Subject: S7-05-15: WebForm Comments from Henry M. Phillip
From: Henry M. Phillip
Affiliation:

Aug. 01, 2022


August 1, 2022

 This proposal would be a positive if it fosters a modernization of both exchange, FINRA, and SEC rules, all which should be updated to keep pace with modern times.  The SEC should consider reducing any immunity afforded to the exchanges, since their SRO duties will likely be diminished.  CAT seems like a tool that is underutilized.  Why not add TRACE and other securities or other products to CAT?  The data in the CAT is probably subject to some of the most sophisticated surveillance algorithms there are, yet it seems like there is little talk of how that data is used yet alone expanding it.  Overall, a more business like approach should govern prop traders.  If excessive orders are a problem, for example, exchanges ought to just charge a fee for orders above xyz level.  Without a customer business, prop trading rules should be clearer and more straightforward to administer, which is a job I believe FINRA could do if it has sensible and clear rules to work with.