February 28, 2016
Dear Mr. Fields:
As CEO of a startup Fintech business targeting both retail and Insitutional Investors, we welcome the opportunity to comment.
The notion that the IEX platform should be altered with its existing features and the tactics used to delay its application are simply the work of an Establishment worried about its own market share.
The "data" cited in various studies is not comprehensive and when you have large Investors such as Goldman Sachs, T. Rowe Price, Norges Bank, and Capital Group supporting a venue - the choice is obvious.
The Sell-Side (Wall Street) and Buy-Side (Institutional Investors) are two industries that are now converging as industries mature and innovation takes root. The comment letters on this website from some of our largest financial Institutions with the most to lose should be taken suspiciously.
It is our view that large "metadata" firms use technology to get in the average Investors pockets and is drying up liquidity in the marketplace when over-regulation of our financial markets dries up liquidity. As a result, the "robots" investing in our markets to undermine the honest financial participants is becoming easier for them. As such, any new exchanges that are likely to increase liquidity and broaden choice for Investors - both retail and Institutions - should absolutely be considered without delay.
Startups and new entrants like IEX should not be forced to comply to the same new rules as Incumbents who are active and adept at controlling the regulatory process - or else innovation fails and Investors will begin to lose trust in the system. Without trust, capitalism fails and runs on the system ensue.
Not everybody is seeking to be transparent about their motives-- but it is clear to most market participants what is happening.
We therefore strongly support the IEX Application with no qualifications and recommend the SEC stop delaying their decision as the Incumbents are attempting to do. Investors want more choice in consolidating markets immediately.
Dylan Moore
CEO, Founder
1WealthStreet