*Letters

Securities Exchange Act

Published on:
January 28, 2010
Issue:
Committee:

SIFMA provides comments to the Securities and Exchange Commission (SEC) regarding the Financial Industry Regulatory Authority’s (FINRA’s) proposed rule that consolidate National Association of Securities Dealers (NASD) Rule 2111 governing market order protection and NASD IM-2110-2 governing limit order protection,  Release No. 61168; File No. SR-FINRA-2009-090. SIFMA is generally supportive of FINRA’s Proposed Rule 5320 and believes that it is an important step forward in FINRA’s efforts to harmonize its rules with the NYSE rules. SIFMA believes that certain modifications should be made regarding: 1) the expansion of the “no-knowledge” interpretation for market making desks to apply to over-the-counter equity securities; 2) the requirement to obtain and use a unique market participant identifier (MPID); 3) the expansion of the hours of effectiveness of the Proposed Rule; and 4) the application of the Proposed Rule to customer orders that are not “market” or “limit” orders.

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