Mar. 31, 2023
March 31, 2023 The proposed S7-30-22 regulation addresses tick sizes, access fees, and transparency of better priced orders. The use of rebates and other incentives in the marketplace is essentially the same as payment for order flow, which promotes trading for the sake of volume. While I prefer zero fees, I would accept a maximum fee of 0.001. I support a variable minimum pricing model for NMS stocks, regardless of trading venue. The proposed amendments to Rule 610 would lower the cap on access fees that can be charged for trading against the best priced quotations displayed in any market. However, I believe exchange rebates should be eliminated entirely. I agree with the proposed tick size regime and prefer a clear rule structure without vague language that could complicate enforcement and result in costly litigation. The revised round lot definition and odd lot dissemination on the SIP, as contained in the Commissions Market Data Infrastructure Rule, should be implemented promptly to restore public trust, which has been eroded by events such as the Gamestop controversy. I hope my comments will be given careful consideration. Thank you for the opportunity to express my views.