October 24, 2014
SECURITIES AND EXCHANGE COMMISSION
(Release No. 34-73237; File No. SR-BATS-2014-043)
September 26, 2014
Self-Regulatory Organizations; BATS Exchange, Inc.; Notice of Filing and Immediate
Effectiveness of a Proposed Rule Change to Adopt Rule 11.24 to Permit Members to Designate
their Retail Orders to be Identified as Retail on the Exchange’s Proprietary Data Feeds
i do not think this is a good idea.
i see no benefit to investors about having their trades marked as "retail" instead of the MPID of the broker. i see no rationalization about why this would be an improvement, which makes me suspicious.
retail investors have a different range of order types to choose from than the marketmaker, high frequency trader, professional traders. as a result, retail order behavior demonstrates their status in the market. the retail investor receives worse information than the other participants, since they do not see non-displayed orders and the daily short report by FINRA does not include all orders traded. the bimonthly short report also includes only those shares that the broker/dealer wants to disclose and this information is made public very late. this bimonthly short report does not match the bimonthly reports provided to regulators. this puts retail orders at a disadvantage at the exchange level. retail order appear to be disadvantaged in settlement procedures because the retail orders may receive IOUs at settlement, rather than receive the shares.
the exchange has not shown any advantage in this rule proposal. in other words, there is no reason to change from the current operation.
i want retail investors to have good, current information and regulators to have good, current information in order to trade at the exchanges. this view is based on transparency and fairness in dodd-frank.
the SEC has to apply their mission statement here. the SEC needs to represent the public interest in the equity markets.
suzanne hamlet shatto
mountlake terrace, WA