CFTC-SEC Joint Committee Report Notes

YesYesterday the blue ribbon committee (membership list below) that the CFTC/SEC appointed to examine regulatory risks and make recommendations on how to avoid another flash crash released this report. Most of it reiterates support for measures that have already been proposed or implemented such as single stock pauses/circuit breakers, but there are a few interesting items.

• Commends the SEC for their sponsored access approach (i.e., pre-trade risk mgmt) and pushes the CFTC to do the same. (Could be very positive for Sponsored Access providers like FTEN/Nasdaq, ULLink, Quanthouse, etc.)
• The committee comes out in favor of incenting high frequency traders to make ‘real’ markets. (Could be very positive for Market Making 2.0 operations such as TradeBot & Virtu).
• Recommends a ‘trade-at’ rule which would effectively penalize internalization and preferencing activities by 50 mils—possibly making it an unprofitable business model. (Very negative for traditional wholesale models like Knight, Citadel and Getco, as well as broker-owned dark pools. Potentially positive for non-broker-owned dark pools like LiquidNet, Pipeline and PDQ).

I think the most controversial aspect of the report will be the trade-at rule recommendation. Besides being completely outside the purview of the Committee’s charter, there are too many uncertainties, such as how many wholesale market makers (Knight, Citadel, etc.) might exit the business and what effect would that have on liquidity. So I doubt a rule will get passed or if one does, it will be watered down enough to be largely ineffective.

Committee Members
Brooksley E. Born, Retired Partner, Arnold & Porter LL.P, Former Chairman CFTC
John J. Brennan, Chairman Emeritus and Senior Advisor, Vanguard Group
Robert F. Engle, Michael Armellino Professor of Finance, Leonard N. Stern School of Business, New York University
Richard G. Ketchum, Chairman and Chief Executive Officer, FINRA
Maureen O’Hara, Robert W. Purcell Professor of Finance, Cornell University
Susan M. Phillips, Dean and Professor of Finance, The George Washington School of Business, Former CFTC Chairman
David S. Ruder, Professor of Law, Emeritus, Northwestern University School of Law, Former SEC Chairman
Joseph E. Stiglitz, Professor of Finance and Business Administration, Columbia University

How Low Is Low (Latency)?

Historically, very few brokers or exchanges actually measured latency of their trading and matching systems, at least not in a way that invited comparison. In the cases where an entity talks about latency numbers they are usually expressed as turnaround times inside a particular system, for example in this article from Wall Street & Technology:

Nasdaq's Hyndman says that migrating to INET has allowed Nasdaq to offer the fastest possible transaction times. "We've reduced latency from 10 milliseconds down to 1," he says, referring to the time it takes once an order is placed on Nasdaq's system to acknowledge it electronically.

Unfortunately, the numbers can pretty much be made to say whatever you want them to say. The biggest problem (from a high-frequency trading standpoint) are that these types of measurements usually don't take into account peak loads on their systems, which tend to occur at the exact times that low-latency is most important to the trading strategy. I find it hard to believe that Nasdaq's expressed turnaround time is correct at 9:30AM, 12:00 noon, and 3:59PM. (Note that the above article was written in 2007 and I'm pretty sure Nasdaq--as well as their competition--have decreased their response times since then).

More recently, in order to attract high frequency order flow some markets have begun to figure out ways to bring more credibility to their metrics and measurements. This article mentions some of the initiatives from NASDAQ, NYSE and BATS. As you will quickly realize, however, one is pushing Correlix, one is pushing SeaNet and one is doing it themselves--good luck comparing those results.

So the fact is that there aren't really any 'standard' metrics for latency measurement of trading systems. This would seem to be a good area for the industry to create a working group to foster cooperation in. Until then, pretty much any reasonable approach can be used and defended by vendors. To be on the safe side and facilitate comparison many just settle for average turnaround.

If I were looking at a report, I would want to start with average times, but some statistics about maximums under some loading conditions would be very helpful as well. The latter would take into account the system's ability to handle increased market data traffic as well as order generation.

Early thoughts on the SEC Sponsored Access Proposed Rule

I've been working on an analysis of the Sponsored Access rule, all 95 pages of it. The SEC wants firms that send trades to exchanges electronically (and which ones don't?) to implement electronic pre-trade checks that make sure their algos aren't going wild. The short story is that so far I don't see these requirements as overly onerous. Here are some preliminary thoughts:

1. The rule applies to all exchange and ATS connectivity, not just sponsored access. So all trading emanating from a B/D, including prop, program, algo, market maker, dma, etc., will be subject to the same risk checks. That means that virtually everyone will be on a level playing field (speed-wise) with the HFT guys being sponsored. Or phrasing it differently, no one will be at a competitive disadvantage by being subject to the risk management controls.

