May 10, 2009
I am not wild about any of your proposed ideas for the up-tic-rule.
It seemed to me that the way it worked in 2006 and 2007 was fine - just before the rule was made invalid. How did it work then - a one cent up-tic?
From the 1930s to about 2000, it was based on a fraction - one sixteenth of a dollar I believe (6.25 cents). That seemed to work very well. So you might want to consider using up-tics in five cent increments.
And, please rigorously enforce and strengthen the naked shorting rules.
Rob Bowles, Trader