Category: Comment Letters

STA Comment Letter on SRO; NYSE Arca; Notice of Filing to List and Trade Shares of Grayscale Bitcoin Trust (BTC)

The Security Traders Association (“STA”) appreciates the opportunity to providecomments in response to the above-referenced notice (“Notice”) of Form 19b-4 underthe Securities Exchange Act of 1934 (as amended, the “Exchange Act”) that NYSE Arcafiled to convert Grayscale® Bitcoin Trust (“GBTC”) under NYSE Arca Rule 8.201-E as anexchange-traded product (“ETP”). STA urges the Securities and Exchange…  Read more

STA Comment Letter on Amendments Regarding the Definition of “Exchange” and Alternative Trading Systems (ATSs) That Trade U.S. Treasury and Agency Securities, National Market System (NMS) Stocks, and Other Securities

The Security Traders Association (“STA”) appreciates the opportunity to provide comments inresponse to the aforementioned proposal (the “Proposal”)2 published by the U.S. Securities andExchange Commission (“SEC” or “Commission”). STA is an organization comprised of individualswho are involved in the trading of financial securities in the U.S and Canada. Our members areemployed at retail brokerage firms,…  Read more

STA Comment Letter on the Importance of Appropriate Length of Comment Periods

As you have highlighted in many contexts, the U.S. Securities and Exchange Commission’s (Commission) tripartite mission is to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation. The rules crafted and enforced by the Commission are the vital foundation of the Commission’s critical mission objectives. The Associations, however, are concerned that meaningful…  Read more

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 and losses be taxed at ordinary income tax rates, which would have harmful impacts on retail investors and degrade overall available liquidity in our markets.…  Read more

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 Members and transparency on costs, allocations and fees before re- submitting a revised funding proposal. STA believes the Proposed Funding Model lacks material information pertaining…  Read more