Comment Letter: Options Listing Procedures Plan

The Security Traders Association (“STA”), feels it imperative to relay its view that the proliferation of series of options for quoting and trading (“strikes”, or “strike prices”) has overly complicated the options markets and necessitated excessive (and thus inefficient) consummations of technology. If left unabated, this condition may degrade market quality as measured by spreads; liquidity – both displayed and total available per strike. STA writes to both inform you of its concern and to request that the Securities and Exchange Commission, (“SEC”, or “Commission”) direct the exchanges to create a working group to propose unified strike listing rules that would provide efficiencies that would foster market growth; better ensure investor protections; and ultimately improve the liquidity of the market. The listed options markets serve an important role for a broad base of investor types and the STA’s concern, although focused on strikes, is not exclusive to the listed options markets. As the Commission is well aware, the listed options and equity markets are highly interconnected and factors impacting one of these markets necessarily impacts the other.

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