Over the course of our seventy-nine year history, the Security Traders Association (STA) has provided unique and focused comment on issues related to market structure. STA members are practitioners in the markets and build consensus from the diverse viewpoints of our membership. STA strives to improve the entire marketplace and not just one individual business model. Today, we are writing to share our views on the Jumpstart Our Business Startups Act (JOBS Act) Section 106 Report to Congress on Decimalization (“Study”) that was issued by Staff of the U.S. Securities and Exchange Commission on July 20, 2012 to examine the effects of decimalization on initial public offerings (IPOs) of small and middle capitalization companies. STA concurs with the Study in recommending the Commission hold a roundtable to provide an opportunity for the industry and other interested persons to provide input on how a pilot program could be best conducted, and we respectfully request that the STA be invited to participate.

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