Subject: File No. S7-02-10
From: Leland Teschler

February 16, 2010

I believe flash trading and the sub-pennying that goes with it are going to sow the seeds of the next market crash. By allowing a select few large firms to enter flash subpenny orders you are closing out the smaller traders who provide a cushion to prices during times of large market runs to the downside. These smaller traders can in no way compete with the handful of large firms that are granted flash trading access. The subpennying that goes on during flash trading effectively shuts out smaller traders. If it continues, they will eventually leave the market. When the next big swoon comes, there will be no bids on the way down from the short-term traders who used to be standing there taking the other side. That also means there won't be any bids that the flash traders can step in front of. The result: A market crash, possibly the biggest of all time.

Can anyone really believe that providing a price that is better by one-hundredth of a cent per share is providing a service? Shareholders may see an additional few cents at best on individual trades, but at a cost of a much wider price gap when it really counts.

I hope the SEC eliminates flash trading and takes away this unfair advantage now weilded by a few huge firms.