August 19, 2014
ID: SEC-2014-1298-0001
34-72730 Jul. 31, 2014 Notice of Filing and Immediate Effectiveness of a Proposed Rule Change to
Amend Rule 11.24(a)(2) to Include Riskless Principal Orders to the Types of Orders that May Qualify as Retail
Orders under the Retail Price Improvement Program
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.
http://blogs.law.harvard.edu/corpgov/2012/11/16/dodd-frank-principles-and-provisions/
these principles are violated by this rule filing in a rather wholesale manner.
BATS Y indicates this rule is "non-controversial". the only reason they do that is that they have adopted processes outside of the approved rules. they ignore the damage that they have done to the stock market.
they seek to advantage marketmakers and brokers over institutional investors and retail investors. they merely reference current order types. these order types are not available to me and probably not available to retail investors. the preparation of this rule proposal contains information on which to make decisions about their processes. they have not halted the processes because they don't respect the regulators and think the regulators have NO CHOICE other than to ratify their behavior.
retail and institutional investors should have the same order types (and instruction) functionality. retail and institutional investors cannot now choose the exchanges for their orders. the only choice is whether we choose to invest in an unfair marketplace.
the regulation SHO process, for instance, depends on accurate reporting of shortselling. none of the exchanges accurately report shortselling. therefore, any "circuit breaker" action rarely occurs. failure to report shortselling accurately violates transparency, lack of an audit trail so that regulators can trace trades through the system.
isn't it funny that these exchange rule proposals about order type appear to be very similar? perhaps this is a conspiracy.