Mar. 31, 2023
Dear Commission Members, I am writing to express my strong support for the proposed tick size regime and to recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. It is imperative to establish a zero or very low fee structure instead of allowing rebates and other inducements in the marketplace to eliminate the potential for trading for the sake of volume. Implementing a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks would promote fair and transparent pricing across trading venues. While reducing the access fee caps is a step in the right direction, completely eliminating exchange rebates would further enhance transparency and fairness in the market. I strongly recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. These steps are necessary to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement matters, and I strongly advocate for higher fines, bigger penalties, and actual consequences. Investors should be willing to support additional 0.64 cents more a share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. Investors will gladly pay a commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. I fully support the harmonization of tick sizes across all exchanges without exceptions or vague language. Clear rules and language are necessary to avoid granting some exchanges an unfair advantage over others. This 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 let us make them fair. The definition of tick-constrained, whatever it is, should apply to as much of the market as possible. The rule would be watered down if the definition is too narrow. It is essential that everyone trades and provides quotes according to the same rules. I strongly dislike the presence of rebates and other inducements in the marketplace. They are merely payment for order flow by another name. I prefer the fees reduced to zero, but 0.001 will suffice. No higher. I support the inclusion of odd-lot information in the SIP, as odd lots are a majority of trades and should have a more significant impact on price. It is vital to make it clear that odd lots should affect the NBBO and have a concrete effect on both price and broker's duty of best execution. Thank you for your attention to these critical matters. I look forward to seeing the Commission's progress in ensuring a fair and transparent market. Sincerely, Kevin Cano Kevin Cano | Data Base Reporting Analyst Grow with us apply @ www.freshexpress.com/careers Fresh Express Incorporated | �� +1-4074076125057 x217 5057 | �� +1-4074072212948 PRIVATE COMMUNICATION: The information contained in this e-mail message is confidential and may be legally privileged. If you are not an intended recipient of this e-mail, be aware that any use, disclosure, publication, distribution or copying of this e-mail message or any part of its content is prohibited and may be unlawful. If you have received this e-mail message in error, please notify the sender and delete the e-mail message from your system.