FIA PTG sent a letter to the SEC today recommending a comprehensive reform of equity market structure and a repeal of Reg NMS Rule 610.d (the Access Rule) and Rule 611 (the Order Protection Rule). For the past few years, FIA PTG has been advocating for comprehensive reform of equity market structure and calling for a review of the Access Rule and Order Protection Rule.
FIA PTG noted that the need to act on market structure reform has become more pressing with the proliferation of speedbumps and other latency mechanisms.
"While we continue to support a comprehensive, data-driven review of Reg NMS and equity market structure, with the opportunity for public input, we recognize the magnitude of this undertaking," the letter noted. "In the interim, we believe the elimination of both Rules 610.d and 611, along with the modernization of the best execution requirements, would simplify the markets in meaningful ways and provide other important benefits for the investing public."
FIA PTG explained that beginning market structure reform with Rule 610.d and Rule 611 would provide meaningful simplification, reduce the proliferation of order types, reduce market fragmentation, and enhance investor confidence. With these improvements in place, the market will be stronger and healthier during the time it takes to complete a holistic market structure review.
"We appreciate that other market participants recognize the need for substantive reform and have begun to echo our calls for a repeal of the Order Protection Rule," the letter said. "We are hopeful that the Commission will give our comments serious consideration and engage with FIA PTG and other market participants on near-term steps that can be taken to address market structure reform."