STA News Media

Comment Letter: STA Comments on S7-27-09, "Regulation of Non-Public Trading Interest"

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22 February 2010

February 22, 2010

Ms. Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Re: Proposed Rule: Regulation of Non-Public Trading Interest Securities Exchange Act Release No. 34-60997; File No. S7-27-09

Dear Ms. Murphy:

The STA appreciates the opportunity to comment on the Proposed Regulation of Non-Public Trading Interest, Release No. 34-60997 (“Release”).

In summary, the Commission is proposing:

1. To treat actionable Indications of Interest (“IOIs”) as quotes and subject them to the same disclosure rules;

2. To lower the Alternative Trading System (“ATS”) trading volume threshold from 5% to .25% of the total volume traded. This would apply on a stock by stock basis and would require that the ATS display its best priced orders to the public if they currently display to more than one person;

3. To require Real-time disclosure via public Reports of Executed Trades. An exemption would be provided for trades greater than $200,000 in value;

4. To exempt from the provisions of Proposals 1 and 2 above, IOIs with a market value of $200,000 made to a counterparty that are reasonably believed to represent a contra-side trading interest of equally large size.


Comment Letter: STA Comments on FINRA SR 2009-077 - Quotation Consolidation Facility

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4 February 2010

February 4, 2010

Ms. Elizabeth M. Murphy
Secretary
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

Re: Comments to Securities Exchange Act Release No. 60999 (File No. SR-FINRA-2009-077)

Dear Ms. Murphy:

The STA appreciates the opportunity to comment on the proposal filed by the Financial Industry Regulatory Authority (“FINRA”) to establish a Quotation Consolidation Facility (“QCF”).

FINRA is proposing to “create a QCF for OTC Equity Securities for regulatory and transparency purposes that would serve as a data consolidator for all quote data in the over-the-counter equity market.” The proposal would require all market makers to provide FINRA with all over-the-counter quotations. FINRA proposes to distribute these as a consolidated quote data stream and charge broker/dealers a monthly fee to receive the data. They also propose charging a fee for the posting of quotes on the system but against which firms cannot execute.

STA opposes the FINRA proposal because it is not necessary. There exists a private facility providing all required information on an economically sound basis. This proposal fails to demonstrate either the need or requirement for such facility. We cannot see any increased value or increase in protection for investors, or regulators, and, at the same time, this proposal comes with very substantial cost increases to all participants which will passed on to investors either implicitly or explicitly.

There already is, as a practical matter, a consolidated quotation system. Pink Quote is the de facto consolidated quotation facility as a result of its own initiative to offer services to customers. Pink Quote currently merges OTCBB quotes with its own quotes, i.e. creates a consolidated quotation feed. This information is made available to investors, market participants and regulators. Pink Quote publishes a consolidated NBBO in securities that are dually-quoted in the OTCBB and requires vendors that purchase market data from it to consolidate quotations from Pink Quote and the OTCBB. FINRA’s proposal would be unlikely to significantly increase the transparency of quotation information.
Nor does STA believe that FINRA needs to be the quote consolidator for regulatory purposes. FINRA meets its regulatory responsibilities towards Pink Quote today by making use of the quote information already provided to it by that company. Pink OTC makes all of the market data generated by its inter-dealer quotation system available to FINRA as its reporting agent for all its broker dealer customers. This is done without charge to FINRA and pursuant to the requirements of existing FINRA Rule 6330.


Comment Letter: STA Opposes Transaction Tax Proposal - H.R. 4191

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2 December 2009

On December 3, 2009, Congressman Peter DeFazio (D-OR) introduced H.R. 4191, a bill titled “Let Wall Street Pay for the Restoration of Main Street Act of 2009.” The bill would establish a “securities transaction tax [that] is applied to stock transactions (1/4 of 1 percent (0.25%)), futures (0.02%), swaps (0.02%), credit default swaps (0.02%), and options (at the rate of the underlying asset).”

I strongly oppose this legislation. Its enactment would lead to serious disruptions in the capital markets while burdening “Main Street” with paying the tax.

