September 28, 2012
Elizabeth M. Murphy, Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-1090
Dear Ms. Murphy,
Themis Trading appreciates the opportunity to comment briefly on the SECs Technology and Trading Roundtable scheduled to take place on October 2nd, 2012.
We applaud the SECs examination of technological risks embedded in our market structure, and agree there is an imperative to bring back investor confidence in our US equity markets. However, we notice that while the makeup of the announced panel (referenced here: http://www.sec.gov/news/press/2012/2012-202.htm) indeed includes some highly respected and brilliant minds on the technology side of our financial industry, it is missing perhaps a bit more balance.
We feel that a more balanced panel would go a long way to showing the general public that the SEC is aggressively protecting their interests. Such a panel would bring investors more confidence that we are all trying to safeguard the financial infrastructure and superhighway on which their long term investments travel. Most importantly such a panel might bring a more diverse palette of market structure ideas on which the Commission might base meaningful reform.
While we at Themis would love to discuss a more fundamental examination of our market structure, and perhaps the value of starting over and eliminating payment for order flow and the rebate maker-taker pricing model, we realize that the purpose of this panel, as conceived, has a more technological bent. As such, might we humbly suggest reaching out to Babsons Professor Michael Goldstein and Nanexs Eric Hunsader for inclusion on this roundtable? Again, we believe a more balanced panel would be fruitful for the Commissions efforts.
Thank you for allowing us to comment.
Themis Trading LLC