The Security Traders Association (“STA”) appreciates the opportunity to provide comments in response
to the Securities and Exchange Commission (“Commission”) re-proposal of amendments to Rule 15b9-1
under the Securities Exchange Act of 1934 (“Act” or “Exchange Act”) that exempts certain registered
brokers or dealers from membership in a registered securities association (“Association”). The reproposed amendments (“Proposal”) “would replace the rule’s de minimis allowance, including the exclusion therefrom for proprietary trading, with narrower exemptions from Association membership for any registered broker or dealer that is a member of a national securities exchange, carries no customer accounts, and effects transactions in securities otherwise than on a national securities exchange of which it is a member.”

Since FINRA is the only SEC registered national securities association (“Association”), the Proposal would
in effect, require certain proprietary trading firms to become FINRA members. For purposes of clarity, STA
will refer to these firms as “non-FINRA members” or “non-member firms”.