The Security Traders Association (“STA”) wishes to offer comment on the three (3) recommendations made by the Securities and Exchange Commission’s (“Commission”) Investor Advisory Committee (“IAC”) Subcommittee on Market Structure (“Subcommittee”) under file number 265-28. These recommendations pertain to the impact decimalization with no minimum price variations (“MPVs”) may have on the ability of the U.S. equity markets to perform the capital raising function for new companies.

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