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without surveillance on a regulated exchange

So we're going to have competition in exchanges, a free market of them with various rules/surveillance levels? Neat!

Competition between exchanges based on rules (e.g. paying liquidity takers versus makers) and surveillance (e.g pits versus dark pools or tape delays) has existed for a long time (think: American Stock Exchange versus NYSE versus NASDAQ) [1]. It sped up after the SEC passed Reg ATS [2].

[1] https://en.m.wikipedia.org/wiki/Alternative_trading_system

[2] https://www.law.cornell.edu/cfr/text/17/242.301

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