Comment Letter to SEC on FINRA Rulemakings Regarding the Imposition of Trading Halts by SROs

MFA filed a comment letter with the SEC in response to coordinated rule proposals from FINRA and other SROs that would amend SRO rules regarding market-wide circuit breakers. In our letter, we expressed our general support for the proposed changes to implement market-wide trading halts based on declines of 7%, 13% and 20%, respectively, in the S&P 500 Index. We also expressed support for extending the period during which Level 1 and Level 2 Declines would trigger a trading halt from 2:30 pm to 3:25 pm. Finally, we encouraged the SROs to amend the proposed trading halts to require a trading halt until the next trading day in the event there is a Level 2 Decline (13%) in the S&P 500 Index after the general cut-off time of 3:25 pm.