MFA Submits Response to the SEC’s Proposed Transaction Fee Pilot

May 15, 2018

From: MFA

To:

Ms. Brent J. Fields, Secretary, U.S. Securities and Exchange Commission

On May 15, MFA submitted comments in response to the SEC’s proposed Transaction Fee Pilot.  MFA’s letter is generally supportive of the SEC’s Transaction Fee Pilot as proposed, and emphasizes the following points:

  • MFA supports the SEC’s approach to assess market practices through a pilot program in order to make data-driven determinations; and urges the SEC to remain focused on the long-term interests of investors as it evaluates the Pilot.
  • MFA supports a Pilot designed in as simple and straight-forward a manner as possible.  The Pilot should remain largely as proposed; specifically, it should be limited to equity exchanges, cover securities of all market capitalizations, exclude non-exchange trading centers; and exclude a trade-at component.
  • MFA members preliminarily believe that the current $0.0030 access fee cap is too high and has become outdated since the SEC’s adoption of Regulation NMS in 2005.  MFA supports testing the impact of lower fee caps and of prohibiting rebates generally, and believe that the Commission should consider permanently lowering the access fee under Rule 610(c).

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