Apr. 01, 2023
I support the direction of this rule but believe it is only a small step to fix our broken capital markets. I am aligned with many that we need to: True Enforcement matters. We want higher fines, bigger penalties, actual consequences. Make them fear fines Investors to support 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 (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. Investors will gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. Fully support the required 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. Outlaw microsecond traders. Prevent them from reselling for seconds or minutes to allow everyone similar capability. Suggest that 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. Make it clear you very much dislike the presence of rebates and other inducements in the marketplace - they are simply payment for order flow by another name. We'd prefer the fees were reduced to zero, but .001 will do. No higher. 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. Make it clear you want odd lots to impact the NBBO and have a concrete effect on both price and broker's duty of best execution. Regards Michael Carlson Farmington Hills, Michigan