April 13, 2010
Dear SEC staff,
Market participants who are allowed to execute sub-penny orders have an advantage over the traders who aren't able to do the same.
Some trading strategies became obsolete because of this practice.
Volume dried up significantly. Liquidity-taking pushes market up during an up-trend and will push it down during a correction as sellers would be willing to grab any liquidity available in sight.
My experience: I used to always provide liquidity in the past, yet ever since sub-pennying took hold I stopped. Now I always take liquidity, which is unfortunate because I would much rather get paid for providing it.
Providing liquidity is a service to the market and right now with the current rules in place, there's no advantage in providing this service.
Please ensure that the same rules apply to all market participants.
Thank you for taking in consideration our concerns.