February 18, 2016
I am submitting my support for the IEX Exchange application and it's approval as filed.
This is an important first step that the SEC must make at this time to undo some of the developments over the past 10 years with regards to high frequency trading and its clear adverse effects on our current markets and market structure.
Equally important is that the SEC not simply stop with the approval of IEX. Important further actions are needed including the following additional regulatory pursuits.
-Elimination of payment for order flow
-Elimination of legal immunity for Exchanges - they are the only for profit publicly listed companies who receive this benefit - why?
-Elimination of internalization and dark pools. How are opaque markets of ANY kind in the best interest of investors? Surely the SEC cannot be in favor of such secretive sources of liquidity where illegal activity is easily obscured.
-Fines that are commensurate with the infraction. Currently the SEC fines for fraud and manipulation do absolutely nothing to deter such behavior in the future. In fact, many firms see them as a green light to employ any illegal strategy they wish since the fine will be nothing compared to the illegal profit windfall. In other words, breaking SEC laws and regulations currently has great ROI.
Hopefully it won't take a total collapse of market structure facilitated by the above practices to get someone to act and begin to undo the dangerous, unfair environment that now exists.
Thank you for the opportunity to comment on what is likely the most important decision before the SEC in the past 50 years.