SIFMA provides comments to the Securities and Exchange Commission (SEC) on the New York Stock Exchange, LLC’s (NYSE’s) notice of filing of proposed rule change to establish an institutional liquidity program on a one-year pilot basis, File No. SR–NYSE–2013–72.

Under the proposal, as a one-year pilot program, the NYSE would add new NYSE Rule 107D to establish an Institutional Liquidity Program (ILP) attract buying and selling interest in greater size to the Exchange for NYSE-listed securities by facilitating interactions between institutional customers (and others with block trading interest) and providers of liquidity exceeding minimum size requirements.

SIFMA supports competition in the securities industry, and we encourage all market participants, including the NYSE, to develop and provide innovative products to investors. In the context of NYSE’s proposal, SIFMA supports the concept of size discovery and the ability to provide investors with additional liquidity options. However, as described in more detail below, SIFMA believes that the ILP raises broader policy issues that the SEC should consider and resolve in its review of the proposal.