Subject: File No. 10-222
From: Larry Doyle
Affiliation: DM Income Advisors

December 14, 2015

To whom it may concern, 

In re: IEX application to become an exchange

The spirit of our great nation is founded upon the preeminence of the rule of law, free and fair markets, and unbridled competition. Seven years after the greatest economic crisis since the market crash of 1929, global investors and the American public at large have serious questions supported by voluminous evidence as to the efficacy of these core principles within our markets.

The erosion of trust and confidence by many investors has stemmed from the fact that the financial services industry has abused its privilege to manage the equity exchanges for their own financial well being at the expense of the investing public. As the exchanges have become for profit enterprises the race for volume to promote their own profitability has precipitated them to offer sweetheart deals to the HFT audience but again at the expense of investing public. Free and fair markets premised on the principle of true competition have taken a back seat to the favors directed toward HFT in the form of co-location and latency arbitrage.

While many in the public may not fully grasp the finer technical points of HFT, they do know that markets that remain subject to periodic "flash crashes" are inherently broken. The exchanges themselves are not held to proper account given that they are afforded the benefit of absolute immunity. Add this all up and no wonder why many think that true free market capitalism no longer thrives in our nation while crony capitalism and real corruption have become the order of the day.  

Against this backdrop, along comes an entity in the form of IEX that wants to "build a better mousetrap" and level the playing field for all investors. Little wonder that powerful HFT forces that have been granted the leeway to engage in what can largely be defined as glorified and legalized front running is coming out adamantly against the IEX application.

In the spirit of those who founded and built our great nation, I beseech you to confirm IEX's application. I firmly believe a confirmation could be the strongest message that the SEC could send to the marketplace that true free market capitalism is being embraced and remains the order of the day. By the same token, if IEX's application were denied or delayed, I firmly believe that the marketplace would view that as an indication that crony capitalism and regulatory capture remains well entrenched. In the process, trust and confidence in the markets and the regulators will continue to erode.

Sincerely, 

Larry Doyle
DM Income Advisors 
Greenwich, CT