2. The CEO of the firm has to personally attest that proper risk controls are in place for all electronic trading. That's right, the CEO. So if you're running an HFT business you better be prepared to explain to him how your business works in very minute detail, because it's his butt on the line. Which by extension means your butt. (Can you imagine having to ask Jamie Dimon to sign off on this? Brian Moynihan?)

3. For the first time, the SEC has actually defined exactly what a broker should be monitoring for, i.e., capital/margin, relationship to last price, obvious errors, Reg SHO, Reg NMS, etc. I see this as going a long way toward relieving brokers' lawyers concerns about compliance, i.e., "If this list of checks is good enough for the SEC, it's good enough for me," effectively eliminating one of the existing blocks on sponsored access.

4. The fact that the SEC has put forward these rules will make it easier to extend sponsored access to other asset classes.

5. Winners:

• Exchanges, because it will be much easier for clients to directly connect and there will be more brokers offering the service,
• FTEN and their nascent competitors because many brokers will turn to them as an outsourced means of compliance with the rule. However, some CEOs may balk at being held responsible for the actions of a small technology firm.
  

6. Losers:

• Firms that have previously spent lots of money building direct exchange access infrastructure, because clients will gravitate toward utility providers like FTEN
• Electronic agency brokers because the value of the service they provide will become harder to differentiate.

Dark Pool Letters to the SEC

Let's get 2010 off to a good start by looking at some of the letters received by the SEC about their proposed "Regulation of Non-Public Trading Interest" or as it is more commonly known, dark pool regulation. To summarize, it appears that most of the industry is supporting either dark pools or dark liquidity in one form or another, while most non-industry commentators are opposing it. Unfortunately, most of the non-industry letters don't specifically address the issues the Commission is looking to regulate, i.e., actionable IOIs, the display obligation threshold, and trade reporting. The public seems to overwhelmingly favor an "all-or-none" approach, that being something close to summary execution (and I don't mean order flow).

The buy-side is largely absent from the comments so far. Larry Tabb has taken up their cause with some interesting statistics he has gathered through his research. Liquidnet has admirably submitted one of the few letters that goes beyond its authors' own self interests.

The award for most thoughtful comments, at least to date, goes to Steve Wunsch. He has turned the arguments of most dark liquidity critics inside-out, and in doing so makes sense of where we are, how we got here, and where we're going in terms of market structure. It's also pretty safe to say that Steve won't be working at the SEC anytime in the near future. To wit: "The Commission has, after all, been doing nothing but imposing transparency and fairness for three and a half decades, and it clearly isn’t working." Required reading!

For those who are fans of complete irrelevance, we're seeing some familiar themes like motherhood, apple pie, and short sales but we're also beginning to see the introduction of new 'worries' like after-hours trading and tax evasion. The power of God is invoked in some letters, something I'm sure the Commission is thrilled about. And to make things even more ominous, members of the plaintiffs' bar are now weighing in.

The deadline for submitting comments on this important proposal, release number 34-60997 is February 22, 2010. Just click here to make your views known.

Bill


"It is common in comment letters to praise the Commission and the work it is doing, complimenting its wisdom and courage for bringing up for discussion all the important and controversial issues of the day. It is also common to grant the Commission good intentions and to attribute any problems only to unintended consequences or to new technologies or to unanticipated economic developments. No one should take such letters seriously." -- Steve Wunsch, Wunsch Auction Associates, LLC, New York, New York

"By way of introduction, I am a plaintiffs' class action lawyer that has represented aggrieved investors in private securities class actions for the past ten years. It is from this perspective that I write. Without belaboring the point, the continued non-disclosure of large volumes of transactions in "dark pools" poses significant threat to efforts to prosecute private rights of action under the federal securities laws." -- Mary K. Blasy, Esq., Scott + Scott, LLP

"This is about hft, flash orders, and dark pools. IN truth I do not want any. I am also so sick of wall street firms telling the sec that I am the person who benefits from things I don't want...The very idea of dark pools is unamerican." -- David Blumenthal, MD

