Mar. 31, 2023
Dear Sir/Madam, I strongly support the Commission's proposed tick size regime and recommend clear language to avoid confusion or litigation. Instead of allowing rebates and other incentives in the market, establish a zero or very low fee structure to eliminate trading for the sake of volume. Implement a variable minimum pricing increment model for NMS stocks to promote fair and transparent pricing across trading venues. While reducing access fee caps is a step in the right direction, completely eliminating exchange rebates would enhance transparency and fairness in the market. Accelerate the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. Regaining public confidence and trust in the market is crucial, particularly in light of recent events like the GameStop controversy. We need stronger enforcement with higher fines, bigger penalties, and real consequences. Investors would gladly pay a commission to avoid being routed through a problematic wholesaler like Citadel Securities. I fully support the harmonization of tick sizes across all exchanges with clear rules and language to prevent unfair advantages and promote fair competition. The definition of tick-constrained should apply to as much of the market as possible to ensure everyone trades according to the same rules. Rebates and other incentives in the market should be eliminated or reduced to a minimum fee to prevent payment for order flow. Odd-lot information should be included in the SIP to have a greater impact on price and ensure brokers' duty of best execution. Kindly yours, Konstantin Kobanenko