February 9, 2015
Anonymous Retail Investor to
Securities and Exchange Commission
Public comment on Release No. 34-74219 File No. SR-NYSEARCA-2015-03
Proposal for per rack unit cabinet allocation and data/network connections to retail investors.
Current pricing of NYSE ARCA colocation services creates an arbitrary and anti-competitive barrier to entry for retail market participants. The pricing is done in units of space i.e. cabinets that are unnecessarily large for the small hardware requirements of retail market participants who only require one or two rack units (typically) of colocation space for hardware. Similarly, network connection ports and bandwidth (1 GB and 10GB) are not allocated and priced fairly to retail participants. It seems perverse to offer retail liquidity programs but no access to the pricing quotations for small participants or retail traders in the market place or at time intervals that would allow fair participation in the limit order book compiled by the matching engine nor messages that originate and terminate at any or all messaging systems.
It is also perverse to sell data points (messages) we (retail traders) help to generate back to us at inflated prices.
The pricing for these services is not comparable to similar telecom, carrier, ISP, web hosting or other colocation services in other sectors of the economy that use the same type of systems, networks, hardware and software.
I respectfully ask that SFTI connections be available to retail traders (non-professional) traders at a reasonable (discounted) per unit costs and data/messaging connections be available at similar, (discounted) costs.
Data feeds and messaging should be available for the same price that is typical of retail brokerage firms to individual traders at the facilities offered by the exchange. Examples shown here:
https://www.interactivebrokers.com/en/index.php?f=marketDatap=mdata
http://www.tradestation.com/pricing/software-and-data-pricing/market-data-pricing
I respectfully ask that direct data/messaging from the exchange be available to non-professional individuals in the data center or SFTI point of presence in the same format and specification as professionals but at the above stated rates per customer or at approximately those stated rates.
Even within the financial community these costs are not on par with other facilities. For example Equinix NY4 offers colocation at prices less than the NYSE cost.
A search for normal (non-financial) colocation services and data yield numbers such as these:
http://www.creativedata.net/index.cfm?webid=168
Single Rack Space - $30 per month per space 1/2 Rack (20 net rack spaces) - $495 per monthFull Rack (40 net rack spaces) - $735 per month
http://www.simplywebhosting.com/colocation-pricing.shtml $50/month per rack unit
http://www.co-location.com/detailedpricing.html $80.00 per 1U Starting at $575 per 1/2 Cabinet Starting at $650 per Full Cabinet
We encourage exchanges to look for ways to allow fair and equal access to the exchange auction mechanism for all participants and or allow and even encourage their members to do so.
Respectfully,
Average Retail Investor
http://en.wikipedia.org/wiki/Household_income_in_the_United_States
http://www.statisticbrain.com/american-family-financial-statistics/
http://finance.zacks.com/much-money-average-american-family-savings-7304.html