Mar. 31, 2023
Dear Chairman Gensler, I am writing to express my strong support for the proposed Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (Release No. 34-96494), which was issued by the U.S. Securities and Exchange Commission on January 19, 2022. As a concerned investor, I believe that the proposed tick size regime is an important step towards promoting fairness and transparency in the securities markets. I strongly recommend that clear and unambiguous language be included in the rule structure to avoid any confusion or litigation. I also strongly support the recommendation to establish a zero or very low fee structure, instead of allowing rebates and other inducements in the marketplace. This would eliminate the potential for trading for the sake of volume and ensure that market participants compete on a level playing field. I believe that the implementation of a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks would promote fair and transparent pricing across trading venues. It is important that the model be applied uniformly across all exchanges to avoid granting an unfair advantage to certain market participants. While reducing the access fee caps is a step in the right direction, I strongly recommend that exchange rebates be completely eliminated to enhance transparency and fairness in the market. This will help to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. I fully support the recommendation to accelerate the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. I also believe that enforcement matters, and that higher fines and bigger penalties with actual consequences should be imposed on market participants who do not comply with the rules. I strongly recommend that investors be given the option to pay an additional 0.64 cents more a share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. It is also important to fully support the harmonization of tick sizes across all exchanges, with clear rules and language that apply uniformly to all participants. I strongly recommend that the definition of tick-constrained applies to as much of the market as possible and that rebates and other inducements in the marketplace be eliminated or reduced to a minimal amount. Finally, I support the inclusion of odd-lot information in the SIP, 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 the broker's duty of best execution. Thank you for your attention to this important matter. Sincerely, Mr David Daumas