Subject: SR-BatsBZX-2017-34
From: Cole Stevens
Affiliation: Nobilis Health

July 6, 2017

Hi There,

Nobilis Health appreciates the opportunity to comment on SR-BatsBZX-2017-34, the proposal to introduce the “Bats Market Close.”

As a publicly-listed company, Nobilis Health wants to ensure that the secondary market trading in our stock is stable and robust.  We feel that listing on NYSE supports this goal.  Our Designated Market Maker, J. Streicher, has liquidity obligations throughout the trading day and most importantly watches over the key market benchmarks of the opening and closing auctions.  Given the importance of the closing price for both listed companies and the broader investing community, the process which produces this closing price must be changed only with careful consideration.

We believe that the Bats Market Close proposal will introduce confusion among listed companies, investors, and market participants, and therefore make assessing market activity and sentiment more difficult.  We also anticipate that the beneficiaries of this confusion will be market intermediaries rather than investors or listed companies.  Furthermore, we believe this continued fragmentation and decentralizing of closing activity will only increase volatility and reduce visibility for us as a public company.  We therefore ask the Commission to weigh the interests of all relevant parties when reviewing this proposal, and urge the Commission to reject this and any proposal that it feels could harm today’s very successful closing process. 

Best Regards,

Cole Stevens

Cole Stevens | Investor Relations Associate