The authors of the legislation state that is intended to “make it clear to our constituents that we know Main Street is suffering and a restored Wall Street should now share in its recovery with everyone else.” In spite of exemptions for tax-deferred accounts and other specified trading, the incidence of the tax would ultimately impose a significant and open-ended burden on the individuals and businesses that make up “Main Street.” For example, while an individual trader may not accumulate $100,000 in trades annually, an individual investor in a mutual fund will pay this tax as the fund itself will vastly exceed that amount in trading in a year.

What the creators of this bill need to realize is that Wall Street and Main Street are not separate entities. Wall Street helps to build Main Street by raising the capital businesses need to operate and employ “Main Street. The vast majority of main street investors use managed accounts and mutual funds to invest their savings, the fees paid for such services help sustain Wall Street This tax would be passed through to those investors, the very people that the creators of this bill claim they are trying to protect.

Click here to view the letter in its entirety.


Press Release: STA Supports Liquidity Provision and as well as Pools with Fair Access and Full Disclosure

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2 November 2009

(New York: October 30, 2009) The STA affirms its support of the importance of liquidity providers regardless of the market capitalization of any particular stock. The US securities markets provide for the health and growth of the overall economy as well as the engine for raising capital. Absent the provision of liquidity, our securities markets would not exist. Historically, liquidity has been provided in exchange listed securities by specialists and market makers and in OTC securities by market makers. Both take risk to secure fair, liquid, and orderly trading.

Over the course of recent decades technology has evolved this function but its importance to investors and issuers remains the same.

Consistent with this, STA’s history has been one of participation by, and support of “liquidity providers.” Representation of liquidity providers and their perspective is a core mission of the STA. The importance of their role in the market is essential to any debate regarding market structure, or rules and regulation of exchanges, brokers, or ATSs.

Click here to view the press release in its entirety.


Press Release: STA Elects 2010 Officers and Governors

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20 October 2009

(New York: October 20, 2009) At its 76th Annual Conference and Business Meeting, the Security Traders Association (STA), which represents 5,200 broker and institutional equity securities traders in North America, elected its leadership for 2010.

Elected to serve as Officers for 2010 include:

Chairman, Brett Mock, BTIG LLC, San Francisco
Vice Chairman, Joseph Cangemi, BNY ConvergEx Group, New York
Treasurer, Louis Matrone, JonesTrading Institutional Services LLC, Dallas
Secretary, Jennifer Setzenfand, Federated Investors, Inc., Pittsburgh

Click here to view the press release in its entirety.


Comment Letter: Reg SHO Uptick Rule

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22 September 2009

September 21, 2009

Ms. Elizabeth M. Murphy
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

RE: Release No. 34-60509; File No. S7-08-09
Proposed Price Test Amendments to Regulation SHO

Dear Ms. Murphy:

The Security Traders Association (STA or the “Association”) welcomes the opportunity to respond to questions posed by the Securities and Exchange Commission (“SEC” or “the Commission”) in SEC File 34-60509, Proposed Amendments to Regulation SHO.

The STA is a professional trade organization that works to improve the markets, ethics, business standards, and working environment for our members. There are approximately 5,200 members across North America, all engaged in the buying selling and trading of securities. The STA provides a forum for our traders, representing institutions, broker-dealers, ECNs, exchanges, market makers and floor brokers to share their unique perspective on issues facing the securities markets. Our members work together to promote investor protection and efficient, liquid markets.

A major fact that many market observers fail to recognize is that the equity markets have functioned efficiently throughout the recent financial meltdown and subsequent recovery. At times the equity markets were the last frontier of liquidity. When investors wanted liquidity they turned to the equity markets which were not frozen, unlike some other markets. When they did, the equity markets were functioning, providing bids and offers to facilitate investor transactions.

The STA has been involved in the discussion and debate about short sales for decades. Our members are actively involved in the business of trading securities and are therefore uniquely qualified to discuss regulations concerning the purchase and sales of securities. We believe that short selling is a legitimate and economically important activity that fosters price discovery and provides additional liquidity to the markets. The STA supports legitimate short selling as a critical component of overall liquidity. We applaud the SEC for focusing on balancing the costs and benefits of any additional short selling restrictions at both the April 8, 2009 open meeting and the May 5, 2009 Roundtable. We are not aware of any evidence produced at these meetings or in all the subsequent comment letters that showed restricting short selling would have eliminated naked or abusive short selling, increased investor confidence in any meaningful fashion or that the benefits of these regulations would outweigh the additional costs they would impose.