"Why, if you will prohibit or restrict dark-pool trading (DPT), do you allow after-hours trading (AHT)? ...AHT is every bit as discriminatory against a large segment of the market participants as is DPT... After-hours trading should be immediately abolished, or all markets and brokerages should be mandatorily extended to cover those hours." -- Malcolm L. Kantzler

"I am employed in a dusty old warehouse. I do not make much money. So I want the mutual fund managers to have the best pricing they can so I can make the most money on my humble investments. Dark pools provide that...These regulations come from the human need to control other people but do not control me. Or it is somehow evil for someone else to have a profit or more of a profit because that is greed but I can have a profit, even a large profit, and that is moral and ethical. We then conclude we need to stop this immoral greed. Then we use these type of regulations to stick it to the evil greedy people (the big boys - rich) we do not like. What happens is we hurt ourselves more than the people we are targeting. This regulation intended to stick it to the greedy ends up cutting our own throat. This is exactly the reason the Lord gave the tenth commandment Thou shalt not covet - Exodus 20:17. Regulation like this is coveting. Coveting always comes back and cuts the throat of the coveter. The Lord gave us the tenth commandment to protect us. The Lord will stick it to the greedy. I trust the Lord, not government regulation." -- Bob O., Plymouth, Minnesota

"... if the trades are not made public, it is a great opportunity for parties to make a secret profit that would not be taxed." -- William A. Thayer, San Diego, California

"The proposal to eliminate,almost(1/4 of 1%), "dark pools",should have been instituted long ago..Great work and may God bless" -- James A. Swiatek, Newaygo, Michigan

"Re Dark Pools: Don't regulate them ... ban them ... completely ..." -- Ken Blanton

"The number one recommendation from heads of buy-side desks on action to be taken to improve market structure is to move slowly, carefully, and with the utmost of care. What action would these traders like to see today as the politicians and regulators contemplate how to restore investor confidence? Twenty-five percent of head traders say three things: “don’t do anything precipitously,” get rid of an uneven playing field by banning flash orders, and leave short sales alone. Another 23% are calling for no restrictions on dark pools – no reporting requirements whatsoever and no action that would threaten the choice to go dark." -- Larry Tabb, CEO, TABB Group, LLC

"Call me naive, but since beginning my adventure into the stock market about three months ago I quickly came to the conclusion that there was some outside force manipulating stocks at a pace significantly faster than my ability to digest company information and react with a simple trade ticket to buy or sell. After looking into my suspicions via Internet searches I happened upon the issue of computer driven trading. I guess I was of the ignorant mindset that only a human would be allowed to initiate a trade. Basically I have come to the realization that the average individual has no chance what so ever against the algorithms and dark pools that are aligned to take his/her small savings a penny at a time at the speed of light. I can stare in amazement as the company stock charts bouncing up and down for no apparent real-world reasons, and now that I know that there is a mindless math program running at 50 gigahertz behind these movements I have given up and will chalk this experience up to the unrelenting Wall Street greed that will drive this nation into the ground. I have always considered myself a reasonably intelligent individual, but now I know what Chess Champion, Garry Kasparov must have felt like when he was defeated by IBM's Deep Blue Supercomputer...." -- Brian Klaus

"The stock you think you are buying in the stock market may not be that stock, but an inferior imitation. The inferior imitation is phantom stock, and it occurs in short selling. We propose procedures to close a perilous loophole for this fraud that the SEC rules permit." -- Tom Garcia, Ph.D., Professor (retired), University of Chicago, Booth Business School, Rancho Santa Fe, California

"Dark pools should be banned...along with all the other financial chicanery (derivatives, collateralized mortgages, erosion of credit standards) that has nearly caused the collapse of the world's economic systems...Why are some investors allowed to be in the markets and not abide the rules that are there for Everyman? ...Stop it. Stop all the infractions. Put the focus of investors upon creating wealth through the development of a tangible product, or a service that ennables those who do, or something that can be marketed to the world, rather than how to suck the economy dry in yet another financial shell game" -- Janice B. Campbell, Chief Compliance Officer, John A. Wolfe Associates, Inc., Portage, Michigan

