May 27, 2016
This shell game off fee changes continues in failing to address the fact that ARCA, which speaks about competitive rates, and not disenfranchising anyone, has ceased publication of its daily aggregate short volume which all public exchanges including ARCA had agreed to provide in 2009, and which it received the benefits of having proposed legislation under Dodd Frank aborted, a requirement that money managers would have to report their short positions, which was aborted, and the market makers were given a naked short exemption...
All of the above was intended to make markets more transparent and bolster confidence in our markets...
ARCA now has reneged on its deal, and now wishes to charge investors 6000.00 to 12,000 per year, or more, for the data that prior to April 11, 2016, had been free as agreed...
Every other exchange in the US,...BATS EDGE NSDQ NSX NYSE NPSX NQBX....without exception...continues to provide that data free as agreed upon....
ARCA remains the only hold out and without ARCA's data, the others are rendered obsolete, because no clear picture can be gained by having to guess ARCA's short volume percentages for any given stock.
Not only are we now as susceptible to another 2009 naked short sale attack on our financial institutions, it is EVEN MORE LIKELY to occur, given the decriminalization given by means of the market maker exemption, and the lack of any reporting requirements on the part of fund managers...
ARCA, in holding out this information, is poised to be the key exchange by which naked short schemes can be carried out, being the only one that wont tell the public what the daily short volume percentages were each day.
This is a disaster in the making that the Commission should take VERY SERIOUSLY as it is a willful breach of a deal made in good faith under Mary Shapiro's leadership and it spits in the face of the investing public and the Commission itself, in that it was done without any notice or application to the Commission or the public.
To allow this to continue is criminal ....