STA Comment Letter on 15c2 -11

We commend the Commission for proposing amendments to modernize Rule 15c2-11. As the Commission notes in the Proposal, the OTC securities market has undergone significant changes since Rule 15c2-11 was last amended in 1991. At that time, quotes in the OTC marketplace were published daily and other disclosures were limited. The OTC market is now much more developed, with electronic, real-time quotes of OTC securities and disclosure of other information easily accessible to individual investors
through the internet. For these reasons, STA agrees it is appropriate for the Commission to consider modernizing Rule 15c2-11. STA offers the following comments about certain aspects of the Proposal, including: (1) the increased burden that may be imposed on market makers; and (2) potential consequences for retail investors when securities are no longer eligible for public quoting.

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