Comment Letter to Senate Banking On Capital Formation

Dear Chairman Johnson and Ranking Member Shelby,

Recently, the House of Representative passed H.R. 3606, the “Jumpstart Our Business
Startups Act.” The Security Traders Association, “STA”1 would like to share our thoughts
regarding this bill. Furthermore, we wish to comment on the existing state of our market
structure and its ability to perform its role in capital formation. The STA has been in existence
since 1934. Our long history of writing comment letters and white papers has provided regulators
with a unique perspective on market events and trends. The subject of market structure and its
role in capital formation is an issue the STA has commented on in the past, including in a letter
to then SEC Chairman William Donaldson, dated May 14, 2003 which stated:

“The raising of equity capital by corporations is the cornerstone of our economy.
However, given the recent regulatory events surrounding research and investment
banking and market structure changes affecting trading, the raising of capital has
become exceeding more difficult. That, in turn, is impacting the U.S. economy and its
ability to create jobs.

Action must be taken soon to remedy what could soon be a capital formation crisis.”

Read letter here