Subject: File No. 10-222
From: David Rainbeau
Affiliation: Managing Member, On Point Trading Asset Management, LLC

December 10, 2015

As someone who has been trading the markets for 10 years, I am on the front lines of all the theoretical discussions about market structure.

It is not that the speed of the HFTs is inherently bad or wrong. However, the market structure now is such that you have the illusion of liquidity and the absence of market participants willing to stand and trade at a price.

Speed in the market is helpful, but has now reached a point where it interferes with price discovery. This being said, speed is only one part of the market structure problem.

I support the IEX as it is finally a different kind of solution for the market structure problem that is not getting real consideration otherwise.