In support of the CVM's proposal, Direct Edge offers evidence, information and studies the CVM may wish to consider in evaluating appropriate conceptual approaches.

Direct Edge's views reflect its direct experience, desire to operate as a new exchange competitor, recognition of the unique features of the Brazilian capital markets and analysis of competitive market structure frameworks of several countries.

"Direct Edge greatly appreciates the opportunity to offer its thoughts to CVM regarding the consultation," said William O'Brien, Chief Executive Officer of Direct Edge. "We believe that Brazil already has one of the world's premier capital markets, and are excited by the prospect of adding additional value to brokers and investors as a new exchange entrant. While introducing competition requires certain regulatory transitions to ensure continued efficiency and investor protection, we believe that CVM is taking a thoughtful and deliberative approach and is focused on the relevant subject matter."

The CVM's request for consultation instructed respondents to specifically address the challenges of ensuring the integrity of best execution, market data distribution and self-regulation in a market with multiple exchange participants. Direct Edge believes these are the appropriate areas of focus in evaluating regulatory changes to ensure a smooth operational implementation, minimize costs on brokers and other market participants, and maintain proper oversight and protection for investors.