July 7, 2017
CACI International Inc appreciates the opportunity to comment on SR-BatsBZX-2017-34, the proposal to introduce the “Bats Market Close.”
One of the primary reasons we chose to list on the NYSE in 2002 was to have the human oversight of a specialist then and a Designated Market Maker (DMM) now throughout the trading day, and especially during the opening and closing auctions. We saw this as a quality of market discriminator. We expected the specialist then and the DMM now to facilitate fair and orderly trading and to commit capital to help dampen volatility. Fragmenting liquidity in the closing auction, if this proposal were to be approved, would impact the DMM’s ability to provide this service. We believe it would add an unnecessary layer of complexity to a system that currently is too complex, and could lead to increased volatility for CACI’s investors.
We ask that the Commission consider, in depth, how the consequences of approval of the Bats Market Close would increase market fragmentation, diminish and impair human oversight of the end-of-the-day stock trading, and impact the time-tested auction process to determine the critically important closing price.
David L. Dragics
Senior Vice President, Investor Relations