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: Sunny V Karnani
Affiliation:

Mar. 31, 2023

 


Ms. Countryman 



Please accept this message as my expressing support for the Commission's proposed tick size regime. This along with clear language in the rule structure to avoid ambiguity or litigation would be appreciated. For example, tick-constrained, whatever its definition, 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. Also, rebates and inducements should be banned from the marketplace. They function just like PFOF, but with a different name. 



Odd-lot information should be included in the SIP. Household investors represent the majority of odd lot trades and it should have an impact on the NBBO. Suppressing this data affects best execution and is another mechanism where household investors get skimmed. 



Finally, and as mentioned in a previous comment: Enforcement matters. Higher fines and actual consequences are required to ensure that market participants in a fair and transparent manner. 



Thank you, 

Sunny Karnani