April 4, 2014
Addressing Mr. Simon's obviously biased comment letter, however deceitful and misleading it may be.
Simon - "The three comment letters received by the Commission do not raise any significant issues related to removing the contra-party size restriction for QCC orders as proposed in this rule filing"
Story - "What the ISE does not mention is that by its very nature the QCC order type LIMITS participation on an order to counter-parties that have been selectively shown the order by the broker handling it. If the ISE is so concerned about MAXIMIZING the opportunity for price improvement and competition, they should be making the argument for exposure to the ENTIRE marketplace, not just selective counter-parties."
The original intent of QCC order type was to supposedly provide a block-crossing mechanism for large institutional orders. However, since its INCEPTION the ISE has allowed brokers to break-up the initiating order into many smaller counter-party trades and cross it on QCC as long as the PRINT was over 1000 contracts.
Simon - "The ISE is seeking to enhance the QCC order type"
The truth of the matter is the ISE isn't "looking" to enhance the order type. The ISE has allowed brokers to conduct this deceitful practice from the beginning. The ISE is only NOW trying to get the SEC's permission to break-up QCC orders because the PHLX brought the SEC's attention to this matter. Most likely, if not for the PHLX actions, the ISE would have continued allowing this practice indefinitely.
The data would be extremely easy to sequester to show that this is true.
The ISE must figure it's easier to ask for forgiveness than permission
Simon - "which is designed to ensure that large orders can benefit from participation with the largest possible pool of liquidity providers"
Again, if Mr. Simon and the ISE are in fact so concerned about "ensuring" the largest pool of liquidity providers, why do they want to limit order exposure?
Under current QCC rules, liquidity providers are supposedly limited to select counter-parties that a broker handling an originating order chooses to solicit. The proposal now put forth will only create a more opaque market, and at the same time include smaller (higher commission paying) counter parties to be exploited.
The simple truth is this, "to ensure the largest pool of liquidity providers, the order MUST be exposed to the OPEN market". Anything less, is NOT maximizing exposure and is limiting in it's very nature.
An orders exposure should not be limited to a select few counter-parties that a broker chooses to solicit.