Letters

Proposal to Identify OTC Trades Reported as “Out of Sequence”

Summary

SIFMA submitted comments to the Financial Industry Regulatory Authority (FINRA) in response to FINRA’s requests for comment on a proposal to identify over-the-counter (OTC) trades reported more than two seconds following trade execution as “out of sequence” and not last sale eligible for public dissemination purposes. The proposal is one of seven FINRA initiatives relating to equity market structure and automated trading activities.

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