May 21, 2016
Allowing IEX to become a public exchange is a no brainer. There is data to suggest that this 350 ms "speed bump" will improve the credibility of the marketplaces for consumers, while dampening or eliminating damaging malicious HFT practices. IEX's customers are experts in capital allocation and can certainly apply this same rigor to the services they consume from exchange. They clearly see the value in this type of service and can pass this along to the consumer in the form of savings and trust. There is no valid argument to interpret the word "immediate" to block IEX from becoming a public exchange on the grounds of its product features and operating procedures. Instead the word "immediate" should be reinterpreted in the spirit in which it was intended. That all potential participants on a public stock exchange should be participating on a level playing field - meaning, these potential participants have the same volume of knowledge and speed of access to view, create, process, and clear financial transactions, and that the exchange itself should not be selling what is effectively inside information to exchange participants. If anything firms that abuse the letter of the law, and hide behind the word "immediate", should be prosecuted for willfully providing asymmetrical information to their customers, who assume the exchange is acting neutrally, or at least not detrimentally to the customers interests. Please interpret the word "immediate" in the spirit it was intended and allow consumer choice for IEX's products and services.