Mar. 31, 2023
Dear Commissioners, I am writing to express my strong support for the proposed tick size regime and to recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. I believe that a variable minimum pricing increment model should be implemented that applies to both quoting and trading of NMS stocks to promote fair and transparent pricing across trading venues. While reducing the access fee caps is a step in the right direction, completely eliminating exchange rebates would further enhance transparency and fairness in the market. I also suggest accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. These steps are crucial to regaining public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement matters, and I strongly believe that higher fines, bigger penalties, and actual consequences should be imposed for violations of the rules. Investors are willing to pay an additional 0.64 cents per share to avoid being routed through a wholesaler with a long record of flouting the law like Citadel Securities. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. We will gladly pay a commission to avoid being routed through a wholesaler, especially one with such a tarnished reputation. I fully support the harmonization of tick sizes across all exchanges, with clear rules and language. There should be no exceptions or vague language that grants certain exchanges an unfair advantage over others. This leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets are supposed to be fair - so make them fair. I also recommend that the definition of tick-constrained applies to as much of the market as possible, without any watering down of the rule. It is important that everyone trades and provides quotes according to the same rules. Finally, I would like to emphasize my strong dislike for the presence of rebates and other inducements in the marketplace, as they are simply payment for order flow by another name. I would prefer the fees to be reduced to zero, but even a fee of 0.001 would be acceptable. The inclusion of odd-lot information in the SIP is also crucial, as odd lots are a majority of trades and should have a greater impact on price. It is important that odd lots impact the NBBO and have a concrete effect on both price and broker's duty of best execution. Thank you for considering my recommendations, and I hope that you will take the necessary steps to ensure fair and transparent trading in the market.