February 6, 2020 Ms. Vanessa Countryman Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: Proposed Rule Change to Add a New Discretionary Limit Order Type – File No. SR-IEX-2019-15 Dear Ms. Countryman, Themis Trading appreciates the opportunity to comment in support of the proposal submitted by the Investors Exchange LLC (“IEX”) to introduce a new Discretionary Limit order type (“D-Limit”). For your background, Themis Trading is an institutional agency brokerage, providing investment managers of all sizes with the best possible execution on their equity trade orders. We represent long-term investors who form the backbone of (more…)

We have written several notes to you over the last 30 months about the CBOE Market Close, including notes dated October 18th 2017, January 22nd 2018, and January 26th 2018. CBOE’s plans to disrupt NYSE’s and Nasdaq’s monopoly over their closing auctions have traveled a long road indeed. Closing auctions are one of the few areas where the NYSE and Nasdaq are still insulated from competition. At the close, stock trading – done on dozens of exchanges and dark pools throughout the regular trading day – reverts back to the primary exchange for the closing auction. Back in May 2017 CBOE (more…)


Jun, 2019