Subject: File No. 10-222
From: mark f ierardo

December 16, 2015

The fact that HFT in general violate regulation NMS in that they have an unfair speed advantage over the SIP is simply wrong. The fact that IEX is supplying a level playing field leads to fairness for all participants, eliminating the latency arbitrage HFT depends on. There's is merely a game of speed jumping in front of bids/offers they know are coming but have yet to hit the SIP. Trades are supposed to be executied according to the SIP NBBO. That simply does not happen with current co-location direct-feed schemes, a condition an IEX router would alleviate.