Mar. 31, 2023
I support the tick size regime proposed by the Commission, and would also have support for any structure that is clear and does not rely on vague language that allows unnecessary loopholes. For example, some funds and firms might request language like "has a reasonable amount of liquidity at the NBBO", which translates to "I can ignore the rule if I feel my lawyers can help me get away with it". Loose language makes enforcement difficult or impossible, and wastes taxpayer dollars on needless litigation time. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Please do not include vague language in the application of your rules and regulations to prevent these abusers from twisting the regulations in their favor. I think that the exclusion of odd lots from the NBBO is an issue. In today's markets odd lots make up a large majority of trades for household investors and by excluding them it takes a large portion of household investors' influence on the markets. Please find a way to fairly include these odd lots in a way that best represents their actual value to the NBBO. Every rule the SEC passes is only as good as its enforcement and punishment. Fines need to be larger and penalties more severe to deter the illegal behavior that has eroded our markets over the past decades. People need to go to jail. Fines need to be larger than the profits from the illegal activity that occurred. Licenses need to be revoked and people must be banned from participating in the market for the rules to be taken seriously.