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ASA Resubmits Comments to SEC on Proposal to Amend Definition of “Exchange”

Today, the American Securities Association (ASA) resubmitted comments to the U.S. Securities and Exchange Commission (SEC) in response to the reopening of public comments regarding its January 2022 proposal to amend the definition of “exchange” under Exchange Act Rule 3b-16. In April 2022, ASA wrote to the SEC cautioning against implementing 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.”


About the American Securities Association

American Securities Association, based in Washington, DC, represents the retail and institutional capital markets interests of regional financial services firms who provide Main Street businesses with access to capital and advise hardworking Americans how to create and preserve wealth. ASA’s mission is to promote trust and confidence among investors, facilitate capital formation, and support efficient and competitively balanced capital markets. This mission advances financial independence, stimulates job creation, and increases prosperity. The ASA has a geographically diverse membership of almost one hundred members that spans the Heartland, Southwest, Southeast, Atlantic, and Pacific Northwest regions of the United States.


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