Proposed Elimination of Flash Order Exception

SIFMA’s Equity Options Trading Committee provides comments to the Securities and Exchange Commission (SEC) regarding the proposal to eliminate the flash order exception provided in Rule 602(a)(1)(i)(A) of Regulation NMS. The committee believes that flash orders are beneficial to options investors, especially retail options investor, and argues that a broad ban on flash orders would not only deprive investors who use them of those benefits, but also believe that such a ban could have significant adverse consequences for the options markets generally by decreasing competition and liquidity and increasing volatility.