Click here to view this letter in its entirety.


Comment Letter: STA Comments on Rule 204T

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14 August 2009

August 13, 2009

Ms. Elizabeth M. Murphy
Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
RE: Release No. 34-59748; File No. S7-08-09 and
Release No. 34-60388; File No. S7-30-08

Dear Ms. Murphy:

The Securities and Exchange Commission’s recent actions adopting Rule 204T on a permanent basis is a significant advance in the effort to control abusive short selling. Rule 204T is a measured and targeted regulation that places the regulatory burden primarily upon those market participants that engage in short selling. It is an effective regulation that has significantly reduced the number of issues on the threshold lists and reduced overall fails to deliver by over 50%. This rule works. The deliberative open process used to vet this rule is most effective for considering complex issues. The Security Traders Association congratulates the Commission on this exemplary rulemaking effort.

The Security Traders Association (STA) has been involved in the short sale discussions for decades. We have long viewed short sales as a valid investment alternative and we have held equally strong support for strict enforcement of locate and delivery rules that serve to eliminate illegal naked and abusive short selling. The STA has also long shared its concerns about abusive short selling. We continue to believe that short sale regulations should concentrate on the clearing and settlements processes.

We absolutely concur with Commissioner Paredes’ remarks at the Security Traders Association’s 13th Annual Washington Conference on May 6, 2009:

Much attention has focused on concerns with short selling, but it is equally important to emphasize the benefits of short selling. Short selling makes significant contributions to the effective operation of securities markets, benefiting all market participants and the economy overall. Short selling contributes to liquidity, capital formation, and more efficiently allocated risk. Short selling can buttress buying by allowing investors going long to hedge their positions; and short selling can encourage market participation by leading to improved price discovery. Short selling helps ensure that securities prices are not systematically biased higher than the fundamentals warrant, as could be the case if prices did not reflect the less optimistic views of short sellers. Price discovery matters because investors would be less willing to invest if the contrarian views of short sellers were not fully incorporated into securities prices. Furthermore, when price discovery is compromised, we run the risk that our securities markets allocate capital inefficiently.

Click here to view this letter in its entirety.


Comment Letter: STA Comments on SEC Reg SHO Rule Filing

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24 June 2009

June 19, 2009

The Honorable Mary L. Schapiro
Chairman
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
RE: Release No. 34-59748: File No.S7-08-09; Proposed Price Test Amendments to Regulation SHO

Dear Chairman Schapiro:

The Security Traders Association (STA or the “Association”) welcomes the opportunity to answer questions the Securities and Exchange Commission (SEC or the “Commission”) poses regarding SEC File 34-59748, Proposed Amendments to Regulation SHO.

The STA is a professional trade organization that works to improve our markets, ethics, business standards, and the working environment for our members. There are approximately 5,200 members across North America, all engaged in the buying selling and trading of securities. Members participate in STA through 27 affiliate organizations and represent the interests of the trading community and institutional investors. The STA provides a forum for our traders, representing institutions, broker-dealers, ECNs, and floor brokers to share their unique perspective on issues facing the securities markets. Our members work together to promote their shared interests in efficient liquid markets as well as in investor protection.

The STA has been involved in the short sale discussions for decades. Our members are actively involved in the business of trading securities and are therefore uniquely qualified to discuss regulations concerning the purchase and sales of securities. We are in fundamental agreement with the SEC that short selling is a legitimate and economically important activity that fosters price discovery and provides additional liquidity to the markets. The STA supports legal short selling as a critical component of overall liquidity. We applaud the Commissioners for focusing on balancing the costs and benefits of any additional short selling restrictions at both the April 8, 2009 open meeting and the May 5, 2009 Roundtable. We support strict enforcement of locate and delivery rules that eliminate illegal and abusive short selling, including naked shorts.

Click here to view this letter in its entirety.


