Mar. 31, 2023
Dear SEC, I strongly believe that the rules passed by the SEC are only as good as the enforcement that supports them. It's long passed the time for the establishment of 1:1 fines that actually serve as a significant enough deterrent to actually protect financial markets from fraud. We need to see broker-dealers lose their licenses when they commit crimes instead of them receiving fines that amount to nothing more than a cost of doing business, which is often outweighed by their ill-gotten gains obtained through “honest mistakes” which have been given a free pass (often by regulators such as the SEC and FINRA) for decades. As a regular investor, I would gladly pay a little extra to trade on a fair market and to avoid having my orders routed through wholesalers so that they can be used against me. many of these wholesalers have been charged over 70 times by the United States government for fraud and yet for some reason they are still being allowed to operate. Lets be honest, if we're going to pay commission anyway, why not avoid being routed through a wholesaler with a long record of flouting the law, Virtu and Citadel Securities come to mind here. I wholeheartedly support the harmonization of tick sizes across all exchanges. It's shocking to learn that some exchanges get special treatment, which allows them to build monopolies in some areas of the market. This is unfair and leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. We need to level the playing field and make the markets fair for all investors. Moreover, I support legal structure that is clear and does not rely on vague language. Clear language and a clear and unambiguous tick size rule structure are strongly preferred. Loose language makes enforcement difficult or impossible and wastes taxpayer dollars on needless litigation time. I also believe that rebates and other inducements in the marketplace are simply payment for order flow by another name. It would be better to reduce access fees to zero to avoid any conflicts of interest. Lastly, I believe that odd lot information should be included in the SIP. The majority of trades in the markets are odd lots, and for certain tickers, this proportion is certainly much higher. We need more information with which to make better investing decisions, especially concerning which firms are allowed to handle our orders. The exclusion of odd lots from the NBBO is also a problem since it amounts to the exclusion of most individual investors from the price of a stock. We need to find a way to fairly and proportionately include odd lots in the calculation of the NBBO. In summary, as an investor who believes the SEC wants to do the right thing to protect both the markets and it's investors, I strongly support the SEC's efforts to create a fair and transparent market for all. It's time for stricter enforcement, clearer rules, and more information for investors. Sincerely, Jack Vanstone Sent from Jack Vanstone's iPhone