April 13, 2010
I have been in communication with the leadership of our firm, Bob Bright and Dennis Dick, who presented arguments to the SEC in March concerning the sub-pennying problem which is now so rampant in the endeavor of fairly trading equities via large broker dealers and the various US Exchanges.
Any ground rules which level the playing field for anyone providing the service of attempting to add liquidity to our capital markets, is one of the essential functions of the SEC, in my opinion.
I support any action the SEC can take to eliminate or alter the practice of sub-pennying and any activity which allows certain, but not all, market participants to see orders and/or to subvert the NBBO.