Subject: File No. SR-BYX-2014-011
From: Suzanne Shatto

August 19, 2014

there should be no premium service offered by exchanges that advantages premium customers over the marketplace. since BATS Y exchange has control of data through their computer system, BATS Y should not profit by advantaging customers who pay a larger fee.

dodd frank principles:
Markets should be transparent.
Regulation should be consistent, without gaps that can be exploited by those who wish to indulge in risky, destabilizing or illegal behavior.
Market participants, not taxpayers, should bear the risks of their market activities.
And regulators should have the willingness and the tools they need to apply these principles to the day-to-day workings of the financial markets.
The Dodd-Frank Act translated these principles into law that is the foundation for effective regulation.

such a service would create an illusion for the non-premium customer, displaying an order book that does not exist. when you couple such a service with undisplayed and anonymous orders, you have a good story but not the accurate story. information is an important factor in the stock market.

this shifts risk from the marketmakers and brokers to the retail/institutional investors.

i am quite concerned that the data from the order flow going through the BATS Y exchange is not transparent to regulators.