MFA Comments to SEC on EDGA Asymmetric Speed Bump
August 2, 2019
On August 2, MFA submitted comments to the SEC raising concerns with the Cboe EDGA asymmetric speed bump proposal, designed to protect certain liquidity providers. In the letter, MFA raised concerns that an asymmetric speed bump would harm investors and violate securities law requirements that the rules of an exchange “not be designed to permit unfair discrimination between customers, issuers, brokers, or dealers”, “protect investors and the public interest” and to “not impose any burden on competition not necessary or appropriate”.
MFA also raised concerns that the Cboe EDGA proposal would introduce the need for SEC guidance on how firms should evaluate whether their broker-dealers provide best execution regarding the routing of quotes to an unprotected exchange compared to protected exchanges.
MFA urged the SEC to disapprove the Cboe EDGA asymmetric speed bump proposal.