April 13, 2010
I am in favor of the "Trade At" rule and I am against sub-penny orders and flash trading. I have been a liquidity provider in the markets for 8 years now, but because of the sub-penny and flash orders, I am no longer providing liquidity. I no longer place trades on the bid or ask, I only use market orders so that I know I can get filled. In other words, I would rather pay the spread than take my chances on the bid or ask. This is a first for me.
I believe, as time goes on, most traders are approaching the markets in the same manner I am and taking liquidity instead of providing it. This will create larger spreads between the bid and ask prices, and, in my opinion, in the case of a large geopolitical event, will create a sell-off of an unprecedented nature as all market participants will simply step away or push the market lower.
Please do your best to eliminate the sub-penny orders and flash trading so this current two-tiered market, can return to one-tier, and liquidity providers can return to trade in a fair market where we have one true NBBO that everyone has equal access to.