Category: Comment Letters


  • Letter to Members

    As many of you already know, the STA has long advocated for policies which improve the marketplace and foster investor trust, integrity and capital formation. As an association comprised of […] Read More

  • SEC IAC Recommendations

    The Security Traders Association (“STA”) wishes to offer comment on the three (3) recommendations made by the Securities and Exchange Commission’s (“Commission”) Investor Advisory Committee (“IAC”) Subcommittee on Market Structure […] Read More

  • FINRA/ATS Filing

    The Security Traders Association (“STA”) welcomes the opportunity to comment on proposed rule changes (“ATS Filing”) to: (i) FINRA Rule 4522 to require each alternative trading system (“ATS”) to report […] Read More

  • SEC Small Business Advisory Committee

    The Security Traders Association (“STA”) wishes to offer comment on several of the recommendations made by the Commission’s Small Business Advisory Committee under file number 265-27. The STA also respectfully […] Read More

  • Shortening Deadline for Form 13(f)

    The Security Traders Association, “STA” welcomes the opportunity to comment on NYSE Petition for Rulemaking under Section 13(f) of the Securities Exchange Act of 1934; File No. 4-659; “Petition”. The […] Read More

  • Tick Study

    Over the course of our seventy-nine year history, the Security Traders Association (STA) has provided unique and focused comment on issues related to market structure. STA members are practitioners in […] Read More

  • Tick Size

    We urge the Commission to initiate a pilot program to investigate whether widening the MPVs for emerging growth companies will result in benefits to investors. We recommend that, at a […] Read More

  • “Mini Contract” proposals

    The Security Traders Association, “STA” welcomes the opportunity to comment on Regulatory notices; SR-NYSEArca-2012-26 & SR-ISE-2012-26 Mini-Option Proposals, “Proposals”. The STA is an organization comprised of individuals who are involved […] Read More

  • RLP

    The Security Traders Association (“STA”) appreciates this opportunity to submit comments in regards to the above-referenced New York Stock Exchange (“NYSE”) proposal to establish a Retail Liquidity Program (“RLP” or […] Read More

  • Comment Letter – Senate Banking on Capital Formation

    STA letter to Senator Tim Johnson, then Chairman of the Committee on Banking, House and Urban Affairs; dated March 20, 2012:   “We believe both market makers and other liquidity […] Read More