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Articles filed under: Comment Letters & Viewpoints (20)

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KCG Comment Letter to SEC on CHX Liquidity Taking Access Delay

KCG is generally supportive of initiatives designed to encourage liquidity provision. We agree with CHX that the LTAD would encourage liquidity providers to make tighter and deeper markets on the Exchange, but we also acknowledge certain potential side effects highlighted by several commenters including that the speed bump might render CHX quotations somewhat less accessible.

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KCG Comment Letter to SEC on Securities Exchange Act Release 79431

KCG agrees with the numerous concerns raised by commenters and, therefore, respectfully opposes Nasdaq’s proposed rule change to establish the Third Party Connectivity Service on the following grounds:

It constitutes an access services fee for UTP data that has not been approved by the UTP Operating Committee; It benefits Nasdaq’s proprietary data over UTP data and is therefore anti- competitive; There is no indication that it is technically necessary; It raises conflict of interest concerns stemming from exchanges’ role as market data providers to market participants who are required by regulation to obtain it; and It contravenes the UTP SIP’s fundamental purpose of providing market participants with quality market data at relatively low cost.

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KCG Comment Letter to SEC on Disclosure of Order Handling Information

Requiring all broker-dealers to supply institutional customers with standardized information on execution quality and order routing will ensure the availability of order handling information that today only certain broker-dealers voluntarily provide to their institutional customers. Although we strongly support the policy goals underlying the Proposal, we believe certain modifications are necessary to ensure the proposed rule amendments actually achieve the Proposal’s objectives and supply institutional investors with meaningful order handling transparency.

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KCG Comment Letter to SEC on Options Auction Fee Structures

KCG recommends that the Commission disapprove the rule change because the fee structure proposed by the Exchange would establish a material fee differential among market participants that is inequitable, unfairly discriminatory, and unduly burdensome on competition. Moreover, we recommend the Commission conduct a broad review of the fee structures applied by all options exchanges to their auction mechanisms as the Exchange’s proposal is symptomatic of an industry-wide problem.

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KCG Comment Letter to SEC on Regulation of NMS Stock Alternative Trading Systems

KCG supports the Proposal’s fundamental objectives of enhancing operational transparency of NMS Stock ATSs and increasing awareness among market participants of potential conflicts of interest that ATS operators may encounter. We believe that requiring all NMS Stock ATSs to make uniform disclosure concerning their operations and potential conflicts of interest along with mandating that those disclosures be made public will empower market participants to make informed decisions about where to route their orders. We therefore endorse the policy goals underlying the Proposal and suggest certain limited modifications for improvements we believe are necessary to particular aspects of the proposed amendments.

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