On September 23, MFA submitted a letter to the SEC in general support of the SEC’s Proposal on order routing disclosures. MFA was pleased to see that the Proposal incorporated many comments from a joint letter MFA, ICI and SIFMA submitted in 2014. In the letter, MFA emphasized that the Proposal should create a minimum level of order routing disclosure and that it should not limit information available to investors or how they analyze best execution. In addition, our letter recommended that:
- A broker-dealer’s institutional customer order routing report should cover all of an institutional investor’s orders, rather than be limited to orders that are $200,000 or more.
- The SEC should provide a new or small broker-dealer with a de minimis exemption from the requirement to publish an aggregated institutional order handling report, but require such broker-dealer to provide individual institutional customer order routing reports upon request as per the Proposal.
- The Commission should provide a broker-dealer with greater flexibility in categorizing its order routing strategies for purposes of institutional customer reports, rather than report order routing via the narrowly defined terms: aggressive, neutral, or passive.