Subject: File No. S7-21-09
From: William A Thayer
Affiliation: Certified Financial Planner (retired)

September 30, 2009

First, flash orders only favor the very few that have access to fast ordering computers. This does not benefit the ordinary citizen at all. It creates a non-level playing field. It is inherently unfair.

Second, what do flash orders do to enhance our economic production? Nothing. A company like GE issues stock so that it can have the money to build jet engines etc. It doesn't need the money for 10 seconds, 10 minutes or 10 hours. It needs it long term. Certainly, any citizen might have their own reasons for selling GE at any second, but there is plenty of existing liquidity to do that. The argument that flash orders increases liquidity is bogus. Flash orders do not fulfill the important function of supplying our companies with long term capital. It is just a short term, hi tech technique to enhance the profits of a very limited number of investors.