May 31, 2018
I just learned about this proposed pilot program concerning transaction fees. This comment will be brief, as I want to be able to comment before the comment period expires (if it hasn't already). I will endeavor to prepare a more detailed comment for submission. I have significant experience (over 20 years) trading US equities.
I am strongly in support of the proposed Pilot program, and lower liquidity fees in general. Personally, While I feel that the taker/maker model makes sense, I believe those fess/rebates should be significantly lower, especially in large cap issues. It does not surprise me that several exchanges and prominent high frequency firms such as Virtu would be against these proposed changes. Their business models and technology have been very adept at prospering in the existing structure.
I would implement the Pilot and include as many large cap/high volume stocks as possible in the brackets containing the capped fee levels.
While I am all for competition in the general sense, and among market venues, ultimately the objectives of the Commission and investors may be best met by something closer to a functioning (through rules and market linkages) Central Limit Order Book (CLOB) within which market participants can collect more moderate rebates for passive orders or pay a reduced fee for taking liquidity.
Thank you for your work in this important area.