Dear Ms. Countryman:

My name is Nicholas Anthony and I am the Manager of the Cato Institute’s Center for Monetary and Financial Alternatives. I appreciate the opportunity to provide input to assist the Securities and Exchange Commission (SEC) in its amendments regarding Regulation ATS. The Cato Institute is a public policy research organization dedicated to the principles of individual liberty, limited government, free markets, and peace, and the Center for Monetary and Financial Alternatives focuses on identifying, studying, and promoting alternatives to centralized, bureaucratic, and discretionary monetary and financial regulatory systems. The opinions I express here are my own.

There are many items to address in this proposal, but I will focus my comments on the specific challenges people are facing in regard to the proposed amendments and other recent SEC proposals.

The Issue in Addressing Regulation ATS
In a dissenting statement, SEC Commissioner Hester Peirce wrote,

The [proposed rule] weighs in at a hefty 650 pages, contains over 220 separate comment requests (with many requests containing multiple questions), and addresses about a dozen significant issues, several of which affect trading venues of all types (including currently unregulated communication protocol systems)… Notwithstanding the literal and figurative bulk of this release, the Commission has determined that it is appropriate to provide the public with 30 days to read, understand, consider, consult, identify, model, assess, and discuss these rules… I cannot comprehend why we insist on blindfolding ourselves, rather than embracing the notice-and-comment process that has been so valuable in unearthing issues for our consideration.