FIA PTG filed comments with the SEC today opposing the CHX Liquidity Enhancing Access Delay (LEAD). The comments reiterate the concerns raised in FIA PTG's October 2016 and January 2017 comments on the CHX Liquidity Taking Access Delay (LTAD, now withdrawn) and March 2017 comments on LEAD.
Namely, FIA PTG argued that the result of this asymmetric speed bump is unfair discrimination among market participants. Allowing some market participants to have a structural latency advantage over others frustrates the purposes of Rule 611 by impairing fair and efficient access to an exchange’s quotations. The unfair discrimination in CHX’s new LEAD proposal is even more egregious than it was in its previous LTAD proposal.
FIA PTG also reiterated its call for a moratorium on new types of artificial delays like this proposal until the SEC is able to complete a comprehensive review of Regulation NMS. Layering the additional complexity that accompanies these latency introducing mechanisms on our already byzantine equity market structure creates troubling complexity.