"The Commission's proposal would apply restrictions on ATSs that have never been applied to other market participants performing the equivalent function, including agency trading desks, firms that execute as principal, firms that cross customer orders as agent, firms that internalize customer orders and floor brokers. Because of the disparity in application of the display requirement across different categories of market participants performing the same function, we expect market participants will structure around the rule restrictions to achieve the same result, but in a less efficient manner. ...attempting to address these alternative structures would mean the end of principal trading desks, agency trading desks and floor brokers, which would be a bad result for investors. We also disagree with the assertion that dark pools have created a "two-tier market." ...Since institutional and retail brokers representing long-term investors can participate in dark pools, dark pools do not create a two-tiered market. If the Commission has evidence to support the assertion that retail brokers are excluded from alternative trading venues, we think it should be presented and discussed." -- Seth Merrin, Chief Executive Officer; Anthony Barchetto, Head of Trading Strategy; Jay Biancamano, Global Head of Marketplace; VIad Khandros, Market Structure Analyst; Howard Meyerson, General Counsel; Liquidnet, Inc.

"Dark pools-Just the given name should be enough to know they are wrong and should be done away with. One guarantee for sure, is that they are a way for the ones who operate them to hide the ways they manipulate the prices of stocks to their benefit and the real persons detriment. Price manipulation of any kind should be reason for jail and or fines and complete banishment from future participation in the markets of any type by any and all in a company at all levels with no exceptions. We are constantly told how the markets use fair pricing and fair participation standards to create level and fair playing fields. When dark pools are allowed to exist, this fairness is not anywhere present. Besides the unethical and immoral practice these dark pools cause and promote in the markets, they also allow for the hidden gains the owners of them receive to avoid the taxes the visible participants are forced to pay. How is this fair at all, in any form or amount? It is not. Period. The dark pools and any incarnation of them the owners of them come up with in the future must be outlawed with punishments mentioned above or harsher. With statutes that allow for ease of prosecution of offenders. These dark pools and their likes have caused the largest bubbles and their eventual bursting in the markets that has always provided the benefits to the owners and the losses to the individual. Always. Where is the fairness in that?" -- Matt K.

"Don’t surrender to the pressure from the large players and do not fall for the argument of lost employment ! There will be much more people employed if this malpractice is finally forbidden !" -- Aston Susilovic, Capital Alternative Investment Management GmbH, Switzerland

"Investors expect full transparency, honesty, and disclosure before and after selecting investments. There is no reason they shouldn't have that." -- Christopher Krause, Madison, Wisconsin, Morgan Stanley Smith Barney, Financial Advisor

"Because the Commission has had a virtually unobstructed ability to impose a flawed transparency on the stock market for over three decades, in many respects what appears to be good is bad and what appears to be bad is good." -- Steve Wunsch, Wunsch Auction Associates, LLC, New York, New York

Investors Say The Darndest Things, Part II

I received so many emails from people thanking me for excerpting the comments on the SEC Flash Order ban proposal that I have decided to make it an ongoing project. In addition to providing food for thought, part of this exercise is to let you gauge the level of discourse that is shaping trading markets today and part of it is to, well, make you laugh.

The letters that clearly fall under the heading of, "You can't make this stuff up" make me wonder how much attention the SEC actually pays to them. That said, please understand that these are just the comments that struck me as interesting; there are many more that present balanced and well-reasoned viewpoints. In particular, I urge you to read the DirectEdge letter that makes the clearest case for flash functionality in the equity markets, and the CBOE letter that does the same for the options markets. For those of you who (like me) tend to doze off while reading SEC filings, the ISE letter is probably the most readable and entertaining.

Anyway, here are excerpts from the remainder of the letters to the SEC on the Flash Order ban proposal. I've also put links to the complete text of each letter on the SEC website following the quotes.

Stay tuned for comments from the Dark Pool proposal, they're sure to be interesting!

Bill

"Wall Street firms have become so large, rich and powerful that they have half of Congress (if not 3/4) in their pockets. And just about all of the U.S. Treasury...I, for one, would prefer to see them fail one after the other than be cheated on every trade I make...Thank you for looking and ENDING these awful and shameful practices. and don't stop there either. You need to defend the individual investor from these out-of-control monsters (I mean it)." -- Laurent Mayer, Individual Investor

"All trades should be required to trade and be reported upon no matter who, what or where the trade is arranged. This is the only way to provided market transparency. This include GS and "private" invester originization like KKK and Blackrock etc... I also like that "naked" options should also be prohibited." -- Bob G. Mall

"I can't believe you would allow false algo trading." -- Wallace Ungles

"The bottom line in this issue is not facts but emotion. Humans cannot tolerate the idea someone has more than they do. Or someone has an advantage over them. This is envy. This is jealousy. Making decisions based on these emotions always comes back to hurt and damage the one who is jealous or full of envy. Acting on these emotions is self-loathing resentment lust." -- Bob O., Plymouth, Minnesota

