April 13, 2010
Having some market participants able to hide sub-penny increment orders in front of NBBO visible orders, is clearly unfair to those who don't have the ability to do this.
There is no point in providing liquidity under the current set of rules, and liquidity has, in fact, been drying up as a direct result of the current rules.
The "Trade AT" proposal seems a reasonable solution to this problem.
Please ensure that the same rules apply to all market participants.