Tick Size

We urge the Commission to initiate a pilot program to investigate whether widening the MPVs for emerging growth companies will result in benefits to investors. We recommend that, at a minimum, such a program have the following characteristics:

  • A defined measure, to determine whether there is a benefit to investors and capital formation
    for emerging growth companies with reintroducing wider MPVs, will need to be determined.
    We recommend a measure which could quantify overall liquidity, both displayed and enhanced.
  • Utilize a statistically significant number of emerging growth companies to study the impact on
    the secondary markets of quoting securities in MPVs greater than one penny.
  • Establish eligibility criteria for companies to qualify for the pilot program.
  • Allow the pilot program to operate for a sufficient period, a minimum of 2 years, so that firms
    will have an incentive to make the financial commitment necessary to participate on a
    commercially viable basis.

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