The Security Traders Association, “STA” welcomes the opportunity to comment on NYSE Petition for Rulemaking under Section 13(f) of the Securities Exchange Act of 1934; File No. 4-659; “Petition”. 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 Petition. The STA uses a Committee structure to vet issues amongst its various constituencies to create bottom-up consensus. With regard to the Petition, the STA relied mostly on input we received from our Institutional Advisory Committee and Institutional Committee, which are comprised of representatives from the trading desks of institutional asset managers. These members carry the fiduciary responsibilities of best execution on behalf of their investors.

Read full comment letter (PDF)>