Mar. 31, 2023
March 31, 2023 The practice of offering rebates and other incentives in the market is essentially just another form of payment for order flow. This leads to trading simply for the sake of increasing volume. While I would prefer that these fees be eliminated altogether, a reduction to .001 would be acceptable to me. I strongly support the establishment of a variable minimum pricing increment model that would apply to the quoting and trading of NMS stocks on all trading venues. While the proposed amendments to Rule 610 that would reduce access fee caps are a step in the right direction, I believe that exchange rebates should be completely eliminated. I also fully endorse the Commission's proposed tick size regime, but I urge that the structure of the rules be clear and unambiguous, without any vague language that could lead to enforcement difficulties and unnecessary litigation. I recommend that the implementation of the revised round lot definition and the odd lot dissemination on the SIP, as outlined in the Commission's Market Data Infrastructure Rule (MDIR), be accelerated. It is unacceptable that reporting can take so long in an industry that prides itself on trading at lightning speed.