Dark Pools Being Used to Step in Front of the NBBO. Presented by: Dennis Dick, CFA Trader Member of Bright Trading LLC Email: 4CJG@brighttrading.net Phone: Will provide through email correspondence. Proposal to Review SEC Rule 612: The Sub Penny Rule SEC rule 612 was implemented to protect the integrity of the NBBO (National Best Bid and Offer). It has come to our attention that the rule needs to be reexamined and opened up once more for public comment. It is our belief that Broker-Dealers and Algorithmic programs (also known as High Frequency Traders) are circumventing the current rule by stepping ahead of the NBBO through the use of dark pools and in-house trading. http://www.defendtrading.com/SubpennyinginDarkPoolsCompromisingNBBO.pdf Must read.