Mar. 31, 2023
To whom it may concern at the SEC, Thank you for proposing this rule. As a concerned individual investor, I am encouraged to see proposals that improve transparency and make markets more fair. That being said, while I wholeheartedly agree with the spirit of the rule, I believe that there are some areas that need further attention and/or clarification before it is ready. I am concerned about the vague language used in areas of the proposed rule, particularly the words "reasonable". I feel that the ambiguity of this word has a tendency to be exploited and potentially abused. Therefore, I urge the use of concrete, well-defined language that leaves no room for interpretation. Secondly, I believe that the effective enforcement of this rule is crucial. To ensure that the rule serves as a real deterrent, I would urge the SEC to impose higher fines and revoke the licenses of broker-dealers who breach rules repeatedly. The current fines seem like a cost of doing business and do not prevent ill-gotten gains obtained through "honest mistakes". This is especially evident when seeing how many repeat offenders there are (i.e. hedge funds) where the fine is a mere fraction of the gains. Lastly, I believe that odd lot information should be included in the SIP. I would also urge the SEC to consider including odd lots into the calculation of the NBBO. The exclusion of odd lots means that the majority of individual investors are essentially excluded from affecting the price of a stock. Thank you for your consideration of my comments. Sincerely, Eugene Horikoshi