September 27, 2021
Clearly you have begun to see the dangers of Citadel and Virtu controlling the vast majority of our securities trading, or at the very least you are now being forced into taking further action. Thank you. One can only hope that this is merely the beginning if we are to maintain any semblance or any illusion of truly having a free and fair marketplace these changes are a step in the right direction. I believe the ramifications of these changes may be minor at first, but anything that alleviates the ability of DMM's to manipulate with impunity can and must be done these loopholes should have been addressed long ago. When Citadel is allowed to alter closing prices and allowed to utilize aggressing transactions solely for their own benefit it does more then destabilize the market, it robs from the poor to give to the rich. It destroys retail traders, it hurts pension funds, it irreversibly changes the course of small companies trying to survive despite the whims of the alleged free market. My only concern is that there appears to be one major loophole still being left in place: \"Instead, the Exchange will remain unopened, halted, or paused and will close the security as provided for in the Rule 7.35 Series. Because in these circumstances, the Exchange would proceed to a Closing Auction, the Exchange proposes to accept (or not cancel) Closing D Orders entered by DMMs in NYSE-listed securities during this ten-minute period, even if the security is in a halt state during that period.\" Why would DMM's be impervious to any security halt? I understand the circumstances described, however this is still an uneven playing field and an invitation for chicanery. If the attempt here is to reduce the power of DMM's in our marketplace and to eliminate the possibilities for fraud and manipulation, lets not leave such a blatant opportunity in place.