Subject: File No. 4-657
From: peter schulkin, Ph.D.

March 8, 2018

I have a fair amount of experience trading in low-priced FINRA Tick Pilot stocks with order entry limited to 5 cent increments. My experience is that artificially limiting the orders put in by individuals to 5 cent increments only benefits dealers in the stock who can buy and sell at any price and who can trade in their own accounts ahead of individuals and who can take advantage of the fact that individuals are pressured into paying up for stocks that they want to buy. I have watched my buy orders at the bottom of the 5 cent range trade at my price for extended periods and I get not a single share even though the size shows few shares bid at my price. Similarly, I find it more difficult to sell shares in FINRA Tick Pilot stocks.

In short, I strongly feel that the artificial FINRA Tick Pilot ranges benefit only the market dealers and hurt the little investors. I hate it when I find out that a stock I'm interested in turns out to be a FINRA Tick Pilot stock.