Subject: S7-30-22: WebForm Comments from Greg Linder
From: Greg Linder
Affiliation: Founder and CEO, SolarSCADA

Jan. 12, 2023



January 12, 2023

 I appreciate the spirit of Regulation NMS minimum pricing- Following the level 2 data I have access to, I'm always astounding to see stocks trading with 3 and 4 digit decimal places.

I find it highly unlikely that $0.0001 tick sizes benefits anyone other than high-volume middlemen from skimming these spreads as these shares are processed through the system. Even large institutional investors won't re-balance their portfolios for a price improvement of thousands of a cent It makes no financial sense.

This rule certainly would help to prevent fractional-sent skimming and front-running, and rob certain HFT volume-based trading algorithms of their sources of revenue, which is, taking fractions of these pennies off while they briefly hold the shares acting as in-betweeners.

I fully support this change to make the tick sizes more reasonable for all market participants. The US Stock market worked with great strength and vigor for 200 years with tick increments in 1/8's, and I have yet to see any good argument for anyone other than volume-based HFT operators to realize any gains from thousandths-of-a-cent tick sizes.

I hope this rule passes, and the restructuring of the fee and rebate systems proposed also is adopted by market participants.

The Markets in the US stopped being \"useful\" for business to raise capital and speculate on success or failure of business some time ago- So many entities are shorted into oblivion through FTD's and share rehypothecation as to series effect the actual use of the market as a way for companies to succeed and fail on their own merit, such is the degree of manipulation happening in the plumbing of the system itself.

Anything that can help real price discovery on lit markets is getting 100% support from small business owners and retail investors alike.