Open Call – Implementation of Rule 606

STA Open Call – February 26, 2020

Rule 606 Implementation

Chris Bok, FIF & Jim Toes, STA

Reference Material[1]

STA Comment Letter on Rule 15c2-11

STA commends the Commission for proposing amendments to modernize Rule 15c2-11 STA offers the following comments about certain aspects of the Proposal, including: (1) the increased burden that may be imposed on market makers; and (2) potential consequences for retail investors when securities are no longer eligible for public quoting. Full letter here

SEC Proposed Order for New Consolidated Market Data Plan

On Jan 8th the SEC announced it will seek public comments on a proposed order that will modernize the governance of National Market System (NMS) plans that consolidate and disseminate core market data from trading venues by among other things, unifying the three existing plans into one. Comment letters are available here

FINRA Regulatory Notice 20-05; Requesting Comment on Recommendations to Enhance Continuing Education for Securities Industry Professionals Link

While registered persons of broker-dealers are subject to continuing education, they are unable to extend that continuing education in order to maintain their qualification following the termination of any of their registrations. To address this issue, the CE Council recommends that FINRA, and the other SROs participating in the CE program, consider rule changes that would enable previously registered individuals to maintain their qualification for their terminated registration categories by participating in an annual continuing education program. STA Comment Letter

Executive Summary

Amended Rule 606(b)(3) requires that brokers, upon request from their customers, provide a non-public report with a standardized set of individualized disclosures concerning the firm’s handling of that customer’s not-held orders.

  • Standardized disclosures include, but are not limited to, the First and Second routes on orders
  • As of Feb 15th, customers began requesting reports on First routes.
  • Beginning May 15th, customers can begin requesting First and Second route data.

Information on 606(a) and 606(b)(3) provided by Chris Bok, FIF can be found



 This brief is meant for informational purposes only and therefore should not be considered legal advice. STA’s and the STA Foundation’s goals is to raise awareness on this industry development and encourage dialogue.