Comment Letter: STA Short Sale Circuit Breaker Proposal

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4 May 2009

May 4, 2009

The Honorable Mary L. Schapiro
Chairman
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
SUBJECT: File Number S7-08-09

Dear Chairman Schapiro:

The Security Traders Association (STA) has been involved in the short sale discussions for decades. We have long respected short sales as a valid investment alternative. We have held equally strong support for strict enforcement of locate and delivery rules that serve to eliminate illegal and abusive short selling, including naked shorts.

The current discussions on how to combat abusive short selling and the attributed volatility have been trading centric (trading triggers result in trading restrictions). We believe that the past 18 months have taught us that we need to think outside the box. The STA has communicated our concerns about “tick tests” and “bid tests” on many occasions in the past. We believe that price tests (such as the “bid test” or “tick test”) have been rendered ineffective by structural changes to the markets and that price tests would be unable to dampen volatility even if they were to be reinstituted. It is the considered position of the Board of Directors of the STA that an objective means of establishing benchmarks for these tests does not exist in today’s market structure. We continue to believe that both tests are seriously flawed and if they were to be implemented gaming of these types of trading restrictions would become rampant again. Neither price test would present any appreciable resistance for abusive short selling in downward spiraling issues and thus would be ineffective in solving the current quandary. The STA believes that rules should be promulgated to control identifiable and measurable problems, and does not believe that reincarnating discredited regulations of yesteryear will position us to effectively compete in today’s markets. In this vein the Security Traders Association has developed an alternative Short Sale Circuit-Breaker Proposal.

Click here to view this letter in its entirety.


Comment Letter: SEC Proposal on Short Sale Price Test

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18 March 2009

March 18, 2009

The Honorable Mary L. Schapiro
Chairman
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
SUBJECT: SEC Proposal on Short Sale Price Test

Re: SEC Release No 34-58592/Sept. 18, 2008
Emergency Order Pursuant to Section 12(k)(2) of The Securities Exchange Act of 1934 Taking Temporary Action to Respond to Market Developments.

Dear Commissioner Schapiro:

The Security Traders Association (STA) is in fundamental agreement with the Securities and Exchange Commission that short selling is a legitimate and economically important activity that fosters price discovery and provides additional liquidity to the markets. We firmly believe that the Securities Exchange Commission (SEC) bolstered the integrity of the markets when, after extensive study, it removed disparate price tests which provided an opportunity for regulatory arbitrage and had been rendered ineffective by structural changes to the markets. In the best traditions of the SEC, the agency acted in an exemplary manner when it released the Regulation SHO Concept Release and provided industry participants with an opportunity to comment on and help shape the final regulation. The SEC further promoted investor protection by implementing the new regulation as a pilot program giving participants, academia and regulators the opportunity to further study the effects of the rule change and by encouraging additional study of the proposed changes.

Click here to view this letter in its entirety.


Comment Letter: Letter to Ways and Means Committee Opposing Transaction Tax

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9 March 2009

March 6, 2009

The Honorable Charles Rangel
Chairman
House Committee on Ways and Means
1102 Longworth House Office Building
Washington, DC 20515

Dear Chairman Rangel:

On behalf of the Security Traders Association (STA) and its approximately 5,200 members, I am writing to express our strong opposition to the “Let Wall Street Pay for Wall Street’s Bailout Act of 2009” (H.R. 1068). The proposed legislation would seriously harm the economy as well as individual investors, savers and retirees.

The STA is a worldwide professional trade organization that works to improve the ethics, business standards and working environment for individual members who are engaged in the buying, selling, and trading of securities. Members participate in the STA through 26 affiliate organizations and represent the interests of the trading community and institutional investors. The STA provides a forum for our members and other market participants to share their unique perspectives on issues facing the securities markets. They work together to promote their shared interest in efficient, liquid markets as well as in investor protection.

While H.R. 1068 attempts to target the transaction tax on “Wall Street investors”, it would result in a direct tax increase on individuals planning for retirement, middle class families saving for college through Section 529 programs, state and local government workers invested in public employee retirement systems, and many others. While “wealthy investors” would certainly pay some of the transaction tax, it would also constitute a large and burdensome tax increase on the middle class.

Click here to view this letter in its entirety.
To view the related press release, click here.


