Subject: Cardinal Health, Inc. Comments on SR-BatsBZX-2017-34
From: Sally J. Curley
Affiliation: Cardinal Health, Inc.

July 14, 2017

Cardinal Health, Inc. thanks the Commission for the opportunity to comment on SR-BatsBZX-2017-34, the proposal to introduce the “Bats Market Close.”

A key reason that Cardinal Health chose to list on New York Stock Exchange is to have the human oversight of a Designated Market Maker (DMM) throughout the trading day, and especially during the opening and closing auctions.  In the past, due to the use of dark pools and other trading vehicles, we have experience volatility during the last half hour of trading.

Our expectation is that the DMM will facilitate fair and orderly trading and will commit sufficient 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.  This is particularly worrisome during a period when passive investing is on the rise, and public companies are increasingly at a disadvantage in identifying their shareholder base.

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.

Thank you for your consideration of this important topic.

Sally J. Curley
Senior Vice President, Investor Relations
Cardinal Health, Inc.