Subject: RE: File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders
From: Avyatar
Affiliation:

Mar. 31, 2023



Hello SEC, I have a comment on the Proposed Rule above.

There is a strong support for the Commission's proposed tick size
regime and a recommendation for clear and unambiguous language in the
rule structure to avoid any confusion or litigation. It is suggested
that instead of allowing rebates and other inducements in the
marketplace, a zero or very low fee structure should be established to
eliminate the potential for trading for the sake of volume. To promote
fair and transparent pricing across trading venues, it is recommended
to implement a variable minimum pricing increment model that applies
to both quoting and trading of NMS stocks. While reducing the access
fee caps is a step in the right direction, completely eliminating
exchange rebates would further enhance transparency and fairness in
the market. There is a recommendation to accelerate the implementation
of the revised round lot definition and odd lot dissemination on the
SIP to enhance reporting efficiency and reduce delays. These steps are
important to regain public confidence and trust in the market,
particularly in light of recent events such as the GameStop
controversy. Investors are willing to pay commission to avoid being
routed through a wholesaler, particularly one with a long record of
flouting the law like Citadel Securities. It is fully supported that
tick sizes should be harmonized across all exchanges with clear rules
and language without any exceptions. Unfair advantages given to some
exchanges lead to monopolistic control, which counteracts and
eventually kills the positive benefits of competition. To make the
markets fair, it is important to ensure they are fair for all.