Apr. 01, 2023
To Whom It May Concern, One of the first things I'll mention Is something that came to my attention in the past few months and that's the disproportion in tick sizes across markets. These kind of discrepancies parallel things like high frequency trading where the tick size gives priority to certain parties. All exchanges should quote and trade the same otherwise you're going to have larger groups controlling our markets without true competition. The absence of odd lots from the NBBO is a major issue for retail traders today. I'd ask the Commission to push for inclusion of odd lots into the calculation of the NBBO. At the same time I've been pleased with the Commissions support of odd lots data into the SIP. This helps inform investors on who is handling the trades and make generally better investment decisions. It's the kind of true transparency that a market that was "the envy of the world" would and should foster and such efforts have definitely been appreciated buy a small investor such as myself. One of the things I've become aware of in the past 2 years is that financial regulation in this country is metered out in nothing more than small capped fines without real cost to the perpetrator. What good is regulation when this becomes 'cost of doing business' rather than a serious punitive response? Take away broker licenses, enforce the criminal penal code when appropriate, don't standardize 'bad behavior' because that's the opposite of what our country was founded on. However, it certainly is the culture in the financial world that the American people are beginning to become more aware of today. Why is pay for order flow still legal? We hear big names like Ken Griffin of Citadel, and other market makers like Doug City at Virtue tout the advantages modern day retail investors have with apps that offer free trading. In one interview the gentleman boasted about how much he lost in these transactions- to paraphrase, "all for he benefit of retail". On what planet does that pass a 'smell test'? That a man who runs not only a market making firm but as well a hedge fund consider putting retail investors first in low cost or even free abilities to trade before his own profit making? I'll answer: it doesn't. This is blatant gas lighting and the small fees that retail avoid on the front end, they pay for dearly on many securities on the back end. How hard is this to see? In much the same way that big tech offers 'free' apps to the public just to data harvest their personal information, pay for order flow is and has been losing proposition. Between this and the idea of paying a little more for better execution it's like the old saying, "take my money, already". Not to mention that rebates and financial products that create access fees are PFOF by any other name. I definitely support the tick size proposal pushed by the Commission and would stress the use of clear and non obfuscated language in its implementation. Clear written language that most people can understand and not be muddied by clever lawyers representing large financial firms. Thank You, Paul Bekavac