SIFMA provides comments to the Securities and Exchange Commission (SEC) requesting an exemption under Rule 611(d) of Regulation NMS under the Securities Exchange Act of 1934 for non-convertible preferred securities.  The proposed exemption, like the various exceptions to the Order Protection Rule (OPR) adopted by the SEC, is “narrowly drawn to prevent abuse,” while facilitating the continued efficient trading of preferred securities by investors and other market participants. As a result, the proposed exemption is “appropriate in the public interest, and is consistent with the protection of investors” and should be granted by the SEC.