“The SEC is to be commended for tackling the complex and vitally important job of restructuring our capital markets for the 21st century,” said Ira Hammerman, SIA senior vice president and general counsel. “SEC Chairman William Donaldson and the commission have demonstrated outstanding leadership on this issue. The fact that the commission has taken the time and effort to revise its original proposal, and resubmit it for public comment, shows that the SEC not only wants to get the job done, it wants to get it done right.”
In its comment letter on the initial proposal, SIA stressed that intermarket price protection of all firm and accessible quotes was essential to effective reform. SIA also recommended: establishing efficient linkages among markets to improve access to quotes and orders, and to achieve intermarket price protection; adopting the SEC’s proposed rule to minimize locked and crossed markets (subject to certain exceptions); addressing access-fee regulation; implementing cost-based market-data fees and transparency in fee-setting and governance structures; and, adopting the proposed ban on sub-penny quoting.
Hammerman said that SIA would review the revised Regulation NMS proposal and consult with its member-firms in preparing a formal comment letter.