SIFMA’s Equity Options Trading Committee provides comments to the Securities and Exchange Commission (SEC) on the Penny Pilot Program, File No. SR-NYSEArca-2009-44. SIFMA comments regarding the NYSE Arca, Inc’s Notice of Filing of Proposed Rule Change Amending Rule 6.72 Governing Trading Differentials and Proposing to Expand the Penny Pilot, the Chicago Board Options Exchange, Incorporated’s Notice of Filing of Proposed Rule Change Amending CBOE Rules Relating to the Penny Pilot Program and the International Securities Exchange LLC’s Notice of Filing of Proposed Rule Change Relating to the Penny Pilot Program.  SIFMA has expressed strong support for a Penny Pilot Program over the past several years, but also expressed their strongly held view that the benefits of penny quoting in narrowing quote spreads must be weighed against serious negative effects that penny quoting can have on the options markets in  other respects.