Equity Market Structure
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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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FIA PTG responds for the third time to FINRA proposal to add IntelligentCross ATS to the Alternative Display Facility
In a letter filed with the US Securities and Exchange Commission (SEC), the FIA Principal Traders Group (FIA PTG) again opposed a proposal to add IntelligentCross ATS as a new entrant to FINRA’s Alternative Display Facility.
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FIA PTG urges SEC to reject proposed CAT funding model
In a letter filed with the US Securities and Exchange Commission (SEC) in response to the Amendment to the National Market System Plan Governing the Consolidated Audit Trail (CAT), the FIA Principal Traders Group (FIA PTG) urged the SEC to reject the latest proposed Funding Model. FIA PTG said the CAT requires a fundamental change to its governance and transparency model.
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FIA PTG Responds to Regulation Systems Compliance and Integrity Expansion Proposal
In a letter filed today with the US Securities and Exchange Commission in response to the Regulation Systems Compliance and Integrity Expansion Proposal (Reg SCI), the FIA Principal Traders Group (FIA PTG) said that the SEC has not justified expanding Reg SCI to broker-dealers nor has it adequately considered alternatives and the impact on competition.
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FIA PTG Responds to SEC Cybersecurity Risk Management Proposal
In a letter filed today with the Securities and Exchange Commission (SEC) in response to the Risk Management Proposal, the FIA Principal Traders Group (FIA PTG) recommended that the SEC prioritize critical operations as focus of rule scope and requirements; take into account firm attributes, market structure and service provider due diligence mechanisms as part of reasonably designed policies and procedures; leverage the Financial Services Information Sharing and Analysis Center (FS-ISAC) for incident reporting and threat analysis; eliminate public disclosure requirements and associated risk in favor of Reg S-P customer notifications; and address implementation and enforcement concerns in the adopting release.
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FIA PTG Responds to TSX Alpha Exchange Proposed Amendments to add Additional Order Books
In a letter filed with TMX Group, the FIA Principal Traders Group (FIA PTG) commented on Alpha Exchange’s recently proposed amendments to their Alpha Trading Policy Manual to introduce two new order books and to make changes to their order processing delay.
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