The Security Traders Association (“STA”)1 submits this comment letter on the national market system plan (“Plan”) proposal filed by the national securities exchanges and the Financial Industry Regulatory Authority (“FINRA”) to implement a targeted 12-month pilot program that will widen minimum quoting and trading increments (“tick sizes”) for certain stocks with smaller capitalization. This proposal was filed on August 26, 2014 in response to the June 24, 2014 Securities and Exchange Commission (“SEC” or “Commission”) order directing the exchanges and the Financial Industry Regulatory Authority to submit a tick size pilot plan (Release No. 34-72460). Data gathered from the Plan will enable the Commission to study the impact of wider quoting and trading increments on the trading of certain small capitalization stocks. Once published in the Federal Register, the Plan will be open for public comment for 21 days.

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