*Letters

Retail Orders, Retail Liquidity Programs, & Retail Member Organizations

Published on:
March 11, 2013
Issues:
Committee:

SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposals to allow participants to attest that “substantially all” orders submitted to the Retail Liquidity Program (RLP) will qualify as “Retail Orders,”  SR-NYSE-2013-08; SR-NYSEMKT-2013-07; SR-BYX-2013-008; and SR-NASDAQ-2013-031. The Programs each create a new class of market participants: Retail Member Organizations (RMOs). In order to qualify as an RMO, a participant is required to submit an attestation to the Exchange that “any” order flow submitted would qualify as a “Retail Order.” These Programs were approved on a pilot basis by the Commission staff acting pursuant to delegated authority.

SIFMA believes that the proposed amendments weakening the standard to allow some non-retail orders represents a material and problematic departure from the Programs originally considered by the Commission.

SIFMA is concerned that the “substantially all” standard proposed by the Exchanges is so vague that it could allow a material amount of non-retail order flow to qualify for the Programs.

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.