Apr. 01, 2023
I strongly support this rule because it promotes fairness in the markets and will reduce corruption. I srongly support the Commission's proposed tick size regime, and recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. Instead of allowing rebates and other inducements in the marketplace, you should establish a zero or very low fee structure to eliminate the potential for trading for the sake of volume. There should be a variable minimum pricing increment model 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 recommend 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 must be taken to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement matters. We want higher fines, bigger penalties, actual consequences. As it is now, it is cheaper to break the law and pay the fine as a cost of business. I support adding an additional cost of 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 (https://files.brokercheck.finra.org/firm/firm_116797.pdf). The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. I will gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. I fully support the harmonisation of tick sizes across all exchanges. No exceptions, no "reasonable" vague language. Clear rules, clear language. Some exchanges shouldn’t be granted an unfair advantage over others. It 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. The definition of tick-constrained, whatever it is, should apply to as much of the market as possible. The rule would be watered down if the definition is too narrow. The important thing is that everyone trades and provides quotes according to the same rules. I dislike the presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name. It would be better if the fees were reduced to zero, but .001 is acceptable. I support the inclusion of odd-lot information in the SIP. Odd lots are a majority of trades and should have a greater impact on price. I would like odd lots to impact the NBBO and have a concrete effect on both price and broker's duty of best execution. Get Outlook for Android