Subject: File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders
From: Konstantin Kobanenko
Affiliation:

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