Mar. 31, 2023
Dear Ms. Countryman, I am writing in support of File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders, and the Commission's proposed tick size regime. However, I strongly recommend the use of clear and unambiguous language in the rule structure to avoid any confusion or litigation. I believe that the price improvement provided by wholesalers is minimal and not worth the damage they bring to the market. Investors would pay commission to avoid being routed through a wholesaler, especially one with a long record of ignoring the law like Citadel Securities. Therefore, I recommend that we fully support the harmonization of tick sizes across all exchanges. There should be no exceptions, and clear rules and language are necessary. Some exchanges should not 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 we must make them fair. I suggest that the definition of tick-constrained, whatever it may be, should apply to as much of the market as possible. The rule would be watered down if the definition is too narrow. The important thing is that everyone trades and provides quotes according to the same rules. I do not like the presence of rebates and other inducements in the marketplace. They are simply payment for order flow by another name. I would prefer the fees to be reduced to zero. Finally, I fully support the inclusion of odd-lot information in the SIP. Odd lots are a majority of trades and should have a greater impact on price. I want odd lots to impact the NBBO and have a concrete effect on both price and broker's duty of best execution. Thank you.