March 28, 2015
I agree with the need to update this rule, and for increased regulatory oversight of trading activity that has the potential to disrupt markets. However, I ask that the committee please consider, at least for now, exempting firms that do not trade in sufficiently large size so as to disrupt markets (e.g., based on the dollar amount traded per day).
The sad reality is that there are limited resources for policing markets, and adding another layer of oversight to small players takes away resources that could be better spent rooting out large-scale, abusive trading activity.
Sincerely,
Ryan Porter