May 18, 2022

Nasdaq Unlisted Trading Privileges Plan Participants
Consolidated Quotation Plan Participants

Re: CTA and UTP/CQ Plans Odd Lot Quotation Proposal

Dear SIP Operating Committees:

The Securities Industry and Financial Markets Association (“SIFMA”)1 is pleased to submit this letter to you in response to your proposal for the Securities Information Processors (“SIPs”) to disseminate certain odd lot quotation data as ancillary information on the SIP data feeds (the “Proposal”).2 This is the second time the SIPs have requested comment letter feedback regarding the introduction of odd lots on the SIP, with the first occurring in October 2019.3 In our comment letter responding to that original 2019 request,4 we expressed support for the additional market transparency that odd lots would provide to market participants while recommending that, at least initially, display of odd lots to customers be optional and used for informational purposes only to allow regulators time to evaluate the impact of odd lot dissemination on best execution and Rule 611 of Regulation NMS (the “Order Protection Rule” or “OPR”).

At a high level, SIFMA’s views on the current proposal are similar to the ones we expressed on the 2019 proposal – namely, that we are supportive of adding odd lot quotation information to the SIP solely for transparency and informational purposes. Our support of the current proposal, however, is contingent on the SEC and FINRA affirmatively acknowledging that the addition of odd lot quotation information to the SIP would not change firms’ best

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s one million employees, we advocate on legislation, regulation and business policy affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit http://www.sifma.org.
2 See Proposal of the CTA and UTP Operating Committees Regarding Odd Lots on the SIPs (March 2022) https://www.ctaplan.com/publicdocs/ctaplan/CTA_Odd_Lots_Proposal_2022.pdf.
3 See Odd Lot Proposal (October 2019) https://www.ctaplan.com/publicdocs/CTA_Odd_Lots_Proposal.pdf.
4 https://www.theice.com/publicdocs/SIFMA_CL_on_CTA_and_UTP_Odd_Lot_Proposal_November_26_ 2019.pdf.