"Ban completely ... flash orders and high frequency trading." -- Kenton C. Blanton, Fremont, California

"To date, there are dozens of comments regarding the Proposal posted on the SEC website. They are almost all from individuals expressing anger at the industry over perceived unfairness in the markets. We recognize that the troubled economy has elevated fears and we appreciate the frustrations voiced by individual investors. However, we would like to set the record straight regarding flash trading. Unfortunately, flash trading has been mischaracterized as an unfair practice that benefits high frequency traders. This has confused investors and many industry professionals." -- William J. Brodsky, Chairman and CEO, Chicago Board Options Exchange, Inc., Chicago, Illinois

"BATS supports...the elimination of flash order types on rational policy grounds rather than on the exaggerated and often irrational concerns voiced widely in the media over the last several months. BATS briefly offered a version of the “flash” order (referred to as “BOLT”) earlier this year. When we implemented BOLT, we publicly stated that we did so for competitive reasons, but that we were concerned about the market structure implications of allowing equities and options exchanges as well as alternative trading systems to continue to offer such order types." -- Eric Swanson, BATS Exchange, Inc., Lenexa, Kansas

"...the Proposal would inflict unintended and substantial damage to the price transparency, liquidity, and execution quality currently enjoyed by retail customers." -- John C. Nagel, Managing Director and Deputy General Counsel, Head of Global Compliance, Citadel Investment Group, L.L.C.

"While a ban may appear to be a convenient response to populist sentiment, Direct Edge respectfully requests that the Commission carefully consider why and how such technology is used, how it can help investors achieve their objectives of accessing market-wide liquidity through a single market center, and whether any credible evidence of its impact on overall market integrity dictates an abolition of the practice as the only alternative. To date, the positive aspects of flash technology have been understated, the concerns have been generally overstated and under-supported, and less restrictive and comprehensive solutions to address such concerns have been ignored." -- Eric Hess, General Counsel, Direct Edge Holdings, LLC

"The business lobby group Businesses Aligned to Prevent Price Improvement, or BAPPI, today announced a drive to enact the Consumer Relief Initiative for Pride and Protection Legislative Engagement Act of 2010, or "CRIPPLE." CRIPPLE would prevent any business in the United States from asking its sales force to match a better price of a competitor. Explains BAPPI leader Rod Kanehl, "Why bother asking anyone to improve their prices? The government should require people to advertise their best prices. And if they don't have the best price, they must reject a customer's order. Better yet, the government should require a business to send the customer to a competitor who has a better price." -- Michael J. Simon, Secretary, International Securities Exchange, LLC, New York, New York

"Verbal representation...attracts significant institutional liquidity to the market, enhances price discovery, provides market information available to all participants through the floor brokers of member firms, and...provides one of the few real alternatives to automated markets for public investors today...it serves our markets well, and should not be circumscribed as part of the Commission's appropriate efforts to ban modern-day flash orders." -- Richard S. Rosenblatt, CEO, Rosenblatt Securities Inc.

"First, let me say that this practice is insidious...This practice ensures that even if I can make wise, well grounded choices, the brokerages are always going to one-up me on the buy price, and sell just before I do...Every service agreement I have ever signed (I'm assuming) whether with a full service brokerage such as Merrill-Lynch or a deep discount brokerage such as TradeKing GIVES THE BROKERAGE MY CONSENT AND BLESSING TO ALLOW THEM TO FRONT-RUN MY ORDERS WITH FLASH TRADING." -- Ryan Fisher, New York, New York

"While I have nothing against the maker/taker exchanges or the high frequency traders who are proposing that flash orders be banned these options exchanges and traders should expect OptionsHouse to do everything in its power to execute OptionsHouse customer orders away from them. OptionsHouse is doing what brokers are supposed to do with payment for order flow and zero exchange fees in that it is passing on its cost savings directly through to its customers by offering low commissions. Flash orders enable OptionsHouse to continue to keep its commissions low thereby providing an ongoing cost savings to its customers." -- George Ruhana, CEO, OptionsHouse, LLC

Let the Games Begin

As I write this note it has been over two weeks since the SEC met on October 21 to approve some measures relating to dark pools. Interestingly, the Commission has not yet published these proposals in the Federal Register nor on their website so other than some meeting debate and press release information we still don't know exactly what they contain. This seems like an inordinate amount of time to leave people to speculate about the impact of these important proposals and I wonder if there isn't a bit of intrigue going on behind the scenes in Washington. Of course, that hasn't stopped industry participants from talking about potential ways around the dark pool proposals should they become rules.

