Mar. 31, 2023
Dear Civil Servant, As an individual retail investor, I am grateful for these efforts to create more competition and transparency in the market, I am glad to comment on these proposals. I see these are large recommended enhancements to market structure and hope you keep the spirit of these change to be effective and true. Every rule the SEC passes is only as good as the enforcement that backs it. I want to see higher fines that actually serve as a significant deterrent and not as a TAX INCENTIVE! Wallstreet players, Broker-dealers or other authority that retail NEED to trust if need to delegate responsibility, abuse of trust should lose their licenses instead of receiving fines when the intent harms retail to use conflict of interest, system is poorly managed or is negligent at best. The practice amounts to nothing more than the cost of doing business - a cost that is often outweighed by the ill-gotten gains obtained through “honest mistakes”, "without admitting or denying fault right"? As I am pointed out, the service for these "sophisticated" trading systems are not for retail benefit since I can 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 (https://files.brokercheck.finra.org/firm/firm_116797.pdf). Logically I would pay commission to avoid being routed through a wholesaler, especially one with a long rap sheet of breaking the law like Citadel Securities. Rules for me, rules for thee right? I fully support the harmonization of tick sizes across all exchanges. it sounds ridiculous that coupon and rebate incentives some exchanges do to compete against other aspiring monopolies that do get special treatment and are able to leverage that special treatment to dominate in some areas of the market. Needlessly complex plumbing of the market in the name of competition for Wallstreet players to fight over RETAIL BEING THE PRODUCT! All exchanges should have to quote AND trade in the same increments. Exchanges shouldn’t be granted an unfair advantage over others, does not promote healthy open competition market, leads to abnormal monopolistic control of parts of the market that is counter-intuitive and kills the positive benefits of competition. The markets are supposed to be fair, that is why trust is important right? If more open practices are so harmful then there is great risk for the system individual investors rely on. . I support the tick size changes proposed by the Commission, and would also support any structure that is clear in function and meaning, it should not rely on vague language. For example, some funds and firms might request language like "has a reasonable amount of liquidity at the NBBO", which translates to "I can ignore the rule if I feel my lawyers can help me get away with it". Loose language makes enforcement difficult or impossible, and wastes taxpayer dollars on needless litigation time. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Please do not include vague language in the application of your rules, this leads to stupidity having ease of access to crime, such as the term "reasonably locate"... F5 right? I support the inclusion of odd lot information in the SIP, and applaud the Commission's efforts to provide individual investors with more information with which to make better investing decisions, the effects of transparency boost confidence in markets - especially concerning which firms are allowed to handle our orders. Two years ago, the majority of trades in the markets were odd lots (55%; from https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing/). For certain tickers, this proportion is certainly much higher. Why are the bids and offers of so many orders kept invisible? If the Commission were to remove odd lot information from this rule, confidence in the U.S. markets would become even more damaged than it already is. The exclusion of odd lots from the NBBO is a problem. Odd lots are now a majority of trades in the markets. Within some stocks, they are the vast majority. The exclusion of odd lots from the price of a stock amounts to the exclusion of most individual investors - most of the voting public. Please look into a way to fairly and proportionately include odd lots in the calculation of the NBBO. Thank you, An individual investor