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.

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