SEC Trading & Markets Re: Limit Up/Limit Down

STA Issues

STA and FIF will formally announce a implementation partnership on LULD.

Most firms are still reviewing the recent approval notice and have yet to create a complete list of questions. New terms and conditions, in particular; “Straddle state” and greater discretion granted to the exchanges to effect a halt are garnering most of the attention.

There is support within the broker dealer and investment management industry for the “Advisory Committee”. The structure, its role within the Plan and the amount of transparency it will be afforded appear meaningful and fair

Read specific comments (PDF)>