Subject: 10-239: WebForm Comments from James Brady
From: James Brady
Affiliation: Financial Planner

Feb. 26, 2023

February 26, 2023

 The vc founder backing this exchange has been implicated in insider trading by the SECs own investigation, which they can see as not pertinent.

What can not be ignored is that 24X wants non displayed orders during market hours, and non displayed limit orders 24/7. The amount of pre and post market fraud in American equities would be built on with this.

Ive written in past comments that without market reform (eliminating failure to delivers) the American market seems to risky for typical high net worth Australian clients financial planning industry, who already make a leap to consider investments outside retirement that isnt real estate.

These are the millionaire next door types who started medium sized plumbing businesses and perhaps own their home, and own either the business or both that and an investment property. They rely on Australian planners to plan their childrens future opportunities, protect their retirement and insure their quality of life in the middle to upper class with a reasonable expectation around risk in fair and transparent markets.

The ethical body for post graduate qualified planners FASEA has ethical standards to not breach clients fiduciary interest and to promote the standards of the profession.

Allowing this exchange to go forward would mean for many clients the juice (risk) is not worth the squeeze when comparing international shares/bonds and real estate and weighing portfolio exposure for clients to American markets.

Im not being hyperbolic to say this sentiment isnt a unique one.

When Australian planers compare and contrast the risk of American markets Ive found this is a common view.

Put simply this exchange going forward would make me consider less exposure to American equities.