February 16, 2010
The continued use of the subpenny by those involved with dark pools, while being touted as provideing price improvement, are in fact reducing intraday liquidity. I have been on several occasions stepped in front of for both my bid and ask and had the market then move away from my order.
To expand this subpenny phenomenon to allow exchanges to subpenny the NBO in the name of "price improvement" will in fact reduce liquidity even further.
It is my hope that rather than permit expansion of the subpenny abilities to exchanges, the SEC will instead work to prohibit subpenny bid and offers in any manner by all market participants
Thank you for your consideration