June 3, 2006
ISE's proposed cancellation-fee policy has the (possibly intended) consequence of playing favorites in the market with a two-tiered pricing structure. One that slaps-on an additional layer of fees to ordinary public market participants, while handing the benefit of no charge to privilaged members such as market-makers in effect, discouraging public investors and decreasing liquidity, while generating fee-revenues for itself.
Less than a week ago, ISE, a publicly-traded entity, announced that its average daily options-contract volume jumped 68.3% in the last quarter perhaps maybe that rise in trading volume is the source of any increase in bandwidth traffic.
The fact that other large options exchanges (and ISE itself) have managed to operate for so long and quite well without this type of fee-structure is indicative of how unnecessary these extra charges are. An additional concern is that, if passed, these fees would become viral among the other exchanges, thereby forcing up costs to the public for participating in the market.
In short, I urge the SEC to keep in mind the small investor who would be punished by this policy, and to thus reject this additional, and unnecessary barrier.
Best regards,
Terrance L. Jackson
Independant Equity-Option Trader