May 26, 2020
1. I support the request of a number of parties, including various organizations representing retail and individual investors, and trading groups, that the May 26 deadline for comments be extended, in view of the significant changes resulting from a nearly 600 page rule changing the way in data about quotations and trades ia aggregated.
2. The use of a destributed data collection system may be desirable on first view, but it is not clear how the development of multiple parties interacting and providing quotations and trade data can be implemented over time to assure accuracy, completeness, and avoidance of gaming and fraud.
3. The issues of latency and timing of quotations from multiple sources are serious issues. Front running, fraudulent price seeking and bidding, and arbitrage between different locations for execution of trades have been historically problmenatic for the securities markets. While the Department of Justice represents that competition in data collection and submission will be inherently good, it is not actually good if the data provide systemic advantages to some groups of traders or market makers. All forms of data submission must assure full and equal, transparent and equally timely access to data, and assurance which cannot be provided at this time given the complecity of the way the disaggregated data submission may be implemented.
4. Some authority or agency should examine ways in which the new system could be gamed, arbitraged, fraudulently used, or otherwise implemented to interfere with retail investors ability to access market data and execute trades on a fiair and equitable basis, on a time and price equivalent to all other market participants, including those who may have better access to data, quotes and execution. It would be worthwhile to undertake a study by, for example, Rand, or a University such as MIT or Columbia to study the gaming potential and necessary safeguards under the new system. Without such a study of possible market failure and fraudulent executiion, the new market data from disaggregated sources poses a risk which, as unexamined, is unacceptable.