September 28, 2016
Apologies to the Commission for not responding to 182 questions and for not using company letterhead, but family health issues preclude my devoting the time I would have liked to on this matter.
1. Retail vs Institutional. At the edges we can clearly differentiate between the two. 10 shares of GE vs 1,000,000 shares is quite clear. But in the great middle, the classification breaks down. How would you classify a former trader at a big bank now trading for his own account from home? Is he really retail? How about a trader using crowd sourcing on the Quantopian platform?
1a. Drop the split. Everyone wants to know how their trades were handled. That is obvious to anyone who read the pro IEX comment letters. Sure some people won't be able to make heads or tails from the data, but they could crowd source the data or enroll in a free MOOC and learn how.
2. XML and PDF? Really? Does any SEC staffer know how to process and analyze data in a PDF file? Why not CSV (for Excel or Google Sheets), JSON, or even a flat text file? Is there a reason to make the data hard to analyze by dumping it as PDF?
3. Why should a trader have to ask for the data, thus generating costs to the provider? Just automate the process such that it's emailed to the client, either with the trade confirmation or on a periodic basis. Once automated, the costs asymptotically approach 0 if emailed.
Abe Kohen
President
AK Financial Engineering Consultants, LLC