Mar. 31, 2023
Vanessa Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington DC 20549 Ms. Countryman: I support this proposed rule. I am in favor of the tick size regime proposed by the commission. Just as the U.S. Dollars and coins are denominated in fixed increments which remain the same, and pricing of goods is likewise constrained to those increments, so too should the pricing for our equities be uniform in increment wherever they are exchanged. The positive effect of this simple, consistent representation of pricing can not be overstated. Uniformity of tick size needs to be rigorously enforced *everywhere* pricing occurs without exception. This will simplify the pricing information available to participants, increasing understanding among the public consumers of that pricing information, and result in increased consistency of execution in trading. It bears repeating, that enforcing consistency of tick size, everywhere quoting and trading occurs, without exception, will greatly enhance the transparency, fairness, and accessibility of our markets for every participant. Also I am strongly in support of odd lot information being added to the SIP. With modern technology available the omission of the odd-lot information can only reasonably be explained as a vestige of past technical constraints. We can and should do better in the interest of having the most timely and accurate NBBO possible. This implementation of this should be pursued by the commission with the utmost insistence. Lastly, reducing the access fee cap is not enough. The presence of access fees, rebates, etc. only serve as 'perverse incentives' which result in the concentration of volume across an increasingly limited number of participants. These sorts of perverse incentives are an anti-competitive practice which invariably create a positive feedback system, the concentration of volume increases over time which also serves to reduce the number of participants. These same sort of rebate systems led to the passage of the Sherman antitrust act over 100 years ago. The fact that these systems remain in place in the current market can only be a lack of rulemaking, and/or a lack of enforcement. Reducing the access fee cap is only a start. I would also like to see the commission reduce access fees to zero, disallow rebates, and limit or restrict any other system that offers 'volume advantages.' Allowing trading for the sake of trading to gain advantages is not a characteristic of an efficient market, and without explicit rulemaking against the various ways in which it is practiced, it will continue. Enforcement needs to be more robust, and must become more punitive in nature. Currently enforcement actions result in fines which are only a small percentage of the profit making gained from anti-competitive practices. This not only fails to disincentivize rule breaking but implicitly allows for rule breaking as the fines are merely 'a cost of doing business.' A key enhancement to enforcement which *must* be considered is that 'frequent flyers' - that is participants who have had charges brought repeatedly - be prohibited from further participation in the market, licenses revoked, etc. The only way to achieve rule compliance is with consequences that impact the Thank you for your consideration. -janson