Policy Writing

Comment Letter on SEC Reg NMS Reforms Proposal

Re: Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (Release No. 34-96494; File No. S7-30-22), January 2024. [PDF]

Discussion of ‘Would Order-by-Order Auctions be Competitive?’ at the SEC, 10th Annual Conference on Financial Market Regulation, May 2023

SEC, 10th Annual Conference on Financial Market Regulation, May 2023.

Comment Letter on SEC Retail Investor Auctions Proposal

Re: Order Competition Rule Proposal (Release No. 34-96495; File No. S7-31-22), March 2023.
Discussion of ‘Would Order-by-Order Auctions be Competitive?’ at the SEC, 10th Annual Conference on Financial Market Regulation, May 2023
[PDF]

Bigger Is Better When It Comes to Vaccine Production

Coauthors: Christopher Snyder
Wall Street Journal, March 2021. [PDF]

Three Pillars of the Economic Policy Response to the Covid-19 Crisis

Coauthors: Anil Kashyap, Ralph Koijen, and Brent Neiman
Working Paper, March 2020. [PDF]

FCA Insight Brief Description of “Quantifying the High-Frequency Trading ‘Arms Race'”

Coauthors: Matteo Aquilina and Peter O'Neill
Insight, Big Bucks from Small Change, January 2020. [PDF]

FTC Keynote Talk, How to Fix the Market for Event Tickets

FTC "That's the Ticket" Workshop on Consumer Protection Issues into the Event Tickets Market, June 11 2019.
PowerPoint Slides with Speaking Notes
Slides as PDF
Slides as PDF with Speaking Notes

Response to ESMA’s Call for Evidence re Periodic Auctions

Response to ESMA’s Call for Evidence: “Periodic Auctions for Equity Instruments” (ESMA70-156-785), January 2019. [PDF]

Response to RFI on the Evolution of the U.S. Treasury Market Structure

Response to RFI on the Evolution of the U.S. Treasury Market Structure, Re: Notice Seeking Public Comment on the Evolution of the Treasury Market Structure (Docket No. TREAS-DO-2015-0013), April 2016. [PDF]

Comment Letter on Proposed Commission Interpretation of One Millisecond as De Minimis

Re: Proposed Commission Interpretation Regarding Automated Quotations Under Regulation NMS (Release No. 34-77407; File No. S7-03-16), April 2016. [PDF]

IEX Comment Letter

Re: Investors’ Exchange LLC Form 1 Application (Release No. 34-75925; File No. 10-222), February 2016. [PDF]

CFTC Comment Letter

Re: CFTC Concept Release — Risk Controls and System Safeguards for Automated Trading Environments, RIN 3038-AD52, February 2014. [PDF]