Press Release: STA Opposes Proposed Transaction Tax

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25 February 2009

(New York: February 23, 2009) The Security Traders Association (STA), the leading advocacy and education organization for professional equity traders in the U.S., today stated its strong opposition to a bill introduced by Congressman Peter DeFazio, H.R. 1068 the “Let Wall Street Pay for Wall Street’s Bailout Act of 2009.” The bill aims to impose a 0.25% transaction tax on the “sale and purchase of financial instruments such as stock, options, and futures.” The proceeds of this tax are to pay for the “net cost” TARP and emergency Federal Reserve programs.

In an open letter, the STA registered both its strong opposition and the rationale for its position. The STA demonstrates that bill is based on erroneous premises and misstatements of fact and could lead to serious disruptions in the capital markets at a time of national crisis.

A synopsis of the STA’s position follows:

Click here to view the press release in its entirety.


Comment Letter: Robust Regulation and Market Quality: The Importance of Due Process in the Course of Self Regulatory Rulemaking

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12 January 2009

January 12, 2009

Via Electronic Mail (rule-comments@sec.gov)

Ms. Florence E. Harmon
Acting Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
RE: Amendments to Regulation SHO (Interim Final Temporary Rule) SEC Release No 34-58773, File No. S7-30-08

SUBJECT: Robust Regulation and Market Quality: The Importance of Due Process in the Course of Self Regulatory Rulemaking

Dear Ms. Harmon:

Securities and Exchange Commission (SEC) Chairman Christopher Cox’s comments in a recent Washington Post interview provide us with an opportunity to reflect on some of the events of 2008.

The Chairman stated: “‘What we have done in this current turmoil is stay calm, which has been our greatest contribution — not being impulsive, not changing the rules willy-nilly, but going through a very professional and orderly process that takes into account unintended consequences and gives ample notice to market participants,’ Cox said. This caution, he added, ‘has really been a signal achievement for the SEC.’” The STA agrees that such an approach to rulemaking, along with strict enforcement of existing regulations, would have been the most prudent course of action during the very turbulent market conditions in 2008.

Click here to view this letter in its entirety.


Press Release: STA Elects 2009 Officers and Governors

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21 October 2008

(New York: October 21, 2008) The Security Traders Association (STA), the leading advocacy and education organization for professional equity traders in the U.S., today announced the new members of its Board of Governors and Officers for 2009. The Board of Governors provides overall governance for the Association. The Officers, elected for a one-year term, comprise the Executive Committee, set the direction, and oversee operations. The elections were made at the Association’s 75th Annual Conference and Business meeting. The Governors and Officers are elected by the 5,200 members of the Association, represented through 26 Affiliates in North America and Europe.

Newly elected Governors and their Affiliates are:

• John Daley of Dallas
• Rory O’Kane of Chicago
• Joe Roman of Georgia
• Jon Schneider of Kansas City
• Jennifer Setzenfand of Pittsburgh

Click here to view the press release in its entirety.


Press Release: NYIF Partners with STA for Continuing Education

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6 October 2008

(New York: October 6, 2008) The Security Traders Association (STA), the leading advocacy and education organization for professional equity traders in the U.S., today announced that it has, through its education arm, the STA University, formed a strategic partnership with The New York Institute of Finance (NYIF). Under the agreement, NYIF will provide the Association’s 5,200 members access to the eLearning course catalog and Virtual Classes of the NYIF through the STAU. The courses are in areas that are critical to traders’ continuing professional development.

Initially, NYIF will offer its eLearning courses to STA members. Currently, more than 175 hours of online learning, covering over 25 financial area topics, are available via the web. These topics include back office operations, derivatives, equities, credit, risk management, corporate finance, and many others. All courses earn professional continuing education credits.

Click here to view the press release in its entirety.


Comment Letter: STA Comments on Short Sales

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24 September 2008

September 24, 2008

The Honorable Christopher Cox
Chairman
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: SEC Release No 34-58592/Sept. 18, 2008
Emergency Order Pursuant to Section 12(k)(2) of The Securities Exchange Act of 1934 Taking Temporary Action to Respond to Market Developments.

