Subject: File No. S7-02-10
From: david adorney
Affiliation: equity trader - for both specialist firm and HFT firm

July 24, 2012

I have 13 years experience as trader on both the old regime (specialist) and the new (HFT). So I feel I have a balanced view. The low hanging fruit to fix here is the internalization/dark venues. Markets should be open and "lit" to the public. The escape from the lit exchanges has made this public stock market a private, 2 tiered event everyday. The big firms are now grabbing retail/institutional flow and internalizing it in serious numbers these days. Buyers are NOT meeting sellers as they should. Pro trading firms are inserting themselves in the middle, thus violating the negative obligation that is supposed to hold true. And block orders are NOT getting the best executions due to the lack of protection for real liquidity that is impossible to show on the top of book (due to the HFT orders that will always jump ahead for 100 shares). ALL orders should be forced to trade on the real stock market of lit, open limit orders before they are printed away at sell side firms. Please consider protecting depth of book in that way. There should not be an HFT market and a big bank market as both sides would like.