Mar. 31, 2023
I have the following recommendations and feedback regarding this rule proposal: The proposed tick size regime is great for retail, and it is recommended that the rule structure incorporates clear and unambiguous language to avoid confusion or litigation. To eliminate the potential for trading for the sake of volume, it is suggested that the marketplace establishes a zero or very low fee structure instead of allowing rebates and other inducements. A variable minimum pricing increment model that applies to both quoting and trading of NMS stocks should be implemented to promote fair and transparent pricing across all trading venues. While reducing the access fee caps is a positive step, it is recommended that exchange rebates be completely eliminated to enhance transparency and fairness in the market. The implementation of the revised round lot definition and odd lot dissemination on the SIP should be accelerated to enhance reporting efficiency and reduce delays. In light of recent events, such as the GameStop controversy, it is emphasized that taking these steps is crucial to regain public confidence and trust in the market. Higher fines, bigger penalties, and 100%+ clawbacks are suggested to strengthen enforcement measures. Investors are happy paying an additional 0.64 cents per share to avoid being routed through a wholesaler that has been charged with financial crimes over 70 times by the United States government. It is noted that the minimal price improvement provided by these wholesalers is not worth the damage they bring to the market. Retail investors would prefer to pay a commission to avoid being routed through a wholesaler, particularly one with a history of violating laws, such as Citadel Securities. The harmonization of tick sizes across all exchanges is an excellent change, and it is recommended that clear and unambiguous language is used in the rule structure to prevent unfair advantages and monopolistic control of parts of the market. The definition of tick-constrained should be as comprehensive as possible to ensure that everyone trades and provides quotes according to the same rules. The presence of rebates and other inducements in the marketplace is viewed unfavorably and should be reduced or eliminated to prevent payment for order flow. The inclusion of odd-lot information in the SIP is agreeable and it should be emphasized that odd lots should have a greater impact on price and broker's duty of best execution. It is recommended that odd lots impact the NBBO and have a concrete effect on both price and best execution. Every trade should have a price impact regardless of size, this is how a free market should operate. Thanks, William Jacob Pennstrom Retail Investor