Dear Chairman Cox:

With the current crisis in the financial markets, and based on our long-standing, productive dialogue with legislators and regulators, the Security Traders Association has been patient with and supportive of the SEC’s actions relative to short sales. However, given continued market stress, it is clear that the continued emphasis on short selling, without rigorous analysis and the opportunity for public comment, is not serving the intended purpose of supporting market integrity.

The securities industry is experiencing burdensome expenses in system adjustments and altered procedures in order to conform with the new orders. At the same time there is confusion as to what is expected, in what timeframe, and by which market participants. At a minimum, greater clarity is required. As a result of current confusion regarding regulatory and operating requirements for affected firms, we are witnessing increased investor and industry confusion and loss of confidence in our markets – the exact opposite of our collective objective.

Click here to view this letter in its entirety.


Comment Letter: STA Comments on Market Data Fees

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12 September 2008

September 11, 2008

Ms. Florence E. Harmon
Acting Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: File No. SR-NYSEArca-2006.21, SEC Release No 34-57917

Dear Ms. Harmon:

The Security Traders Association (“STA”) has historically had a sustained and productive dialogue with the Commission on behalf of our members, and we are respectfully submitting this letter to offer our perspective on the recent Proposed Order Approving Proposal by NYSE Arca, Inc. To Establish Fees for Certain Market Data (the “Proposed Order”).

The STA recognizes the critical role the Commission plays in protecting the integrity and confidence that investors rightfully place in the U.S. markets. We believe (and have consistently maintained) that an appropriate balance between regulation and competition is critical to the development of market structure. We further agree with the Congressional findings underpinning the national market system provisions in the Securities Exchange Act of 1934, as amended by the Securities Acts Amendments of 1975 (Section 11A(a)(1), 15 U.S.C. § 78k-1 (a)(1)), where “The Congress finds that…(C) It is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure…(ii) fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets…(iii) the availability to brokers, dealers, and investors of information with respect to quotations for and transactions in securities…..”

Click here to view this letter in its entirety.


Comment Letter: Chairman Cox Responds to STA Comments on Emergency Order

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6 August 2008

Please find attached the letter from SEC Chairman Christopher Cox which responds to our letter of July 23, 2008 responding to the Emergency Order imposed on short selling at that time.

We continue to carefully monitor the short sale issue and will keep you informed as appropriate.

John Giesea
President & CEO
Security Traders Association

Click here to view Chairman Cox’s response.


Comment Letter: STA Comments on Emergency Action by SEC

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23 July 2008

July 23, 2008

The Honorable Christopher Cox
Chairman
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: SEC Release No 58166/July 15, 2008

Emergency Order Pursuant to Section 12(k)(2) of The Securities Exchange Act of 1934 Taking Temporary Action to Respond to Market Developments.

Dear Chairman Cox:

The Security Traders Association1 (STA) has historically engaged in productive dialogue with the Commission on behalf of our members, and we are respectfully submitting this letter to offer our perspective on the recent Emergency Order regarding short selling in the securities of certain financial institutions.

The STA recognizes the critical role the Commission plays in protecting the integrity and confidence that investors rightfully place in the U.S. markets. We believe (and have consistently maintained) that an appropriate balance between regulation and competition is critical to the development of market structure. Further, we acknowledge the Commission’s right to intervene in extraordinary market circumstances. We recognize that the current conditions are unique.

We believe that the Emergency Order of July 15, 2008 should terminate after the July 29th extension expires. Should the Commission determine that any further action, either via emergency powers or rule promulgation, is warranted, it should not be implemented without a detailed analysis of the impact on market participants. Such an analysis should focus in particular on the effect on liquidity providers and widely used clearing systems. Further, we urge that any proposed extension of the Order be issued first for public comment.

Click here to view this letter in its entirety.


STA in the News: STA Endorses SEC Nominees

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10 June 2008

Dear Chairman Dodd:

We are writing today on behalf of the 5,200 members of the Security Traders Association (STA) to express the Association’s strong support of President Bush’s nominations of: Luis Aguilar of McKenna, Long & Aldridge LLP; Troy Paredes of Washington University School of Law; and Elisse Walter of FINRA as SEC Commissioners. We hope their nominations secure quick approval.

