March 15, 2018
We believe one of the key drivers to non-lit liquidity and lack of price discovery is the loophole where flow providers can trade at smaller increments than exchanges, and also that flow providers are given free rein to trade “ahead” of all other displayed liquidity at the same price. This no doubt deters others from showing any real liquidity on the exchanges. We need a trade at rule. Please include a trade at test, split 50/50. It seems like such a no brainer in terms of just promoting fairness in the markets. I am sure the lobby is heavy from these flow providers. They need to limit or eliminate competition in order to profit. Its all wrong. Please fix this. There is no good counter argument, or I challenge there to be one. Thanks.
David Adorney
C & C Trading, LLC
71 Arch Street
Greenwich, CT 06830