STA discussion document with congressional staff for the month of December on: Consolidated Audit Trail; ETPs and Tick Size Pilot Specific Comments: Consolidated Audit Trail – Recommendation for a Revised Implementation PlanSTA delivered a letter to Thesys CAT, LLC and the Operating Committee on the draftCAT Reporting Technical Specifications for Industry Members, distributed onSeptember 7,…  Read more

STA discussion document with congressional staff on: Consolidated Audit Trail; US Treasury Report and ETPs Specific Comments: Consolidated Audit Trail – Recommendation for a Revised Implementation Plan STA delivered a letter to Thesys CAT, LLC and the Operating Committee on the draft CAT Reporting Technical Specifications for Industry Members, distributed on September 7, 2017. In…  Read more

STA discussion document with congressional staff on: Access Fees & Maker/Taker Models;  Disclosure-Order Handling Information; Reg NMS Plans and Market Data. Access Fees & Maker/Taker modelsAccess fees and corresponding liquidity rebates (or “maker/taker” models) have evolved andare now deeply engrained in the current market structure. STA believes that a ban or anelimination of access fees…  Read more

Access Fees & Maker/Taker models Access fees and corresponding liquidity rebates (or “maker/taker” models) have evolved and are now deeply engrained in the current market structure. STA believes that a ban or an elimination of access fees would present a high risk of disruption to investors. Therefore we would support a narrowly designed pilot program…  Read more

STA discussion document with congressional staff for the month of March & April on: Tick Size Pilot, SEC ESMAC & SEC Over Payment Credit Act Tick Size Pilot Data (“Pilot”) – The Tick Size Pilot has been fully implemented for over four (4) months and has produced much data as reported on and debated in…  Read more