STA Urges Real-Time Trade Reporting in OTC ADR's

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16 August 2007

Dear Ms. Morris:

The Security Traders Association (“STA”) appreciates the opportunity to comment on rule proposal SR-NASD-2007-039 filed by the National Association of Securities Dealers, Inc. (“NASD”), currently known, and hereinafter referred to, as the Financial Industry Regulatory Authority, Inc. (“FINRA”). In Release 34-56103, FINRA proposes to delay implementation of certain rule changes approved in SR-NASD-2005-146 until after November 26, 2007. Specifically, FINRA is proposing to delay the approved rule changes that relate solely to the expansion of the scope of NASD IM-2110-2 to OTC Equity Securities and the related deletion of NASD Rule 6541.

The STA supports the proposed expansion of the Manning interpretation to OTC Equity Securities, and agrees with FINRA that the implementation date should be delayed in order to allow firms to make necessary systems changes to ensure the continuation of a fair, liquid, and orderly market.

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