AMC Entertainment Holdings Inc (AMC)

[Beek]

WOW! What a read from the SEC. They are asking some of the right questions at least... Now when are they going to (finally) act on it?
IMO/NFA

https://www.sec.gov/comments/s7-23-15/s72315-25.pdf

Some Quotes:
"The below issues raise questions regarding the value and relevance of ATSs to investors and the markets and whether they should still continue operations."

"The broker-dealers that may eliminate the need for public exchanges are clearly the benefactors from this structure, not the investing public. Is this healthy for the U.S. market system? At what point do ATSs/dark pools become such a percent of the market that some exchanges are no longer viable?"

"The above alleged Barclays and Credit Suisse falsely advertised the benefits of dark pools for pension and mutual funds trading large blocks of shares. The result of such behavior is in direct opposition to the reasons for the very existence of ATSs."

"If dark pool operators route client trades to a cooperating third party and then become the other side to those trades, then dark pools would be acting for their benefit as opposed to protecting their institutional client and providing a fair and efficient market. Moreover, this hypothetical scenario would constitute illegal pre-arranged trading in violation of a number of securities laws. "

Conclusion
"The real question/concerns here may not be that of disclosure, but really what is the value to the marketplace of having these dark trading venues, which have morphed into something completely different than 'originally designed' and are not benefiting the large traders as intended.
If there is no value or benefit to the marketplace, where is the compelling justification to keep dark pools operating? If dark pools might cause risk to the markets, the reasons to disallow them become much stronger."