For those of us engaged daily in the equity trading that fuels the U.S. economy, the years ahead will continue to pose challenges involving numerous issues that will directly impact investors. The equity securities industry continues to be challenged by regulatory, technological, competitive and overall economic forces that require considered thought from the SEC. This is critical in maintaining the ongoing health and vitality of our industry.

STA supports a balance of regulation and competition as the key to sustaining U.S. competitiveness in an increasingly global trading environment. U.S. investors need a Commission with a breadth and depth of experience, expertise, and insight, and with an ability to work with industry participants to assure that the U.S. markets retain their rightful place as the envy of the world.

Click here to view the letter in its entirety.


Comment Letter: STA Supports Enhanced Reg SHO Rule Proposal--S7-08-08

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22 May 2008

Dear Ms. Morris:

The Security Trader’s Association (the “STA” or the “Association”) welcomes this opportunity to comment on the proposal of the Securities and Exchange Commission (the “SEC” or the “Commission”) to promulgate Rule 10b-21, a new anti-fraud rule under the Securities Exchange Act of 1934 (the “Exchange Act”). Specifically, new Rule 10b-21 would address fails-to-deliver securities that are associated with naked short selling.1 With the new rule, the Commission intends to highlight the liability of persons that deceive specified persons about their intention or ability to deliver securities in time for settlement, including persons that deceive their broker-dealer about their locate, source, or ownership of shares and that fail to deliver securities by settlement date. The Commission is concerned that fails-to-deliver associated with naked short selling may have a negative effect on the market and shareholders, and thus seeks to add proposed Rule 10b-21 to its arsenal of tools to combat manipulative short selling.

Click here to view this letter in its entirety.


Comment Letter: STA Comments on Private Issuers Filing--S7-04-08

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22 May 2008

Dear Ms. Morris:

The Security Traders Association (“STA”) welcomes the opportunity to comment on rule proposal S7-04-08 by the Securities and Exchange Commission (the “Commission’) to amend the Rule that exempts a foreign private issuer from having to register a class of equity securities under Section 12(g) of the Securities Exchange Act of 1934 (the “Exchange Act”) based on the submission to the Commission of certain information published outside the United States.

In two recent letters the STA has commented to the Commission of proposed changes2 in the OTC markets as they affect investors, traders, and securities. In each of these cases, the STA recognized and supported the benefits of more efficient and transparent trading of non-U.S. securities.

Click here to view this letter in its entirety.


Press Release: STA Report Calls for Modification of U.S. Market Structure--Key Drivers, Issues Identified

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30 April 2008

(New York: April 30, 2008) The Security Traders Association (STA), the leading advocacy and education organization for professional equity traders in the U.S., today issued a special report. The report details the key drivers of current market structure in the U.S. and recommends incremental actions to improve the markets, assure continued market quality, and sustain U.S. competitiveness. The STA offers this report to establish a dialogue on issues of concern with industry participants and policymakers.

The report finds that U.S. equity market structure has evolved considerably and that the evolution is due primarily to changes in exchange structure, regulation, and technological advancements. One consequence of this evolution is the volatility the U.S. equity markets are now experiencing. These changes and their consequences are having a significant impact on the securities industry and investors.

Among the key findings of the report are: Click here to view the press release in its entirety.


Comment Letter: STA Special Report -- U.S. Market Structure--2008

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30 April 2008


Press Release: STA Applauds Continued Reduction in Section 31 Fees

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5 March 2008

STA Applauds Continued Reduction in Section 31 Fees
Demonstrates Value of Cooperative Effort with Legislators and Regulators

(New York: March 5, 2008) The Security Traders Association (STA), the leading advocacy and education organization for professional equity traders in the U.S., today applauds the continued reduction in Section 31 fees, which are collected on equity trades from the securities industry to fund the Securities and Exchange Commission (SEC).

The STA worked with the Congress to help pass in 2002 The Investor and Capital Markets Fee Relief Act, which projected a reduction in the fee structure. Section 31 fees are paid by investors every time they sell a stock. The Act also increased funding for the SEC and granted SEC employees pay parity with Federal banking regulators as a way to help the Commission attract and retain quality staff.

Click here to view this press release in its entirety.