December 12, 2015
Thank you for the opportunity to comment. I am submitting this letter in support of approval for the IEX Exchange application.
I believe this is essential in order to restore the integrity of our markets for the following reasons:
1. Having been victimized by high speed traders on order fills, it is imperative that a protected quote be provided through an exchange that does not allow and facilitate speed advantages from only a handful of select participants. IEX provides this option.
2. High speed traders are interested in only one thing: latency arbitrage. Using the IEX router would allow myself and other traders the ability to have our order flow avoid such practices.
3. The Code of Federal Rules is being clearly violated by high speed traders with regards to the NBBO and the SIP through the use of proprietary data feeds. This is a violation of a key part of Reg NMS. The IEX model restores the priority of the SIP as it was intended to be implemented.
4. The Securities and Exchange Act guarantees that my orders be given the chance to execute against other investor orders. This guarantee has been subjugated by internalizers. IEX helps investors avoid this opaque process. Citadel incidentally, a vehement opponent of the IEX application is one of the largest internalizers in our markets. There's clearly a reason for that and it is not to benefit retail investors.
5. Current exchanges intentionally slow dow prices sent to the SIP so that faster Direct Feeds can gain an advantage over those orders. IEX gives my orders a chance to avoid this unfair advantage.
6. It has become increasingly difficult to get complete fills on market orders due to incessant quote fading. Routing through IEX would stop this from happening.
7. Opponents of the IEX application continually lament about the 350 microsecond delay introduced by the IEX router, yet it takes these same opponents over 80 times longer than that 350 microseconds to execute an order. Why would opponents such as Citadel even care about 350 microseconds when my broker timestamps my trades in minute increments? This is an important fact that I hope the SEC does not overlook. These opponents are against it in order to protect their unfair latency arbitrage opportunities.
Additionally, existing exchanges send quotes and trades to the SIP more slowly than to their own proprietary Direct Feeds. How is this not the same "speed bump" that IEX proposes? IEX does not plan to sell direct feeds, this, incidentally is what Reg NMS specifies.
Also, The Chicago Stock Exchange has a protected quote but it's "speed bump" is a full 8000 microseconds - much larger than that proposed by IEX. This clearly hasn't caused a catastrophy to date, why would IEX's?
8. The SEC (and most importantly Chairman White) has claimed a desire for increased transparency. However, opponents of the IEX application have been granted meetings which were not properly disclosed to the public. Why?
9. As an equities trader operating from Newport Beach, California, one of the most disturbing aspects of the current market structure is that over 30% of all quotes have expired before they reach my location. This fact is derived from the SEC's own statistics. How are those accessible (automatic) quotes? IEX would ensure that this does not happen.
10. Opponents of the IEX application have cited damage to Latency Arbitrage strategies. High Speed trading firms have gone from denying that latency arbitrage even exists to demanding that it be protected by denying IEX exchange status. Latency Arbitrage is a market manipulation tactic. It provides no useful or beneficial market function and high speed firm Virtu just received a multi-million dollar fine for it in European markets.
11. If I'm not mistaken, regulations give me the right to direct my own orders. However, due to its dark pool status, my broker won't route there even though this is where I want to execute my orders. When IEX is granted exchange status, my broker will accept execution through the IEX Router.
The current exchanges have created an environment in equities that clearly favors one small group of participants - high frequency traders. Direct Feeds have undermined the NBBO process and current regulations are being ignored by these participants in favor of protecting latency arbitrage, a practice which is detrimental to both the vast majority of longer term market participants and market structure itself in times of distress.
Approving the IEX application is the right move. A move away from a market that favors the few who provide little to no value, to one that favors the majority of the investing community.