It has long been STA’s view that liquidity providers contribute to the overall quality of markets to the benefit of investors. While we have advocated for regulators to find modern ways to incentivize their existence, we do not believe the introduction of asymmetric delays is one such way. Therefore, while we appreciate the intended goals of the Proposal and applaud the creativity in its design, we respectfully recommend that the Commission disapprove it.

Read the full letter here.