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: Shaun Ardiente
Affiliation:

Mar. 31, 2023

 


Good evening, 


Effective enforcement is crucial for any rule passed by the SEC. To deter bad behavior, fines must be substantial and lead to meaningful consequences such as revoking the licenses of broker-dealers who repeatedly flout the law. I would rather pay slightly higher fees or commissions than be routed through a wholesaler with a history of legal violations. 

I strongly support fair competition in the marketplace, and believe that all exchanges should adhere to the same tick size regime without any special treatment. Rebates and other incentives, which are just another form of payment for order flow, should be eliminated, and the rules should be clear and unambiguous to prevent any legal loopholes. 

I applaud the Commission's efforts to provide investors with more information, including odd lot data, which is now the majority of trades in the market. The exclusion of odd lots from the calculation of the National Best Bid and Offer (NBBO) unfairly marginalizes individual investors, and should be addressed. It is crucial to have a fair and transparent market that benefits all participants, not just a select few. 



Thank you, 
Shaun