Following a trend begun by an earlier new exchange, IEX – also designed to compete with the Big Three (NYSE, NASDAQ, CBOE) – the shares of the new exchange, MEMX, are not for sale. The new exchange will be controlled by its incumbent owners. In my first MEMX article, I pointed to the absence of any contribution to the overall financial market structure in the MEMX business plan. Reducing fees, as MEMX plans, can at best have only one beneficial effect, a reduction in overall broker-dealer costs perhaps passed through to trading customers as well. But MEMX was not content with a simple reduction in exchange fees.

Had MEMX left its contribution to reduced fees only, the arrival of MEMX would have been boring, but useful. But MEMX went much further. They are going to put their ability to stay in business without making money to use by changing the

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