The most onerous proposal seems to be the one lowering the display requirement from 5% to 0.25% of average daily volume. This would mean that most dark pools that transmit IOIs would have to show a quote which would effectively eliminate their "darkness." But maybe not.

The whole issue of the SEC trying to eliminate actionable IOIs is somewhat confusing. These messages tend to create greater liquidity for orders by knitting together undisplayed interest in different market centers. Why would the regulators want to stop that? As an investor, shouldn't I have the right to show my order to whoever I choose? Do I really want regulators telling me under what conditions I can access markets in the name of supposed fairness?

Investors Say The Darndest Things!

The SEC recently discussed a ban on flash trading and published a proposed rule addressing their concerns. As is usual, they allowed people to submit letters and comments about the practice and the proposed rules. (You still have a couple of weeks left if you want to submit your own letter.)

Many of the submissions are from people who clearly do not understand flash trading and some are from those with obvious self-interests, but nearly all reflect a deep distrust of either Wall Street, the SEC or Goldman Sachs. Also, there is a recurrent theme about naked shorting, which of course has no relationship to flash trading. Even Bernie Madoff has been thrown in for good measure.

Here are some of my favorite quotes excerpted from the letters; the full text of each is available at the SEC website.

_________________________________________________

"After revelations over the past year of how corrupt and unfair the capital markets have become, the SEC should have shut down all the stock markets."

"How long are we going to be manipulated by mathematical formulas until we realize that the capital markets have collapsed because there are no longer any "suckers" on the other side?"

"As long as the SEC is a partner with this criminal element the SEC and the Obama administration will go down in history as no better than Bernie Madoff. PS the only reason Goldman Sachs pays these high bonuses is because their chosen few are willing perpetrators and keep their mouths shut. Its like the Cosa Nostra. After your a 'made' assassin your character must be silent about the real facts."

"any profits made on transactions that take 24 hours or less to complete should be taxed at nearly 100%. under 1 hour would be taxed at a maximum rate of 100%."

"As a general rule, I do not want anything a wall street firm says benefits me."

"I see nothing wrong with limiting trading to a maximum of once a day just as I can change my portfolio inside a 401K. I see everything wrong with an etf trading as much as every 15 seconds."

"Stocks that look good when I can buy them re:20 minute delay in what I see verses the microsec. that people with flash order access have.By the time I buy,they have gone down and I instantly loose money"

"I have read that Goldman Sachs acknowledges they will make $8 billion from their trading software this year, and it is incredible to me that they know in advance how much their HFT software will skim from the markets."

"This can't happen. Institutional investors are taking advantage of small investors. Have you people learned nothing?"

"Having said that, I believe this move to ban Flash trading is like fixing kitchen cabinet first, when there is a whole in roof of the house. There are much more dangerous issues in practice that call for SEC's immediate attention, like naked short sale."

"Please return the exchanges to their normal practice of serving as exchanges for individual investors and not ATMs for the big firms."

"S.E.C., It is nice you are doing something but Flash Orders only really effect The Big Traders us little people are being killed by naked short selling."

"I believe the ban on flash order would enhance the equility [sic] of US stock markets."

"You people at the SEC have a ton to answer for... No less than allowing the endangerment our very existence as a Republic."

"According to a recent article in Securities Industry News, Goldman, Morgan, and a handful of other firms are actually using the NYSE real estate for a fee to place their machines closest to the exchange. These are not advantages available a small broker dealer and/or a small investor."

"Just ask the hedge funds what they think and do the opposite. Stop asking the public and doing the opposite."

"I for one have lost much of my faith in our trading system - Since America only represents about 22% of the world's collective GDP, 78% of my new investments have been going overseas."

"Someone needs to be on top of this. As in Monday."

"There needs to be a randomized lag inserted into the ordering process in order to truly level the playing field this would also dampen some of the speculation driven volatility in the marketplace, as well as discouraging some churn....A randomized delay of even up to a minute is not going to negatively impact the overall flow of the markets."

"Disclaimers: I am not now, nor have I ever been an employee of a brokerage firm."

"I don't know what is SEC motto/principal anymore."