Subject: SEC Proposal on Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (No. S7-30-22)
From: Melisa Virginillo
Affiliation:

Mar. 31, 2023

 


Dear Civil Servant, 

As a retail investor, I value attempts to boost market competition and transparency, and I would like to offer some feedback on the suggested improvements. I think these are important market structure adjustments, and I hope they are carried out in a real and efficient manner. 

Wallstreet players, broker-dealers, or other authorities that retail NEEDS to trust if they are to transfer duty should be stripped of their licenses rather than fined when using a system that is badly managed or at best irresponsible with the intention of harming retail. The procedure is simply a business expense, but one that is frequently surpassed by the illegal benefits made from "honest mistakes," "without admitting or denying guilt right"? 

Although I can pay 12 cents extra per share to avoid going via a wholesaler who has been charged more than 70 times by the US government, it has been pointed out to me that the service for these "advanced" trading systems is not for the advantage of the general public. (https://files.brokercheck.finra.org/firm/firm_116797.pdf) 

I also support the harmonization of tick sizes across all exchanges. It is unreasonable that some exchanges receive special treatment and are able to dominate in certain areas of the market. All exchanges should have to quote and trade in the same increments to promote healthy competition and prevent monopolistic control of the market. 

I agree with the proposed tick size changes and believe that the rule structure should be clear and unambiguous. Loose language makes enforcement difficult and wastes taxpayer dollars on needless litigation time. Clear language and a clear and unambiguous rule structure are strongly preferred. 

I support the Commission's efforts to give individual investors more information so they can make better investment decisions, and I applaud their efforts to include odd lot information in the SIP. Transparency has the positive effect of boosting market confidence, particularly when it comes to the firms that are permitted to process our orders. According to https://bettermarkets.org/newsroom/key-highlights-dennis-kellehers-testimony-march-17-house-financial-services-gamestop-hearing/, 55% of deals in the markets two years ago were odd lots. This fraction is unquestionably considerably larger for some tickers. Why are so many orders' bids and offers kept secret? The Commission would further erode investor trust in U.S. markets if it decided to eliminate odd lot information from this rule... 

Thank you, 
An individual investor