Subject: S7-30-22
From: Luke Czarnota
Affiliation:

Mar. 31, 2023

 


Please make the markets fair 


The proposed SEC regulation on minimum pricing increments, access fees, and transparency of better priced orders (No. S7-30-22) requires strong enforcement for effectiveness. Higher fines that serve as a significant deterrent are necessary, and some broker-dealers that engage in unlawful practices should lose their licenses instead of receiving insignificant fines. It is worth paying slightly more to avoid routing through wholesalers with a record of flouting the law. Harmonization of tick sizes across all exchanges is important to prevent certain exchanges from monopolizing parts of the market. Rebates and other inducements should be eliminated, and access fees should be reduced to zero. A clear and unambiguous tick size regime with no vague language must be implemented. Including odd lot information in the SIP is essential for better investing decisions, and odd lots should be proportionally included in the calculation of the NBBO to prevent the exclusion of most individual investors. 


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