Apr. 01, 2023
Dear SEC Commissioners, I am writing to express my strong support for File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders. I commend the Commission for proposing measures to enhance transparency, fairness, and efficiency in the equities market. Firstly, I strongly support the proposed tick size regime and recommend clear and unambiguous language in the rule structure to avoid confusion or litigation. The establishment of a variable minimum pricing increment model for both quoting and trading of NMS stocks will promote fair and transparent pricing across trading venues. Furthermore, I urge the Commission to establish a zero or very low fee structure instead of allowing rebates and other inducements in the marketplace. Eliminating the potential for trading for the sake of volume is crucial to ensure market integrity and stability. While reducing access fee caps is a step in the right direction, completely eliminating exchange rebates would further 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. It is imperative to take these steps to regain public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement matters, and we need higher fines, bigger penalties, and actual consequences to deter market misconduct. Moreover, I strongly believe investors should support an additional 0.64 cents per share to avoid being 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. I fully support the harmonization of tick sizes across all exchanges, with no exceptions or vague language. Clear rules and language are essential to prevent any exchange from gaining an unfair advantage over others, leading to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. I suggest that the definition of tick-constrained should apply to as much of the market as possible to ensure that everyone trades and provides quotes according to the same rules. Finally, I strongly oppose the presence of rebates and other inducements in the marketplace as they are merely payment for order flow by another name. I urge the Commission to reduce the fees to zero or 0.001, at the maximum. I also 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. The inclusion of odd lots in the NBBO and their impact on price and broker's duty of best execution is crucial to ensure a fair and transparent market. Thank you for your attention to these matters.