The Consumer Federation of America expresses our skepticism with the premise on which the proposal to implement a tick size pilot program is based. Despite its proponents’ best intentions, increasing tick size will likely result in increased costs to investors but without any accompanying benefits to them or to market quality. That is because those increased costs will likely go directly to high frequency trading (HFT) market making firms whose business models do not include engaging in the type of research and capital commitment that promotes capital formation. Further, the profits that HFT market making firms generate will not be tied to any market making obligations that would promote dependable liquidity. Because a tick size pilot is likely to come with significant costs to investors, and is unlikely to serve the Commission’s and Congress’ ultimate goal of fostering an environment that is conducive for capital formation, we do not believe that the Commission should be dedicating valuable resources to move forward on a tick size pilot.