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Clearpool’s Comment Letter on SEC Roundtable on Market Data and Market Access

The Clearpool Group (“Clearpool”) welcomes the opportunity to provide its views on the issues to be examined at the SEC Roundtable on Market Data and Market Access (“Roundtable”).

Launched in 2014 and based in New York, Clearpool Group is an independent agency broker-dealer and provider of tools to assist other broker-dealers in the areas of routing, execution, pre- and posttrade compliance and risk monitoring.1 We created Clearpool as we recognized the need for a solution to allow smaller broker-dealers, i.e., so called Tier 2 broker-dealers, to effectively compete for electronic trading flow, as well as the constraints and cost burdens placed on many of these brokers due to, among other things, market data and market access.

As a relatively new entrant in the markets, Clearpool can attest that costs relating to market data and market access were a significant consideration in our thinking on whether to start the firm, and a significant part of our upstart costs. In our first year, costs related to market data and market access represented approximately twenty-five percent (25%) of our non-human capital operating expense, a considerable amount for a new firm.

Read the full comment letter here.