Mar. 31, 2023
Dear SEC, I am writing to express my strong support for the Commission's proposed tick size regime, which has the potential to promote fair and transparent pricing across trading venues. However, I recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. Furthermore, I urge the SEC to consider implementing a zero or very low fee structure to eliminate the potential for trading for the sake of volume, instead of allowing rebates and other inducements in the marketplace. This will promote a level playing field for all market participants. In addition, I recommend the implementation of a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks. This will further promote fair and transparent pricing across trading venues. While reducing the access fee caps is a step in the right direction, I urge the SEC to completely eliminate exchange rebates to enhance transparency and fairness in the market. I also recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. This will improve market efficiency and provide greater transparency for investors. It is critical that the SEC takes these steps to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Strong enforcement matters, and I urge the SEC to impose higher fines, bigger penalties, and actual consequences for market abuses. Thank you for your attention to this matter. Sincerely, April Woods