December 14, 2015
I am writing in favor of approving the IEX exchange application.
Here is what was published by the SEC in 2005.
SECURITIES AND EXCHANGE COMMISSION
17 CFR PARTS 200, 201, 230, 240, 242, 249, and 270
[Release No. 34-51808; File No. S7-10-04]
AGENCY: Securities and Exchange Commission.
ACTION: Final rules and amendments to joint industry plans.
from page 16.
The Reproposing Release touched on this issue in the specific context of assessing the effect of the Order Protection Rule on the interests of professional traders in conducting extremely short-term trading strategies that can depend on millisecond differences in order response time from markets. Noting that any protection against trade-throughs could interfere to some extent with such short-term trading strategies, the release framed the Commission's policy choice as follows: "Should the overall efficiency of the NMS defer to the needs of professional traders, many of whom rarely intend to hold a position overnight? Or should the NMS serve the needs of longer-term investors, both large and small, that will benefit substantially from intermarket price protection?" The Reproposing Release emphasized that the NMS must meet the needs of longer-term investors, noting that any other outcome would be contrary to the Exchange Act and its objectives of promoting fair and efficient markets that serve the public interest.
The SEC's own words best describe what should happen and that this proposal should be approved because it meets the needs of long-term investors.