Mar. 31, 2023
I support establishing a variable minimum pricing increment model that would apply to both the quoting and trading of NMS stocks, which are stocks listed on a national securities exchange, regardless of trading venue. The proposed amendments to Rule 610 would reduce the level of the access fee caps, which limit the fees that can be charged for trading against the best priced quotations displayed in any market. This is a start, but I’d like to see exchange rebates completely eliminated. I support the tick size regime proposed by the Commission, and would also support any structure that is clear and does not rely on vague language. I’d recommend accelerating implementation of the revised round lot definition, and the odd lot dissemination on the SIP, as contained in the Commission’s Market Data Infrastructure Rule (“MDIR”). This should already be implemented and it’s shocking how long things take in terms of reporting, especially when this Industry is known to do whatever it takes to trade in nanoseconds. I think it’s imperative that the Commission take these steps in order to start gaining back confidence and trust from the public.