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.