Date: December 22, 2014
Issue: Letter to SEC regarding Tick Size Pilot Program
Filing Type: Regulatory
Description: The CCMC previously requested that the comment period for the Proposal be extended to ninety days, and we remain concerned that the condensed comment period the Commission has provided could lead to unintended consequences down the road.1 Nevertheless, the pilot program presents an opportunity for the Securities and Exchange Commission (“Commission”) to collect useful data and evidence regarding the trading environment for small capitalization stocks. Should the Commission decide to move forward and implement the pilot program, we believe that a next phase of this initiative would be warranted only if the pilot produced clear and unambiguous evidence showing that the widening of tick sizes fosters capital formation for small businesses, produces benefits for investors, and increases competition within the equity markets. The Commission should also clearly define and quantify the type of data it would need to see the pilot produce in order to move forward with a permanent widening of tick sizes for small companies.