January 8, 2016
I support the approval of the IEX application as filed.
The protected quote with 350 microsecond delay should have no bearing whatsoever on whether or not to approve this new, investor focused exchange.
Retail investors are already subject to delays by High Frequency Traders using internalization and the SIP.
It currently takes the largest HFT firm, Citadel, over 100 times longer than IEX to execute a retail order.
https://pbs.twimg.com/media/CYN8ixBUQAEyHku.png:large
In that sense, and taking into account the SEC's mandate to protect the interests of longer term investors, IEX already operates closer to what the SEC's own regulations stipulate than Citadel.
The only reason HFT firms oppose this application is because of it's significant impact on their latency arbitrage strategies.
Reg NMS clearly states that these high speed trading strategies take a back seat to longer term investor interests.
The debate has already been settled - by the SEC's own regulations.
When asking which approach benefits longer term ivestors Citadel or IEX, the answer is clear: IEX.
I'm sure the Commission can clearly see this, act according to it's own mandate, and approve the IEX application.