FIA PTG presented a number of critical questions and concerns about the proposal, including the introduction of increased complexity and associated costs to the U.S. equity markets, inequitable discrimination among market participants, and lack of clarity around certain material provisions. FIA PTG particularly emphasized the negative impact ELO would have on displayed liquidity. Far from benefiting investors, Nasdaq’s ELO would reduce incentives for price discovery and price formation to the direct detriment of all market participants.
FIA PTG urged the SEC to reject ELO because of these concerns. At a minimum, FIA PTG requested more time for comments and feedback from Nasdaq to clarify many unclear aspects of the proposal.