Mar. 31, 2023
To whom it may concern, I am in complete support of this rule as a household (retail) investor, and believe it will make the US stock market a more equitable and fair place to invest. I am a foreign investor based in the UK with a very keen interest in US companies who lead globally in their domains. The current state of the market is flawed, and rules like the order competition rule are key to ensuring the integrity, credibility and functioning of the american markets. My stance is in favor of the tick size regime proposed by the Commission, as well as any structure that is precise and devoid of ambiguous language. I believe that some entities, including funds and firms, may request vague language such as "reasonable amount of liquidity at the NBBO," which essentially allows them to disregard the rule, exploiting legal loopholes. Such looseness in language complicates enforcement and leads to unnecessary litigation expenses, ultimately burdening taxpayers. Thus, I strongly urge the Commission to prioritize clarity and unambiguous tick size rule structures while avoiding the use of vague language in the application of rules. I am in favor of the inclusion of odd lot information in the SIP, and I commend the Commission for its efforts to empower individual investors with more data to make informed investment decisions, particularly with respect to which firms can handle our orders. As per a source (https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing/), odd lots accounted for the majority of trades in the markets two years ago (55%), and this proportion is much higher for certain tickers. It begs the question as to why the bids and offers of so many orders remain concealed. Should the Commission exclude odd lot information from this regulation, it would further erode my confidence in the U.S. markets. I believe the exclusion of odd lots from the NBBO is a problem. Odd lots are now a majority of trades in the markets. Within some stocks, they are the vast majority. The exclusion of odd lots from the price of a stock amounts to the exclusion of most individual investors - most of the voting public. Please look into a way to fairly and proportionately include odd lots in the calculation of the NBBO. Further, in my opinion, instead of imposing fines that merely serve as a cost of conducting business, which is often exceeded by the unjust benefits gained from "honest mistakes," broker-dealers that are repeat offenders ought to forfeit their licenses. Sincerely, Daniel Powell