Subject: File No. Equity Market Structure 2013
From: William Silver
Affiliation: former manager of a NYSE Specialist firm

April 3, 2014

with HFT being front page news it seems time to reevaluate the entire market structure. Competition from multiple market centers is not a bad thing. However, the competition should be based on providing the best prices, not the highest liquidity rebate which do not go to the customer.
Also, the opening and closing of stocks should be automated and consolidated as is the case in most major markets in the world- see Hong Kong for example.
Get rid of dark pools- transparency is vital. Australia shows large interest as "undisclosed" rather than a specific ammount and no one undercuts the order since it could be 100,000 or 1 Million shares, or more.
Filling the top of the book with a sweep order does not protect customers from adverse executions.
Lastly, rething the exemption that allows sub penny pricing for "crosses" Reg NMS does not decribe the term and it is being used by firms to internalize thier order flow thru diminimus price improvement ( $1 on a $10,000 order for example)