*Letters

Professional Account Holders Proposal

Published on:
July 28, 2008
Committee:

The Equity Options Trading Committee of SIFMA provides comments to the Securities and Exchange Commission (SEC) on the International Securities Exchange’s (ISE) proposal regarding th definition and regulation of professional account holders, SR-ISE-2006-26; SEC Release No. 34-57254.  While SIFMA applauds the intentions of the proposal, it has concerns about the methodology. SIFMA believes that Electronic Access Members (EAMs) would not be able to meet monitoring and routing obligations, allowing professional customers to “game” the system. SIFMA also notes that extra consideration must be given to; order breakdown, limited visibility, clearing firms versus executing firms, cancellations/replaces/modifications/correction orders, and information barriers between entities.

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