Subject: S7-30-22: WebForm Comments from Charles S
From: Charles S
Affiliation: Scientist

Apr. 01, 2023



 April 1, 2023

 Dear SEC,

The efficacy of any regulation enacted by the SEC is contingent upon the robustness of its enforcement. To bolster compliance, the imposition of substantial fines and sanctions, such as the revocation of broker-dealer licenses, is essential to deter the perception of violations as mere operational expenses.

Investors ought to have the option to avoid routing through wholesalers with questionable legal records. For instance, some may willingly pay a higher cost per share or commission to bypass wholesalers, such as Citadel Securities, that have repeatedly faced charges by the United States government.

The harmonization of tick sizes across all exchanges is a crucial step towards ensuring a level playing field in the marketplace. Eliminating preferential treatment for specific exchanges is imperative to prevent the emergence of monopolistic control and to preserve the benefits of competition. Market fairness should be a primary objective.

Reducing the influence of rebates and other inducements in the marketplace is a commendable goal, as they can effectively function as alternative forms of payment for order flow. A preferable approach would entail minimizing access fees to eliminate the \"take\" component.

A clear and unambiguous tick size rule structure, free from vague language, is crucial for effective enforcement and to minimize the burden on taxpayers. The SEC should avoid incorporating ambiguous terms in its regulations.

The inclusion of odd lot information in the SIP is a welcome initiative, as it equips individual investors with valuable data for informed decision-making. Given that odd lots constitute a significant proportion of trades in the market, their exclusion from visibility is a concern. The SEC's efforts to address this issue are commendable.

Moreover, the exclusion of odd lots from the NBBO calculations is problematic, as it inadvertently disregards the interests of individual investors, who constitute a large segment of the voting public. The SEC should explore ways to incorporate odd lots fairly and proportionately in the determination of the NBBO.

Kind Regards
Daniel