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: Jordan Manntz
Affiliation:

Mar. 31, 2023

I support this rule change.
As an investor and active participant in the stock market, I have seen firsthand the impact that the Securities and Exchange Commission (SEC) has on the industry. However, I believe that every rule the SEC passes is only as good as the enforcement that backs it. This is why I want to see higher fines that actually serve as a significant deterrent. It's not enough to simply pass a rule - there must be real consequences for those who break it.
One area where I believe the SEC could improve its enforcement is with broker-dealers. Some of them should lose their licenses instead of receiving fines that amount to nothing more than a cost of doing business - a cost that is often outweighed by the ill-gotten gains obtained through "honest mistakes". We need to send a clear message that unethical behavior will not be tolerated in our markets.
Another issue that concerns me is the use of wholesalers that have a history of flouting the law. I would gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of breaking the law. In fact, I would even pay more a share to avoid being routed through a wholesaler that has been charged by the United States government.
I also support the harmonization of tick sizes across all exchanges. It's shocking to learn that some exchanges get special treatment and are able to leverage that to build monopolies in some areas of the market. All exchanges should have to quote AND trade in the same increments. It's not fair for some exchanges to be granted an unfair advantage over others, as 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 dislike the presence of rebates and other inducements in the marketplace. They are simply payment for order flow by another name. Instead, I would prefer the SEC reduce access fees to zero. It's important that we eliminate any conflicts of interest that could compromise the integrity of our markets.
I also support the tick size regime proposed by the Commission and would also support any structure that is clear and does not rely on vague language. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Please do not include vague language in the application of your rules. Loose language makes enforcement difficult or impossible and wastes taxpayer dollars on needless litigation time.
Finally, I support the inclusion of odd lot information in the SIP. Two years ago, the majority of trades in the markets were odd lots, and for certain tickers, this proportion is certainly much higher. If the Commission were to remove odd lot information from this rule, my faith in the U.S. markets would become even more damaged than it already is. I also believe that the exclusion of odd lots from the NBBO is a problem. Odd lots are now a majority of trades in the markets, and the exclusion of odd lots from the price of a stock amounts to the exclusion of most individual investors - most of the voting public. The SEC should look into a way to fairly and proportionately include odd lots in the calculation of the NBBO.
Sincerely,
 
Jordan Manntz
A Fair Market Activist