Notice of Filing of a National Market System Plan to Address Extraordinary Market Volatility (“Plan”)

STA Issues

STA is in general support of the, “Plan”. It is an innovative and progressive means to handle volatility in today’s highly technical and electronic market.
Amendments may be required after implementation. Certain single arbitrary measures in the “Plan” may not meet the intended purposes of the plan for all NMS issues(large, mid and small cap) and all market participants (retail, institutional, market makers and proprietary traders using quantitative models on low latency trading platforms).

The role of the “Processor” in calculating and disseminating the applicable price bands accurately and timely is vital in avoiding negative consequences, in particular, gaming.

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