October 4, 2009
To Commissioners:
I would like to take this opportunity to support SEC for banning Flash trading. It has been around for so long that its presence seemed part of the fair system until things went wrong. Besides creating two tiered markets, leaving consolidate tape irrelevant and having immeasurable potential for front running, it made underlying market principle of price forming, fall short. Although traders would now have to process all direct price feeds and not just the ones "Flashed", it will be another step towards more transparent market.
Having said that, I believe this move to ban Flash trading is like fixing kitchen cabinet first, when there is a whole in roof of the house. There are much more dangerous issues in practice that call for SEC's immediate attention, like naked short sale. I hope to see SEC prioritize their chain of goals in future and I wish for fair markets that I am only familiar with in theory.
Regards,
Bhanu Saini