Mar. 31, 2023
To Whom it May Concern, Thank you for your time in reading and considering this letter- I am a household investor and small business owner. I believe that in order to build on the hard work I’ve invested in my business and my community - to have something to pass down to my children - and to invest in my own security for the future, that the financial markets must work fairly and in a way that ensures equal access and opportunities for all market participants. It has become clear through my observations of the markets over the past years that there are numerous ways in which large financial interests have continually gained numerous advantages, engineered or accessed legal loopholes, and created systems that inherently disadvantage household investors: the very people who makeup the moral and market fabric of our society are being exposed to a system that inherently works to extract the hard earned wealth that every day people are investing their lives into earning. A primary consideration in all rule proposals is that enforcement must exist, be firm, be effective, be swift, by consistent, and actually be a deterrent. It is my desire to significantly higher fines, that are highly dissuasive to those who may see the current fine structure as merely a cost of doing business. These costs must be debilitating and severe to any who are found to violate these practices. These costs should not be merely limited to punitive financial measures but should include significant professional consequences including the loss of licensure, loss of access to market segments, increased scrutiny or reporting requirements in the future or other measure to ensure that these rules have bite, and market participants are ready to ensure top to bottom organizational compliance with the regulations that end up in place. It is with this thought in mind that I want to speak today in regards to minimum pricing increments, access fees, and transparency and the proposals regarding. If there’s one thing I’ve seen consistently in the markets as I’ve participated over the last decade it’s that there must be higher fines and more severe penalties for violations, there must be greatly enhanced transparency in every corner of the market, enforcement must be made swift, even, and consistent, and that prioritizing this is absolutely mandatory to ensure the current and future success of our market system. With that in mind I want to mention my support for the proposal put forth here with specific regard to: Tick Size Regime as proposed by the commission - but I would also say that specific language in the rule must be used. Precise targets for all aspects of the rule should be put into place to ensure a rigid and consistent application of the rule by all market participants. Inclusion of Odd Lot information in the SIP. This is a solid step in giving general market participants more information, clarity and transparency. Enforcing tick size homogenization across all exchanges. No exchange should be treated differently in a free and fair market - and ensuring that exchanges must quote and trade in the same increments helps bring us all closer to that reality. Additionally I would voice my opposition to the following: Rebates or other Access Fees existence. These should be reduced or removed - they inherently promote conflict of interest, participant or exchange preferential treatment. Thank you for considering these thoughts on the proposed rule, Alex Fleming