Exemptive Relief for Print Protection Transactions

SIFMA provides comments to the Securities and Exchange Commission (SEC) requesting the SEC exempt print protection transactions from Rule 611(a) (the Order Protection Rule) of Regulation NMS under the Securities Exchange Act of 1934. SIFMA believes that the proposed exemption, like the various exceptions to the Order Protection Rule adopted by the SEC, is “narrowly drawn to prevent abuse,” but would allow broker-dealers to continue to provide beneficial executions to orders that do not receive executions because they are not at the top-of-book (“TOB”) in the market in which they are displayed, but are priced superior to orders executed in other markets. As a result, the proposed exemption is “appropriate in the public interest, is consistent with the protection of investors,” and should be granted by the SEC.