Category: Comment Letters
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STA Comment Letter on the Modernization of Derivatives Tax Act 2021
STA urges the Senate to consider the negative impact of the Modernization of Derivatives Act (MODA 2021). The legislation would require mark-to-market tax treatment for derivatives contracts and require gains […] Read More
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STA Comment Letter on CAT Funding Proposal
STA does not support the Proposed Funding Model and we recommend the Commission deny the Filing and instruct the Operating Committee for CAT to address issues involving collaboration with Industry […] Read More
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STA Comment Letter on May 6 GameStop Hearing
STA appreciates the Committee’s actions of holding three public virtual hearings on the market events in late January 2021 involving GameStop and other meme stocks. Public hearings serve an invaluable […] Read More
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STA Comment Letter on Financial Transaction Tax
STA opposes FTTs because they are paid by the end investor and result in higher trading costs due to wider spreads, decreased liquidity, increased price volatility, or lower performance on […] Read More
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STA Comment Letter on GameStop Congressional Hearing
The U.S. markets are in a constant state of evolution driven by innovation and at times, new entrants. Throughout the history of U.S. markets, there have been moments when inefficiencies […] Read More
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STA Comment Letter on Nasdaq BX Proposal to Limit Short-Term Options Strikes
STA believes the Strike Interval Proposal introduces an efficient strike listing standard that balances the interests of option market makers, liquidity providers and investors and, if replicated by other option […] Read More
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STA Files Comment Letter on Form 13F
“STA acknowledges that the current reporting threshold presents burdens on certain small investment managers, but given the importance of the information from Form 13F we recommend that the Commission exercise extreme caution […] Read More
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STA Comment Letter on 15c2 -11
We commend the Commission for proposing amendments to modernize Rule 15c2-11. As the Commission notes in the Proposal, the OTC securities market has undergone significant changes since Rule 15c2-11 was […] Read More
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Comment Letter: Cboe Asymmetric Delay
It has long been STA’s view that liquidity providers contribute to the overall quality of markets to the benefit of investors. While we have advocated for regulators to find modern […] Read More
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Comment Letter: FIF and STA Comments on Amended SEC Rule 606
While much progress has been made with respect to the industry’s implied understanding of the scope and breadth of data that the SEC Staff expects to be reported pursuant to […] Read More