Letters

Regulation of Non-Public Trading Interest

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) regarding the SEC’s proposed rule changes regarding non-public trading interest in national market system stocks, including non-public trading interest in alternative trading systems commonly known as “dark pools,” Release No. 34-60997; File No. S7-27-09. SIFMA supports increased transparency of alternative trading systems (ATSs), but does not believe it is necessary to have real-time disclosure of the identity of ATSs on trade reports to achieve this goal. Instead, the Commission can enhance transparency of ATS activity through delayed reporting of the identity of ATSs executing trades without inadvertently hindering the ability of market participants using ATSs to execute trades with minimal market impact.

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