Subject: SR-BatsBZX-2017-34
From: Robert F. McCadden
Affiliation: Pennsylvania Real Estate Investment Trust

June 29, 2017

Securities and Exchange Commission,
100 F Street, NE, Washington, DC 20549-1090

Pennsylvania Real Estate Investment Trust appreciates the opportunity to comment on SR-BatsBZX-2017-34, the proposal to introduce the “Bats Market Close.”

One of the primary reasons we choose to list on NYSE is to have the human oversight of a Designated Market Maker (DMM) throughout the trading day, and especially during the opening and closing auctions. We expect the DMM to facilitate fair and orderly trading and to commit capital to help dampen volatility. Fragmenting liquidity in the closing auction would impact the DMM’s ability to provide this service and could lead to increased volatility for our investors.

We ask that the Commission consider how approval of the Bats Market Close would increase market fragmentation, diminish and impair human oversight of end-of-day stock trading, and impact the time-tested auction process to determine the critically important closing price.

Very truly yours,

Robert F. McCadden
Executive Vice President and Chief Financial Officer
Pennsylvania Real Estate Investment Trust
200 S. Broad Street
Philadelphia, PA 19102