Security Traders Association

The Security Traders Association, “STA” welcomes the opportunity to comment on Regulatory Notice: 11-43 -Proposed Amendment to FINRA Rule 5210 (“Amendment”). The STA is an organization comprised of individuals who are involved in the trading of financial securities. Our members represent many of the business models in the financial services sector, including full and discount service broker dealers, agency only broker dealers, asset managers, exchanges and ATS’s. Because of the diversity within our membership we are uniquely qualified to provide insight and comments on the Amendment. The STA uses a Committee structure to vet issues amongst its various constituencies to create bottom-up consensus. With regard to the Amendment, the STA utilized its: (1) Institutional Committee, which is comprised solely of traders from institutional asset managers; (2) Compliance Committee, which is comprised of compliance personnel at various broker dealers; and (3) Trading Issues Committee, which has representatives from different market participants. The opinions expressed in this letter will be those of a broad spectrum of market participants who are both the initiators and receivers of Indications of Interest (IOIs).

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