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

Mar. 31, 2023

 




To whom it may concern: 


The utilization of market incentives is essentially a payment for order flow under a different name, resulting in trading solely for the purpose of generating volume. While I would prefer that fees be eliminated entirely, a reduction to 0.001 would suffice. I support the implementation of a variable minimum pricing increment model that applies to both the quoting and trading of NMS stocks across all trading venues. 
Although the proposed amendments to Rule 610 are a good start, I recommend the complete elimination of exchange rebates, as well as further reduction of access fee caps. The tick size regime proposed by the Commission is supported, as long as it is clearly defined and not reliant on vague language that could result in confusion and costly legal disputes. 

I urge the Commission to expedite the implementation of the revised round lot definition and odd lot dissemination on the SIP, as this would help restore public trust and confidence in the market. The recent Gamestop incident has significantly eroded investor confidence, making it imperative for the Commission to take steps to address these concerns. 

I appreciate the opportunity to offer my input, and I hope that my suggestions will be taken into account. 


Thank you, Michael