April 17, 2017
In reading the proposed rule, it is written in incredibly vague terms that appears to me to solely target smaller traders with say less than 100,000 in their account. The verbiage seems to indicate that any software package that is used to deliver real time data could possibly be subject to non-display data feeds if that package also provides analysis and alerting tools that can be programmed by the user. How is this to be deemed fair? What benefit does this proposed rule provide? How are non-professional traders supposed to trade with this type of cloud overhead?
If this rule goes into effect then I and many of the smaller traders out here will likely be forced to quit the game. That is incredibly infuriating. Perhaps if the verbiage was better defined then it would be almost digestible but the broad nature of the language allows for the brokers to have far to much discretion on how to apply the rules.
Perhaps it would be better to state under what exact circumstances non-display data fees would apply while taking into account all the different types of trading that is common today. Also please consider some type of warning criteria, like with pattern day trading on sub 25,000 accts, where by a trader can only execute so many day trades without enforcement kicking in.