Apr. 01, 2023
Dear Sir or Madam, As a concerned retail investor, I respectfully submit my comments on United States SEC file no. S7-30-22. I strongly 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, I suggest establishing a zero or very low fee structure to eliminate the potential for trading for the sake of volume. I also recommend implementing a variable minimum pricing increment model 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, I suggest completely eliminating exchange rebates to 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. I would like to highlight the importance of taking these steps to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. It is crucial to ensure that the market is fair, transparent, and free from manipulation. Additionally, I strongly support Conscious_Student_37's comments on the matter of enforcement. We need higher fines, bigger penalties, and actual consequences for those who break the rules. Investors should not be 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. Investors would gladly pay commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities. We fully support the harmonization of tick sizes across all exchanges and suggest that the definition of tick-constrained should apply to as much of the market as possible to ensure fair and transparent pricing. It is crucial to make it clear that rebates and other inducements in the marketplace are simply payment for order flow by another name. We prefer the fees to be reduced to zero, but 0.001 will do. It is essential to 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. We recommend making it clear that odd lots should impact the NBBO and have a concrete effect on both price and broker's duty of best execution. In conclusion, I urge the SEC to take the necessary steps to ensure a fair, transparent, and trustworthy market for all investors. Thank you for your attention to this matter. Respectfully submitted, Amanda Kappes