FIA PTG submitted a comment letter to the Securities and Exchange Commission (SEC) in response to the Chicago Stock Exchange, Inc. (CHX)  proposal to introduce a Liquidity Enhancing Access Delay (“LEAD”).

LEAD replaced the Liquidity Taking Access Delay (LTAD), which FIA PTG opposed in two separate comment letters (available here and here).

FIA PTG noted that LEAD “not only fails to address our major concerns with the LTAD, but also even more unfairly discriminates by providing a speed advantage to a small number of favored market participants.”

CHX LEAD represents the fourth iteration of a latency-introducing proposal in equity markets, all of which have required multiple rounds of responses from market participants.  FIA PTG emphasized the need for a moratorium on new types of artificial delays until the SEC is able to complete a comprehensive review of Reg NMS.  “Indeed, consider if the time and effort spent developing, evaluating, and responding to these proposals were instead devoted to developing, evaluating, and responding to proposals for comprehensive market structure reform. We might see real progress in addressing the fundamental complexity in market structure. We strongly support action by the Commission to address the fundamental complexity in market structure instead of taking a piecemeal approach to individual exchange proposals.”

The full letter is available here.