Broker-Dealers

"The proposed rule provides a handy checklist for SEC examiners and enforcement attorneys, but it does not foster brokers’ exercise of judgment to achieve what ...

"Redundant regulation will increase costs without corresponding benefits to investors"

"The Commission’s analysis about the forgone price improvement, the so-called 'competitive shortfall,' ignores the fact that the current market is not static"

"The proposing release acknowledges that wholesalers do generally provide some price improvement relative to national securities exchanges. So what is the need for the proposed rule, ...

"The proposal would implement a modernized, more-flexible definition for round lots"

"The Commission may need to give further thought to its theory of competition in this area of our regulations"

"I am open to alternative ways to update these requirements and the subject matter deserves further exploration through the public comment process"

"The proposal appears to be a reasonable attempt to address deficiencies of the current Rule 605, but the Commission will still need input from market ...

"The changes to the minimum tick size make updating the access fees more urgent, because if the fees stay the same while the minimum tick ...

"While I do not necessarily agree with all parts of the proposal, it will commence a healthy process of public comment necessary to appropriately improve ...