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: Jason A Karkiewicz
Affiliation:

Mar. 31, 2023

 


Dear Sir/Madam,
 
I am writing to express my strong support for the Securities and Exchange Commission's proposed rule on the National Market System Plan to Address Market Volatility (File No. 4-931) and to recommend additional measures that could further enhance transparency, fairness, and efficiency in the market.
 
Specifically, I strongly support the Commission's proposed tick size regime and believe that it will promote fair and transparent pricing across trading venues. However, I recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation.
 
Furthermore, I believe that eliminating rebates and other inducements in the marketplace would be a positive step towards reducing trading for the sake of volume. Establishing a zero or very low fee structure could achieve this goal.
I also recommend implementing a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks. This would further promote fair and transparent pricing and eliminate opportunities for price manipulation.
 
While reducing access fee caps is a step in the right direction, I believe that completely eliminating exchange rebates would enhance transparency and fairness in the market. Additionally, I recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays.
 
It is crucial to take these steps to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Clear and decisive actions to promote transparency, fairness, and efficiency will help to restore investor confidence and enhance the overall integrity of the market.
Thank you for your consideration.
 
Sincerely,
Jason Karkiewicz
 
Jason Karkiewicz
KOTE INSTRUMENT SERVICE
Radio Channel - CGL


CLEVELAND-CLIFFS INC.
Tek and Kote
30755 Edison Road, New Carlisle, IN 46552-9695
p 574.654.1000   clevelandcliffs.com
 

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