Proposed Rule Change to Implement a Liquidity Taking Access Delay

SIFMA provided comments to the SEC on a proposed rule change filed by the Chicago Stock Exchange (CHX) to implement a Liquidity Taking Access Delay. In particular, the LTAD proposal highlights that structural changes at individual exchanges can raise significant market structure questions and result in increased market complexity. SIFMA believes that after considering all the factors and potential implications associated with CHX’s particular proposed delay – including existing geographic latency, underlying intent of the exchange, and selective application of the delay to certain order types –the Commission should not approve the proposal.

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Proposed Filing