The Security Traders Association (“STA”) wishes to offer comment on the agenda item: “Committee Discussion of Venture Exchanges and Secondary Market Trading Issues” discussed at March 4, 2015, meeting of the Securities and Exchange (“Commission”) Advisory Committee on Small and Emerging Companies. The STA has a long history of offering comments on complex market structure issues. We as an industry association with a diverse membership as measured by geography and business model are well positioned to offer comments on the subject of venture markets and venture exchanges. The STA has twenty-four affiliate organizations, including four (4) in Canada, where a venture exchange called TSX Ventures is operated. In addition two (2) of STA advisory committees, the Buy Side Advisory and Retail Advisory committees, are comprised of financial service professionals from firms who hold investor assets and bear certain investment recommendation and execution responsibilities. We believe the combination of these perspectives will provide the Commission with invaluable insight into the current state of venture markets in the United States, along with recommendations on where the Commission should focus its attention for determining if improvements or new processes are needed.

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