From: Charles Chung
Sent: February 10, 2016
To: rule-comments@sec.gov
Subject: File No. 10-222

December 15, 2015

Brent J. Fields
Secretary, United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

RE: Investors Exchange (IEX) LLC; Application for Registration as a National Securities Exchange (File No. 10-222)

Dear Mr. Fields,

This letter is in support of IEX to become a Stock Exchange. Specifically, I’d like to address the recent comments by the ICE CEO, Jeff Sprecher and elaborate on why I support the application of IEX.

I am vehemently opposed to the recent comments made by the ICE CEO on the latest earnings call. If being ‘unAmerican’ means creating a fair and transparent capital Market system, Mr. Sprecher is correct in his statement. I personally believe being ‘un-American’ is what Mr. Sprecher has done with this exchange — intentionally and purposefully converting what is supposed to be a fair process for every US citizen into something where your willingness and ability to pay more gets you better treatment at the expense of everyone else. I believe being ‘Un-American’ is demonstrating this level of greed and manipulation to drive revenue for a single organization at the expense of the American public. 

In addition, his comments related to letting other exchanges create a speed bump is difficult to understand — his own exchange already has multiple lanes of access ranging from slower for the general public to incredibly fast for those that are willing to pay, which is one of the fundamental causes of unfairness in the current Market. Mr. Sprecher elaborates to say that ‘IEX would actually hurt the other people in the industry’ — they would not hurt other people in the industry, they would force them to unwind their manipulative practices in favour of becoming a fair exchange for all investors in the United States. Unfortunately, the ICE organization seems to have lost their way by taking purposeful and direct actions to both increase and preserve the profits of ICE shareholders instead of doing what is best for the overall population of the United States.

There is a clear distinction between IEX and ICE and that is one of integrity. IEX has decided to identify Market inefficiencies and create a better model for all investors. ICE (and NASDAQ) have decided to recognize Market inefficiencies and exploit these inefficiencies it to maximize their profit at the expense of the general consumer. I applaud IEX and specifically, Mr. Brad Katsuyama for firstly identifying the inefficiencies and secondly, for doing the right thing for consumers with the creation of IEX.

IEX has shone a spotlight on a more effective and fair way for equity Markets to be run and now it is up to the SEC to decide on what is in best interests of citizens of the United States. I fundamentally believe it is to approve IEX’s application to strengthen the ‘light’ of fairness versus stamp it out in favour of the desire of the current incumbents to penalize the public and maximize profits at their expense. The SEC should ‘do the right thing’ by embracing innovation and fairness by approving IEX — the IEX model is truly ‘American’ (unlike the other Exchanges) as it has the best interests of ‘Americans’ at its core.

 

Yours Truly,

Charles Chung
Director, BMC Software Nordics, Baltics and Benelux & Concerned Investor

Stockholm, Sweden