Apr. 18, 2022
I strongly oppose the SEC’s unacceptably broad proposal to expand its definition of an “exchange” and an “ATS,” and I emphatically urge the SEC to reconsider. At a minimum, the SEC should issue a new proposal that makes clear exactly which trading systems and protocols the SEC intends to regulate. Furthermore, this new proposal should have a robust cost-benefit analysis and comment period. Finally, this new proposal should provide the public adequate time to respond—rather than the, as Commissioner Peirce called it, “unconscionably reckless” 30-day period allotted for responses to this incredibly complex proposal. The SEC should understand that any proposed rulemaking that is 654 pages long and contains more than 220 separate requests for comment on a variety of issues requires more than 30 days to study and analyze. For all of these reasons, I stand opposed to the SEC’s proposal, and respectfully request that the SEC take actions to rectify what I consider to be a grave mistake.