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: Mike Bodner
Affiliation:

Mar. 31, 2023

 


To whom it may concern, 


I fully support this rule and want to see it implemented as soon as possible. Broker-dealers should lose their licenses instead of recieving miniscule fines that are a small cost of doing "business". I would gladly pay 12 cents more a share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. I fully support the harmonization of tick sizes across all exchanges. Exchanges should have to quote and trade in the same increments. By not enforcing this, certain exchanges are given unfair advantages that damage the markets.  



'Rebates' and 'inducements' are simply PFOF. I would like to reduce access fees to zero; no "take". 


I support the tick size regime proposed by the Commission, especially if it is structured in a clear and concise way that doesn't rely on vague language open to interpretation. For example, some funds and firms might request language like "has reasonable amount of liquidity at the NBBO" actually means "I can ignore this if I feel my lawyers can get away with it". Loose language makes enforcement impossible and is a waste of taxpayer money. A clear and unambiguous rule regarding tick size structure is greatly preferred.  


Please do not include any vague language in the application of your rules.  


I support the inclusion of odd lot info in the SIP. Why are the bids and offers of so many orders kept invisible? If the Commission were to remove odd lot info from this rule, my faith in the US markets would be damaged even more.  


The exclusion of odd lots from the NBBO is a huge problem. Odd lots are a majority of the trades in the markets. For some stocks, the vast majority - which represents most of the voting public. Please fairly and proportionately include odd lots in the calculation of the NBBO. 


Regards, 
Mike Bodner