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ASA Urges SEC to Act on Market Structure Innovation

The SEC has missed several opportunities to implement reforms that have the longstanding support of a broad spectrum of market participants.

WASHINGTON – The American Securities Association (ASA) today sent a letter to the Securities and Exchange Commission (SEC) calling on the Commission to act and reform our nation’s equity market structure in a way that prioritizes small business capital formation and market stability. 


“The trading rules adopted by the SEC –Regulation National Market System (Reg NMS) – have created an unequal equity market structure that favors speed and algorithmic trading in large cap securities over trading in small and mid-cap securities (SMEs), which has hurt secondary market liquidity in SMEs,” ASA CEO Chris Iacovella wrote in the letter. “The SEC has missed several opportunities to implement reforms that have the longstanding support of a broad spectrum of market participants,” Iacovella continued. “This failure to act has effectively kicked the can down the road on the market structure debate for SMEs, preserved the status quo for those who benefit from the current trading regime, and continues to be a disincentive for growing small American businesses to complete an IPO.”

In the letter, ASA outlined proposals to improve the environment for thinly-traded securities and urged the Commission to swiftly adopt a data-driven intelligent tick size. “We recommend that Commission begin by proposing changes related to UTP and tick size for SMEs, EGCs, and thinly traded stocks,” Iacovella wrote. “This action has the support of a broad cross-section of industry participants and would make it more attractive for businesses to enter our public markets and create greater opportunity for America’s retail investors to share in their success.”

ASA’s letter follows the Commission’s October 17th, 2019 Statement on Market Structure Innovation for Thinly Traded Securities, released outside of the Administrative Procedures Act (APA), which ASA criticized. 

“The SEC would do well to remember that market structure was created for and is intended to support and promote capital formation, not the other way around,” Iacovella concluded. 


ASA’s regional financial services companies work in communities across the country to create jobs, grow the economy, and increase prosperity for all Americans. The ASA exclusively represents the capital market and private client interests of its members and seeks to promote free market principles making it easier to access financial advice and capital. ASA members help Americans save for retirement, provide Main Street businesses with capital to grow, and advise hardworking Americans how to create and preserve wealth. For the latest updates follow @AmerSecurities and learn more at


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