HENRI LALANNE Comment On Regulatory Notice 20-29
I think pennying is really a bad behaviour, that is similar to "front-runnning". I think it is important to find a protocol that reduces that behaviour... I don't have the solution, but may be in case a dealer wants to show his own bid , he has to give the 1st bidder (may be also the 2nd best) another look. Thank you for bringing the subject. Kind regards.