Sep. 22, 2026
Dear Secretary Countryman, As a retail investor, I am writing to provide my perspective on the Commission's proposed updates to Regulation NMS. While evaluating modern intermarket structures and execution practices, I urge the Commission to focus heavily on reducing the predatory advantages of high-frequency trading (HFT) platforms that generate structural drag on long-term retirement accounts. Specifically, I recommend that any comprehensive modernization of Regulation NMS include the implementation of an order-to-trade ratio penalty fee on excessive cancelled stock orders. Predatory algorithms currently exploit exchange infrastructure by utilizing "quote stuffing", flooding market venues with millions of rapid-fire orders and immediately cancelling them milliseconds later to generate artificial data latency and front-run consumer capital. Incorporating an explicit, high-threshold financial penalty on extreme ratios of cancellations to filled trades would directly eliminate this loop without affecting long-term retail holders or legitimate market participants. Thank you for considering the perspectives of individual retail investors as you modernize federal market structures. Sincerely, Payton Loundy