Mar. 30, 2023
Dear Ms. Countryman I consider this concern very important. The suggested changes to tick size regime, minimum pricing increment model, and round lot definition are important for promoting fair and transparent pricing in trading venues. We fully support the harmonization of tick sizes and elimination of rebates and incentives in the market to prevent trading for volume's sake. Establishing a low or no fee structure is crucial to achieving this goal. We also advocate for the acceleration of the revised round lot definition and odd lot dissemination on the SIP to improve reporting efficiency and reduce delays. Enforcement is critical, and we recommend higher fines, penalties, and actual consequences for violators. To avoid being routed through a wholesaler with a history of breaking the law, investors would pay an additional 0.64 cents per share. The price improvement provided by these wholesalers is minimal and not worth the potential harm they bring to the market. We support including odd-lot information in the SIP because they represent the majority of trades and have a significant impact on prices. It is vital that odd lots affect the NBBO and have a tangible effect on price and brokers' duty of best execution. We also propose that the definition of tick-constrained applies to as much of the market as possible to maintain the rule's integrity. In conclusion, we believe that these proposed measures will help restore public trust in the market, particularly after the recent GameStop controversy. It is crucial to ensure that the markets are equitable and transparent for all participants, and we strongly urge the SEC to implement these rules clearly and unambiguously to avoid confusion or litigation. Sincerely, Marco Biesemann (Retail Investor)