Dear Editor,

We appreciate your supportive comments on our proposal to use trade execution data to help investors solve the issue of best execution (OPINION: How to Measure Best Execution? June 1, 2015). Simple data standards can change the industry and be cost efficient. However, we disagree with your conclusion that exchanges will resist this effective solution because they make a significant fraction of their revenue from selling market data. We are proposing the publication of historical trade data, not real time data. Exchanges do not make significant money on historical data. We are confident that our proposal will neither significantly impact the lit exchanges’ market data business lines nor elicit their resistance.

As you note, there is an opportunity for more effective regulation to emerge through voluntary publication of trade data by exchanges. Regulators aim to achieve fairer and more efficient markets but often times the rules they create are so complicated that they reduce competition. Simpler regulation can be more effective and more transformative than the intricate rules being crafted today. We believe that the goals and interests of regulators, investors and exchanges are aligned with our simple and effective proposal.

Sincerely,

Stéphane Tyc