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: Catherine Wells
Affiliation:

Mar. 31, 2023

 


To Whom It May Concern,  


I am writing to voice strong support of the Commission's proposed Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders rule. I applaud the Commission's efforts to provide individual investors like me with a more level playing field, and better information with which to make investing decisions.  I would recommend that in implementation, the Commission ensure completely unambiguous language in the rule structure to avoid any opportunities to evade compliance with vague interpretation or litigation.  


The current disparity in tick sizing allows firms like Citadel to trade at sub-penny intervals on their single-dealer platform, while the rest of us are limited to trading in penny increments. This gives them an unfair advantage with regard to executing trades in the space between penny increments, which may not seem like much but adds up given the staggering number of trades they handle. Tick sizes should be standardized across all exchanges to promote competition and fairness in execution.   


As for rebates paid for payment for order flow (PFOF), I would prefer for PFOF to be banned entirely, but eliminating rebates that can be paid for PFOF is a good step in that direction. This would disincentivize trading for the sake of volume.  


The revised round lot definition and odd lot dissemination on the SIP would enhance reporting efficiency and price discovery - please implement ASAP.   


Catherine Wells 
Individual Household Investor