November 30, 2011
The practice of sub-pennying is unfair and must be resolved. The ability of some market participants to partake in this practice, while others cannot, creates a two-tiered market and promotes less participation by liquidity providers to "park" limit orders away from the market. I strongly encourage the SEC to look at this practice very closely and hopefully realize that this creates an extremely unfair advantage to large broker-dealers who have the ability to trade the sub-penny spread of $0.0098 all day long on thick stocks, without anyone ever knowing about it or being able to do anything about it. This is fraudulent in my opinion, and must be resolved. I am adamantly opposed to the proposed rule change for the NYSE one-year pilot Retail Liquidity Program, and any other proposals that allow sub-pennying in our markets.