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: Pablo Ruiz
Affiliation:

Mar. 31, 2023

 

Dear SEC,
As a scorned day trader, I strongly support the Commission's proposed tick size regime and recommend clear and unambiguous language in the rule structure to avoid any confusion or litigation. The implementation of a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks would promote fair and transparent pricing across trading venues.
I believe 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. 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.
In addition, I recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. This would contribute to regaining public confidence and trust in the market, particularly in light of recent events like the GameStop controversy.
I also support the harmonization of tick sizes across all exchanges without any exceptions or vague language. Clear rules and clear language are necessary to avoid unfair advantages and monopolistic control in parts of the market. The markets are supposed to be fair - so make them fair.
Furthermore, I suggest that the definition of tick-constrained should apply to as much of the market as possible to avoid watering down the rule. Everyone should trade and provide quotes according to the same rules.
Investors would be willing to pay an additional 0.64 cents more per share to avoid being routed through a wholesaler that has been charged over 70 times by the United States government. The price improvement provided by these wholesalers is minimal and not worth the damage they bring to the market. I’m sure I speak for most retail investors and day traders when I say we would gladly pay a commission to avoid being routed through a wholesaler, especially one with a long record of flouting the law like Citadel Securities.
I strongly dislike the presence of rebates and other inducements in the marketplace as they are simply payment for order flow by another name. I would prefer the fees were reduced to zero, but .001 will do. No higher.
Finally, I support the inclusion of odd-lot information in the SIP, as odd lots are a majority of trades and should have a greater impact on price. It should be clear that odd lots impact the NBBO and have a concrete effect on both price and broker's duty of best execution.
I urge the SEC to take these steps to ensure a fair and transparent market that promotes public trust and confidence.
Sincerely, A Scorned Day Trader