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ASA Comments on SEC’s Definition of “Exchange” & Regulation ATS Proposal

WASHINGTON – The American Securities Association (ASA) submitted comments to the Securities and Exchange Commission (SEC) on the Commission’s recent proposal regarding the definition of an “exchange” and amendments to Regulation ATS (Reg ATS) and Regulation SCI.

“While the ASA appreciates the SEC’s efforts to review regulations for a market that continues to rapidly evolve, we believe the SEC must carefully consider the wide-ranging consequences of the Proposal on the $22 trillion U.S. Treasury market along with markets for other securities that would be impacted,” ASA CEO Chris Iacovella wrote in the letter.

In the letter, ASA outlined how the SEC has not provided sufficient time for the public to submit feedback on recent rule proposals, echoing concerns recently raised by Commissioner Peirce. Additionally, ASA urged the SEC to not use an overly-broad definition of Communication Protocol System.

“It is unclear what regulatory benefits may derive from requiring a trading desk to become an exchange or a separately regulated ATS,” Iacovella wrote. “We therefore urge the SEC to establish a clearer set of criteria to define a Communication Protocol System and to not force registration requirements on trading desks of regulated broker-dealers who hold sufficient capital when additional regulatory requirements are not warranted.”


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