IEX offers a simplified and transparent market designed to eliminate conflicts currently present in the equity markets.
IEX's request to register as an exchange comes before the Commission at an important inflection point in the evolution of the U.S. equity markets – important for the industry, for corporate issuers, and above all for the investing public. We do not propose to operate as a “cookie cutter” replica of the dominant exchange business model. We believe that model poses conflicts of interest with what we view as an exchange's public responsibility.
As a new entrant in any industry that challenges established practices, it is by no means surprising that those with deeply rooted interests in maintaining these practices would seek to mischaracterize, malign, or denigrate the very differences that distinguish the challenger, and to block, limit, or delay its ability to compete. That story, of course, is much older than the market structure debates of recent years.
Ultimately, the question is not whether our view, or the view of incumbent exchanges, about certain market practices is correct or not, but instead whether IEX will be given a chance to prove itself on an equal footing with the existing exchanges. We believe that there is room in the national market system for an exchange to chart a different course, to favor investor protection over speed, and to allow the markets, the investing public, and corporate issuers themselves to render a verdict.
–IEX letter in response to material comments raised, November 23, 2015
IEX's Second Comment Letter on NYSE Connectivity Fee Filing
Read IEX's second letter to the SEC opposing NYSE's practices in charging for access and market data.
IEX Comment Letter On Nasdaq Connectivity Fee Proposal
Read IEX's letter to the SEC opposing Nasdaq's proposal to charge participants a new fee to receive UTP data.
IEX Comment Letter On NYSE Connectivity Fee Filing
Read IEX's letter to the SEC opposing NYSE's practices in charging for access and market data.
IEX's third response letter
Read IEX's third letter in response to material comments raised by market participants on IEX's Form 1 application. (February 9, 2016)
IEX's second response letter
Read IEX's second letter in response to material comments raised by market participants on IEX's Form 1 application. (November 23, 2015)
IEX's first response letter
Read IEX's first letter in response to material comments raised by market participants on IEX's Form 1 application. (November 13, 2015)
IEX Comment Letter On LULD Plan
Read IEX's comments to the SEC's proposal to extend the LULD pilot period.
IEX Comment Letter On NYSE Proprietary Feed Proposal
Read IEX's letter to the SEC regarding information asymmetry between NYSE Trades product and CTA Plan.
IEX Comment Letter On NMS Plan Governance
Read IEX's letter to the SEC offering suggestions for consideration by the Commission, the plan participants, and the industry as ways to enhance the operation of the SIPs and contribute to the improvement of governance of NMS Plans in general, and the SIPs in particular.
IEX BATS PBBO Comment Letter
Read the IEX BATS PBBO Comment Letter.