Oct. 19, 2023
October 19, 2023 By Email Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 205499–1090 rule-comments@sec.gov Re: Rule Proposal No. 34-98766; File No. S7-18-23 Volume-Based Exchange Transaction Pricing for NMS Stocks Ms. Countryman: I am writing to endorse the Securities and Exchange Commission’s Proposed Rule 6b-1, which aims to improve the market by prohibiting volume-based transaction pricing for certain types of stock orders on national securities exchanges. Addressing SEC Questions: Advanced Transparency Measures Transparency is the bedrock of market integrity. The proposed rule’s disclosure requirements are an excellent initiative to enhance market transparency. Granularity in Disclosures: More detailed disclosures would empower retail investors, market analysts, and regulatory bodies to better understand and evaluate market dynamics. Public Availability of Disclosures: Transparency can only be effective if it's accessible. Posting these disclosures on both the SEC's and the exchanges' websites would ensure maximum accessibility. Final Remarks and Additional Considerations Alternatives to Prohibition: The direct prohibition of volume-based pricing stands as the most straightforward solution to the problems at hand. Exchange Agreements: If confidential agreements between exchanges and members exist, they must be disclosed and scrutinized to ensure they don't compromise the principles of fairness and transparency. Conclusion I believe that Proposed Rule 6b-1 constitute a proper development towards a fairer, more efficient, and more resilient financial market system. I urge the Commission to adopt this rule post-haste and commend your continued efforts to uphold the highest standards of market integrity. Thank you for considering my comments on this issue. I look forward to observing the positive societal impact that the adoption of this rule will bring. Sincerely, Jens Brage