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A Case Against The Trade-At Rule (SIFMA)

30

April, 2010

Having just read SIFMA’s SEC Comment letter : 

http://sec.gov/comments/s7-02-10/s70210-167.pdf ,

we note their good argument against a trade-at rule, which begins on page 12 of their letter as such:

C.
Trade-At Proposal

The Concept Release asks whether, if commenters believe that the quality of public price discovery has been harmed by non-displayed liquidity, the Commission should consider a “trade-at” rule. Such a rule would prohibit any trading center from executing a trade at the NBBO unless the trading center was displaying that price at the time it received the incoming contra-side order. The trade-at rule would require a trading center not displaying

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