2023

 


Hello SEC,  



As a concerned and interested stockholder, shareholder, and investor in the United States equity markets, I want my support for this rule to be recorded.   



I strongly support the Commission's proposed tick size regime, and recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. Instead of allowing rebates and other inducements in the marketplace, the SEC and its rules should help establish a zero or very low fee structure to eliminate the potential for trading for the sake of volume.  This rule should help implement a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks to promote fair and transparent pricing across trading venues while reducing the access fee caps is a step in the right direction, completely eliminating exchange rebates would further enhance transparency and fairness in the market. 




I recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. These steps are required to regain public confidence and trust in the market, particularly in light of recent events and speculation around rampant and illegal behaviors by market makers.   


I fully support the harmonization of tick sizes across all exchanges. No exceptions, no "reasonable" vague language. Investors like myself demand clear rules and clear language. Certain exchanges shouldn’t be granted an unfair advantage over others. It leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets are supposed to be fair - so make them fair.



I also support the inclusion of odd-lot information in the SIP. Odd lots are a majority of trades, espeically by retail investors, and should have a greater impact on price than they currently do. I want odd lots to impact the NBBO and have a concrete effect on both price and broker's duty of best execution.



At the end of the day, enforcement of new and existing rules matters more than anything else.  I demand to see higher fines, bigger penalties, and actual consequences. SEC violations and resulting fines cannot be a relatively small cost of doing business, it must create and enforce fair markets by having fines be larger than profits.



With urgency and high expectations, 
Christopher McBride