Apr. 21, 2022
Dear Chair Gensler: Of course, the appropriate way to respond to the proposed changes to the Exchange Act is through a Comment Letter. However, I would like to make several simple and high-level comments that will not stand up to scrutiny nor be well received by the industry. I have been involved in the securities industry for over 50 years. I worked on the Pacific Stock Exchange in 1968 during the paper-work crisis; I joined Weeden & Co. as a programmer in 1974 and worked on the Cincinnati Stock Exchange - the first electronic stock exchange; I started a company that provided realtime risk management to firms such as Drexel, UBS, NYSE and PaineWebber in the 1980s; We wrote one of the first odd-lot government trading systems for Spear Leeds and Kellogg; We wrote software for the EDGAR system (EDGAREase) which was widely used by corporations and financial printers to prepare their EDGAR filings; My simple suggestion is that the SEC build a stock exchange. Having been witness to the NYSE dominance, the third-market, payment for order flow, dark pools, ATS platforms and now, communication protocols, I think the only way to adequately protect the investing public is for the government to run the exchange platform. And, it can be paid for by revenue from selling the market data feeds and disciplinary fines. It should be simple and fair - a Hard Clob. It isn't hard to do - we did it in the 1970s at Weeden & Co.. The trading environment now is too complex, uneven with many unfair advantages. The public should have confidence that their hard-earned investment dollars are being treated as fairly as any institutional order. We've seen the success of EDGAR which made corporate information much fairer than the days in which arbs would sit in the filing room and read filings before the public had access. The SEC removed this unfairness with EDGAR and I believe could again remove systemic unfairness by managing the exchange, SEC-EX. Best of luck on your efforts, Thank you, Charles Weeden Managing Partner Weeden Ventures