The Securities Industry Association (SIA)* provides comments the Securities and Exchange Commission (SEC) on the pilot program for quoting of options in penny increments. While SIA strongly the call for such a program, SIA believes the SEC should consider several in connection with the adoption of a pilot program including: 1) the differing effects of penny quoting; 2) the importance of a true pilot program; and 3) consideration of related issues such as quote mitigation.

*SIFMA is the product of a merger between the Securities Industry Association (SIA) and The Bond Market Association (TBMA) in 2006.