STA Comments on SR-NASD-2007-029--OTCBB Access Fees

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4 June 2007

Dear Ms. Morris:

The Security Trader’s Association (“STA”) welcomes the opportunity to comment on the National Association of Securities Dealers, Inc.‘s (“NASD”) proposal to amend NASD Rule 6540© to exclude from the access fee display requirements access fees below a specified level. Specifically, the NASD proposes to allow a participating ATS or ECN to not display its access fee in its published quotation on the OTC Bulletin Board (“OTCBB”) if the fee is $0.003 per share or less for a published quotations that is $1.00 or greater and less than 0.3% of the published quotation on a per share basis if the published quotation is less than $1.00. For the reasons discussed below, we respectfully oppose the proposal and request that the Commission reject it.

The STA is a worldwide professional trade organization that works to improve the ethics, business standards and working environment for our members. There are approximately 5,200 members, all engaged in the buying, selling, and trading of securities. Members participate in STA through 27 national and international 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 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.

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