SRO Proposals Relating to Market Wide Circuit Breakers

SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposals by the Financial Industry Regulatory Authority (FINRA), the New York Stock Exchange (NYSE), the Nasdaq Stock Market (Nasdaq) and other self-regulatory organizations (SROs) to modify their rules relating to the methodology for determining when to halt trading in all stocks due to extraordinary market volatility.

SIFMA supports the adjustment of the current market-wide circuit breakers and commends the SROs for their efforts to modernize the circuit breakers.  Combined with prior SRO initiatives to address extraordinary market volatility – stock-by-stock trading pauses, the adoption of clearly erroneous trading rules, and more stringent market maker requirements – and the anticipated adoption of the SROs’ Limit-Up/Limit-Down rule proposal – the proposed rules will help address extraordinary market volatility.  SIFMA supports the proposed rules as a general matter, and suggest a few modifications to enhance their effectiveness.