December 15, 2015
I strongly support the IEX application for the following reasons :
(1) A table recently posted on the internet showed that Stock Exchanges expressed as a percentage of venues receiving non-directed orders from a "large retail broker" amounted to LESS THAN 0.5%. The majority of their execution flow went to internalisers and pay-for-flow providers. I simply cannot see how this can be beneficial to the retail trader.
(2) IEX should be a protected quote because I want the chance to have my orders executed on a fair market that does not provide select participants with speed advantages.
(3) I intend to use the IEX Router because I cant afford to build my own and I do not want my orders subject to latency arbitrage.
(4) Many of the anti-IEX letters the SEC have received make desperate self-serving interpretions of obscure passages in Reg NMS. The SEC should be weary of these.
(5) I intend to use IEX so that my orders are not internalized and have a chance of executing against other investor orders as guaranteed by the Securities and Exchange Act of 1934.
(6) I'm tired of watching my market orders not completely fill because of Quote Fade - the IEX Router would prevent that.
(7) Do internalizers price my orders based on the SIP or Direct Feeds? The NYSE has stated that internalizers give me the SIP price (which has an intentional speed bump) yet trade on Direct Feed prices.
(8) Mary Jo White, the SEC Chairman, testified to Congress that she wanted to bring transparency, but it seems that some lobbyists and participants are being granted meetings that are not properly disclosed.
(9) Why do all my retail trades get executed by an internalizer, such as Citadel, who happens to be vehemently against the IEX application? (see also point (1) above)
(10) Existing stock exchanges send their quotes and trades slower to the SIP than to their direct feeds. How is that not an intentional (and illegal) speed bump? IEX won't sell a direct feed with a speed advantage, which is exactly what Reg NMS specifies.
(11) Which quote is more accessible (automatic): one that has to persist for 350 microseconds, or one that can be canceled before you can even see it? For example, according to statistics compiled by the SEC and published on their website, over 31% of all stock quotes have already expired by the time they reach California.