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Equity Market Structure

  • FIA PTG urges the SEC to ensure Nasdaq equalizes all co-location data center latencies

    In a letter filed with the Securities and Exchange Commission (SEC), the FIA Principal Traders Group (FIA PTG) urged the SEC to take the following actions to ensure equalization of the entire Nasdaq collocation campus (NY11 and NY11-4) is completed expeditiously.

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  • FIA PTG Comments Again on Application of 24X National Exchange LLC for Registration as an Exchange

    In a letter filed with the Securities and Exchange Commission (SEC), the FIA Principal Traders Group (FIA PTG) commented again on the application of 24X National Exchange LLC for registration as a national securities exchange.

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  • FIA PTG Comments on OCC Margin Add-On Proposal

    In a letter filed with the Securities and Exchange Commission (SEC), the FIA Principal Traders Group (FIA PTG) responded to the Option Clearing Corporation (OCC) Proposal to establish a margin add-on charge to help mitigate the risks of zero-days-to-expiration (0TED) options.

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  • FIA PTG Comments on Application of 24X National Exchange LLC for Registration as an Exchange

    In a letter filed with the Securities and Exchange Commission (SEC) today, the FIA Principal Traders Group (FIA PTG) responded to the SEC’s institution of proceedings in connection with 24X National Exchange’s (24X) application for registration as a national securities exchange.

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  • FIA PTG responds to Nasdaq Cabinet Proximity Option Program Proposals

    In a letter filed with the Securities and Exchange Commission (SEC), the FIA Principal Traders Group (FIA PTG) urged the SEC to disapprove Nasdaq’s proposed rule changes to Expand the Cabinet Proximity Option Program and to Establish a Reservation Fee. FIA PTG raised three principal concerns with respect to the Proposed Rule Changes all in connection with Nasdaq’s existing data center facilities in Carteret, NJ (NY11) and Nasdaq’s new facility under construction just to the north of NY11 (NY11-4).

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  • FIA PTG responds to SRO CAT Fee Filings

    In a letter filed with the Securities and Exchange Commission (SEC) today, the FIA Principal Traders Group (FIA PTG) urged the SEC to disapprove the self-regulatory organizations’ (“SRO”) proposed rule changes to Establish Fees for Industry Members Related to Certain Historical Costs of the National Market System Plan Governing the Consolidated Audit Trail (the “CAT Fee Filings”) incurred by the SROs prior to January 1, 2022.

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  • FIA PTG Responds to SEC Volume-Based Exchange Transaction Pricing Proposal

    In a letter filed with the Securities and Exchange Commission (SEC) today, the FIA Principal Traders Group (FIA PTG) opposed the SEC's Volume-Based Exchange Transaction Pricing Proposal and urged the SEC not to move forward with finalizing it. FIA PTG said that exchange volume-based pricing tiers are just one small piece of the much larger transaction pricing picture, and that tweaking one piece of the pricing puzzle is unlikely to generate the results the Commission is looking for.

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  • FIA PTG responds again to SEC Dealer Definition Proposal

    In a letter filed with the Securities and Exchange Commission, the FIA Principal Traders Group (FIA PTG) offered additional comments on the SEC's Definition of a Dealer proposal. FIA PTG said that while it appreciates the importance of the proposal's stated goals to prevent market disruptions and support market transparency, integrity, resiliency, and investor protection, it fails to see how this proposal addresses any of those issues in a meaningful way.

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  • FIA PTG makes the case for Congressional oversight over CAT funding

    FIA Principal Traders Group (FIA PTG) has published an essay calling for Congressional oversight over Consolidated Audit Trail (CAT) funding. FIA PTG cites dramatically spiraling costs – both historical and ongoing, persistent budget overruns, and a model that lacks incentives to manage costs, as the rationale for this appeal.

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  • FIA PTG responds to Nasdaq PHLX proposal to add additional order types

    In a letter filed with the US Securities and Exchange Commission, the FIA Principal Traders Group (FIA PTG) opposed Nasdaq PHLX’s proposal to establish new “Contra Midpoint Only” and “Contra Midpoint Only with Post-Only” order types. 

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