Mar. 31, 2023
Dear Sir/Madam, I am writing to provide my comments on File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders. I would like to express my strong support for the Commission's proposed tick size regime and recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. Furthermore, I recommend implementing a zero or very low fee structure to eliminate the potential for trading for the sake of volume. Additionally, I support the implementation of 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, I strongly recommend completely eliminating exchange rebates to further enhance transparency and fairness in the market. I would also recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. The recent events like the GameStop controversy have severely undermined public confidence and trust in the market, and it is essential to take these steps to regain the same. I fully support the harmonization of tick sizes across all exchanges, without any exceptions or vague language. Additionally, I suggest that the definition of tick-constrained should apply to as much of the market as possible, and the rule should not be watered down. I strongly dislike the presence of rebates and other inducements in the marketplace, which are merely payment for order flow by another name. I would prefer that the fees be reduced to zero, but .001 will do, and they should not be higher. Lastly, I support the inclusion of odd-lot information in the SIP, as they are a majority of trades and should have a more significant impact on price. It is imperative to have clear rules that apply to all traders and trading venues to ensure a fair and transparent market. Thank you for considering my comments on this important matter. Sincerely, Christopher Sheehan Household Investor