Category: Comment Letters

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 investment vehicles due to reduced trading volume. While most FTT proposals appear on the surface to have low rates, they add up to significant costs…  Read more

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 are identified and the evolutionary process proceeds toward an improved market. We believe the events that occurred in late January and early February, 2021, involving…  Read more

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 exchanges, would foster market growth, better ensure investor protections, and ultimately improve the liquidity of the market. Therefore, STA recommends that the Commission approve the…  Read more

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 in raising the reporting threshold.  We believe a threshold which is materially lower than the proposed $3.5 billion AUM will more effectively balance the interests of…  Read more

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 last amended in 1991. At that time, quotes in the OTC marketplace were published daily and other disclosures were limited. The OTC market is now…  Read more