SIFMA provides comments to the Securities and Exchange Commission (SEC) supporting the extension of the NYSE Arca Penny Pilot Program (Pilot Program) until December 31, 2013. The extension of the Pilot Program prevents the investor confusion that would ensue if the Pilot were to expire prior to the permanent program being approved. In addition, the extension will allow NYSE Arca and the SEC additional time to analyze the impact of the Pilot Program.

SIFMA believes that NYSE Arca and other options exchanges should submit proposed rule changes to make the Pilot into a permanent Penny Trading Program.  Consistency will reduce confusion and allow all investors to seamlessly determine which options classes are traded in pennies.