Subject: S7-32-22
From: Marc Feldman
Affiliation:

Dec. 18, 2022

Best execution And fractional penny proposals. 


We already have price improvement/executions in hundredths of a penny, which is itself a problem. 
Example: 
A stock is Bid 9.46 - 9.47 Ask (10,000x10,000) 
A sell-at-market order comes in for 1000 shares. 
The broker/market maker gives the customer 9.4601 a 100th of a penny (.01c) improvement, but is really stealing a report from the 9.46 bid for Nothing, and in fact trading against the retail client when the market buy order comes and he sells it at 9.4699. The retail seller order also not getting an execution, but the broker/mkt maker making .98 cents. 
So in many cases we need a Larger differential minimum 'improvement' rule. 
At least a.1 or .2 of a cent, never .01 or .02 of a cent. 
Those are just Thief 'improvements' which rob costumes using limit orders of reports and which give negligible 'benefit' to retail investors.  


Thanks 
marc feldman, former trader/mkt maker.