Ray Tierney and Gary Stone (Bloomberg) have added a comment to the SEC’s January 2010 Equity Market Concept Release, that we recommend you read. It specifically makes several great points about the buy side’s need for more and better disclosure, regulatory fairness and equal standards for how the SEC treats Exchanges vs. ATS’s, and it provides some examples of better disclosure that Bloomberg feels the SEC and FINRA should mandate.
Incidentally, we made these same points at a Tabb Market Structure Panel just a few weeks back, and we wrote to you a note titled Flag Day and the Future of FINREG at the same time.
Good transparency means more than telling clients that “all they have to do is call us and we will be happy to discuss how our mechanisms work”, as so many dark pool operators maintain. Bloomberg’s public comment letter demonstrates that they understand the complexity and added best-execution burden that the buyside experiences today. The comment letter is great; we won’t summarize it, as it is concise to begin with.
Please give it a read: