Subject: File No. 10-222
From: Pablo Crespo
Affiliation: Independent Registered Investment Advisor (RIA) and Commodities Trading Advisor (CTA)

December 10, 2015

I am certain you understand that those wanting to block IEX's path are the same for-profit institutions that use market structure and regulatory weaknesses to steal millions from retail traders every single day. Virtu, Citadel, etc. The list is long. HFT and Dark Pool shops abound. They only add liquidity when there are pennies to steal. Their only purpose is to take advantage of retail buy side (Mutual Funds ETFs included) for profit leveraging technology loopholes.

IEX just takes that capability away in THEIR platform/exchange. Let the thieves go somewhere else. Their choice.

I am a very small RIA CTA startup. For months I kept getting horrible fills and stops hit in "funky" price action using Interactive Broker's "SMART" routing. Upon studying the counterparties for each of these, 85% of the bad fills and funky price action/spikes where transacted with an HFT shop or Dark Pool. Never EVER did I get a favorable "price improvement" fill.

Then I switched routing to direct routing and routed all Stops (limit or otherwise) through IEX. Since then, I have not gotten a single unexpected fill or atrocious market fill. And I actually do get a priced improved fill every once in a while. Imagine THAT A market making platform that works as it is supposed to

IEX's type of endeavors are who you need to nurture and protect. Why, because they BENEFIT the people and institutions you, as the SEC, together with FINRA and the States, are supposed to be protecting.

Please don't fall victim to the corruption and influence the HFT's and Dark Pooled institutions exert by throwing billions around...

Do what is right and allow IEX to move forward continuing to help those outside the inner circle of HFTs and Dark Pools. IEX is helping us by protecting our interest, not by offensively attacking the HFTs and Dark Pools. IEX will just provide a venue, it is our choice to use it or use others. Why take that choice away from us? Let me be responsible for my own actions so I can do what is best for me and my clients under the law and regulatory requirements. By blocking IEX path forward, you are forcing me and my clients to become a victim of the HFTs and Dark Pools.