SIFMA Submits Comments to the SEC on Retail Orders, the Retail Liquidity Program, and Retail Member Organizations

SIFMA submitted comments to the SEC on proposals to allow participants to attest that "substantially all" orders submitted to the Retail Liquidity Program ("RLP" or the "Programs") will qualify as "Retail Orders." In the letter, SIFMA states that the proposed amendments represent a material and problematic departure from the Programs originally considered by the SEC.

The Programs each create a new class of market participants: Retail Member Organizations ("RMOs"). In order to qualify as an RMO, a participant is required to submit an attestation to the Exchange that "any" order flow submitted would qualify as a "Retail Order." These Programs were approved on a pilot basis by the SEC staff acting pursuant to delegated authority.

SIFMA is concerned that the "substantially all" standard proposed by the Exchanges is so vague that it could allow a material amount of non-retail order flow to qualify for the Programs.

Click here to view letter in full (links externally to SIFMA website).