Subject: File No. 10-222
From: Bruce R. Clark, PhD
Affiliation: Retired CEO of Leighton Associates, Inc., and small-time investor

December 22, 2015

I write to urge you to permit the IEX as a Registered National Security Exchange, for the benefit of those millions of us small investors who simply want a fair way to buy and sell our stocks and mutual funds. I believe we should be able to trade without paying a 'tribute' to intermediaries who have figured out how to game our markets for the benefit of themselves and the markets that allow them to play. I have been astonished that for over a decade our regulators, notably my former friend Chris Cox, did not put a stop to this blatantly unethical manipulation of trades. The process unfortunately reflects very badly on the SEC, and especially its responsibility to protect private investors from practices like this. In my view, their activity is, by definition, fraud the only reason they are not criminally prosecuted is that the regulator of the system has not put a legal stop to it. I believe that as that regulator, you have the responsibility to act on our behalf. To deny Registered status to IEX is to simply compound the fraud, by not allowing a registered exchange to perform its appropriate function for those of us who want to be treated fairly. Thank you.