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

Mar. 31, 2023

 


Hello, 


I am an individual retail investor. I have been invested in the markets for the past five plus years.  


I am writing to 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. Instead of allowing rebates and other inducements in the marketplace, establish a zero or very low fee structure to eliminate the potential for trading for the sake of volume. Implement a variable minimum pricing increment model that applies to both quoting and trading of NMS stocks to promote fair and transparent pricing across trading venues. 


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. I strongly recommend accelerating the implementation of the revised round lot definition and odd lot dissemination on the SIP to enhance reporting efficiency and reduce delays. I believe taking these steps are absolutely necessary in regaining public confidence and trust in the market, particularly in light of recent events like the GameStop controversy. Enforcement matters. I would like to see higher fines, more severe penalties, and consequences for breaking the law. The cost of doing business should not be so widespread that companies will keep abusing the system. Our free and fair markets will continue to deteriorate unless these rules are allowed to proceed.  


Fully support the harmonisation of tick sizes across all exchanges. No exceptions, no "reasonable" vague language. Clear rules, clear language. Some exchanges shouldn’t be granted an unfair advantage over others. It leads to monopolistic control of parts of the market that counteract and eventually kill the positive benefits of competition. The markets are supposed to be fair - so please make them fair. The definition of tick-constrained, whatever it is, should apply to as much of the market as possible. The rule could be watered down if the definition is too narrow. The important thing is that everyone trades and provides quotes according to the same rules. 


I would also like to add, I dislike the presence of rebates and other inducements in the marketplace. They are simply payment for order flow by another name. I and probably many others would prefer the fees were reduced to zero, but .001 will do. No higher. I also support the inclusion of odd-lot information in the SIP. Odd lots are a majority of trades and should have a greater impact on price. I want odd lots to impact the NBBO and have a concrete effect on both price and broker's duty of best execution. 


Thank you for your time. 


Regards, 
Cole Blocher