SIFMA provides comments to the Securities and Exchange Commission (SEC) on the New York Stock Exchange’s (NYSE) proposed Retail Liquidity Program, and the NYSE’s related request for exemptive relief from Rule 612(c) of Regulation NMS (the Sub-Penny Rule) under the Securities Exchange Act of 1934, SR-NYSE-2011-55.  The Program seeks to attract additional retail order flow via NYSE-listed securities while also providing price improvement through sub-penny pricing.  SIFMA believes that the Program and related request for an exemption from the prohibitions against sub-penny ranking and quoting under Regulation NMS, as well as the Program’s provisions for selective distribution of and access to quotes, raise various market structure concerns that require additional time to be considered before implementation.