Subject: File No. SR-NYSE-2011-55
From: Jordan Wollin

November 29, 2011

The NYSE wants to start sub-pennying in order to attract flow from retail investors.... but retail investors don't have the ability to select which exchange their order goes through. I have a Scottrade account (though I recently became a professional day trader with a firm) and when I enter orders, I simply put in the stock, the limit price, the number of shares and click submit. I know that is no option to select exchanges on Sogotrade and sharebuilder, and would assume its similar for most retail accounts. Thus the whole premise for the program is defunct.

Also consider the retail traders themselves, the ones refered to as "dumb" orders. If they're entering limit orders do you really think the out-of-the-loop retail investor is going to put their order in at $xx.523 instead of right at 50 cents? Probably not. Most retail traders like myself are probably looking to make more than just a few cents at a time as it is. If I just made $5 on a position that Ive had for a number of months, is 1/10th of a penny going to make a difference? No.

The only way for a limit order placed at 1/10th of a penny below a target price is even going to make a difference for a retail trader is if the price stops right at that point and turns back around. If the limit price is in the middle of a trend, then a retail trader actually just LOST money because they could have sold out that 10th of a penny higher.

Since becoming a professional trader at a firm, I have seen firsthand how HFT (more specifically sub-pennying) hurts the individual trader. I can't even count the number of times that I have had an order parked to provide liquidity in hopes of entering or exiting a position that didn't get filled because a sub-penny order stepped in front of the NBBO. The SEC needs to stop sub-pennying everywhere, under any circumstance. That's the only way to keep individual liquidity providers trading in the market and ensure that everyone has an equal playing field.