March 1, 2016
I am writing in support of approving IEX's exchange application.
The goals of an efficient securities market are to connect holders of capital with those needing that capital. By facilitating such transactions, both parties -- along with the rest of the economy -- can benefit. However, such a market is only fair when the rules are transparent and all participants can access the same NBBO.
This is no longer the case. The fact that firms with servers colocated on exchange premises have access to a direct feed vs the rest of us who must rely on the SIP means that there is no longer a true NBBO that is equally available to all parties. This does not promote fair competition, price discovery, and optimal transaction execution.
This form of latency arbitrage becomes much worse when it allows practices such as quote stuffing and quote fading to manipulate the NBBO in a way that harms market participants and violates the spirit of reg NMS.
IEX also promotes transparency by assuring all participants are subject to the same delay. The fact of the matter is all exchanges have speedbumps in place. The only difference between IEX and the currently approved exchanges is that IEX subjects all orders to the same, publicly known speedbump, whereas in other exchanges, that speedbump can vary based on your willingness to pay for exclusive data feeds and/or colocation. In that sense, I believe IEX's proposed exchange is closer to both the spirit and letter of reg NMS than the currently operating exchanges.
Finally, the 350 microsecond delay proposed by IEX has absolutely zero effect on the trading done by actual investors, i.e. those looking to invest in worthwhile business ventures, rather than speculators merely looking to skim money using latency arbitrage. Latency arbitrage contributes little to a market that's supposed to be concerned with evaluating a company's performance and potential, not how quickly you can move in and out of that company's stock.
Indeed, my brokerage timestamps are marked in minutes and seconds. I am unable to, and indeed, do not care to, invest at millisecond speeds, much less microsecond speeds. I suspect the vast majority of investors are in the same boat. We investors have been harmed far more by the unequal, opaque speedbumps used by current exchanges to prioritize HFT orders over those of the rest of the investment community.
I support IEX's exchange application and intend to use the IEX router to execute my orders, because I believe it will reduce the latency arbitrage that HFT firms use to degrade my order execution.
Currently, I am unable to route my orders to IEX due to its status as a dark pool. Approving IEX's change to exchange status gives me another option for improving the execution of my orders, and also promotes further competition from other exchanges to offer me the same benefits that IEX does.
I strongly support approval of IEX's application, and believe it will improve the current market and better align it with the original goals of reg NMS.