Date: November 20, 2014
Issue: Tick Size Pilot Program
To: SEC
Filing Type: Regulatory
Description: We are writing to express our concern regarding the condensed time period in which comments may be received on the self-regulatory organization (“SRO”) proposed national market system (“NMS”) Plan to Implement a Tick Size Pilot Program (“Proposal”). The comment period, following publication in the Federal Register, is only 45 days long, which we believe is an insufficient amount of time given the technical nature of the proposal, and the diversity of stakeholders that have an interest in how the pilot program will be executed. We believe that the comment period should be extended to a minimum of 90 days so that stakeholders are able to provide the most robust and well-informed comments as possible, and to help avoid any unintended consequences that a 45-day comment period may not allow to be fully identified and vetted.