SIA Submits Comments to the SEC on a NASD Proposed Integrated Order Delivery System

The Trading Committee of the Securities Industry Association (SIA)* provides comments to the Securities and Exchange Commission (SEC) on the National Association of Securities Dealers, Inc.’s (NASD’s) proposed Integrated Order Delivery and Execution System (the System), Securities Exchange Act Release No. 34-39718; File No. NASD-98-17. The proposed system would provide an automated execution facility that will consolidate NASDAQ’s two principal trading systems, the Small Order Execution System (SOES) and SelectNet, coupled with a NASDAQ-sponsored voluntary limit order book thatwould allow NASD members and sponsored participants to enter and display anonymous limit orders without the need for those limit orders to be represented in a market maker’s quotation. SIA shares the ultimate goal of the proposal, but believes that in its current form the proposed limit order facility, has anti-competitive elements that could operate to to the detriment of public investors.
*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.