Concept Release on Equity Market Structure

SIFMA provides comments to the Securities and Exchange Commission (SEC) regarding the Commission’s release on equity market structure, Release No. 34-61358; File No. S7-02-10. SIFMA believes that the market structure changes discussed in the Concept Release cannot be universally characterized as favorable or unfavorable market developments. They are more complex in that they represent advancements for investors and the markets in some sense, yet they may also present issues in terms of certain national market system goals. SIFMA suggests to: (1) conform a consolidated audit trail and large trader reporting; (2) increase the harmonization of disparate regulation and compliance oversight; (3) make greater efforts to ensure that regulatory proposals are sufficiently grounded in supporting empirical data; and (4) argues that consolidated market data currently available should be significantly enhanced both in terms of the speed at which data is updated and transmitted, and in terms of the amount of data currently available.