KEY COMMUNICATIONS WITH REGULATORS, CONGRESS, AND THE ADMINISTRATION:
Healthy Markets regularly submits comment letters on regulatory filings and proposals. Here are the most recent -
HMA writes to the Commodity Futures Trading Commission to perform its statutory obligation to ensure rules by designated contract markets (DCMs) comply with the Commodity Exchange Act and Commission rules.
HMA writes to the Securities and Exchange Commission to offer our strong support for the Data Standards Proposal, which would implement the mandates of the Financial Data Transparency Act of 2022.
HMA petitions the Securities and Exchange Commission urging the Commission to immediately revise the Consolidated Audit Trail (CAT) structure, governance and funding so that this essential tool may better protect the stability and integrity of the US capital markets.
HMA comments to the Securities and Exchange Commission to supplement our past support for shortening the time period within which trades in corporate bonds, agency debt securities, asset-backed securities, and some agency pass-through mortgage-backed securities would have to be reported to FINRA’s TRACE.
HMA comments to the Securities and Exchange Commission urging the Commission to suspend a filing by the CBOE family of exchanges and its Sales Value Fee Filings and initiate proceedings to disapprove them.
HMA comments to the Securities and Exchange Commission regarding the SEC suspending (for the second time) a series of CBOE family exchange filings that increase connectivity costs for consumers.
HMA comments to the Securities and Exchange Commission regarding the application by 24X to become a registered stock exchange.
HMA offers a statement for the record to the June 27, 2024 hearing by the House Financial Services Subcommittee on Capital Markets entitled “Solutions in Search of a Problem: Chair Gensler’s Equity Market Structure Reforms.”
HMA comments to the Securities and Exchange Commission regarding the evergreen nature of instantly effective filings that were previously suspended by the Commission.
HMA comments to the Securities and Exchange Commission regarding a proposal by the Nasdaq family of exchanges on a filing to charge cabinet fees.
HMA comments to the Securities and Exchange Commission regarding a proposal by the Nasdaq family of exchanges to tie market data to exchange fees and rebates.
HMA comments to the Securities and Exchange Commission regarding a proposal by the CBOE exchange to exclude its order and execution management products from Commission oversight and having to comply with the obligations imposed on exchanges by the Securities Exchange Act of 1934.
HMA comments to the Securities and Exchange Commission regarding a proposal by the Nasdaq family of exchange to offer select rebate incentives to certain customers.
HMA comments to the Securities and Exchange Commission to express support for the TRACE Reporting Time Proposal, which would generally shorten the time period within which trades in corporate bonds, agency debt securities, asset-backed securities, and some agency pass-through mortgage-backed securities from 15 minutes to 1 minute.
HMA together with the American Securities Association comments on the SEC's recent proposal to address discriminatory Tier Pricing for equity securities on US Stock Exchanges.
HMA comments again to the SEC regarding duplicative filings made by the CBOE family of exchanges to raise market data port fees.
HMA comments to the SEC regarding the staff action approving Intelligent Cross into the ADF which has been called up for reconsideration by the full Commission
HMA comments to the SEC regarding a filing by CBOE to raise port fees which was suspended by the SEC.
HMA petitions the Securities and Exchange Commission to timely address the subsequently vacated exemptive order related to SPIKES Futures; and to establish clear, consistent, and transparent procedures for requests for exemptive or no-action relief.
HMA comments to the Securities and Exchange Commission on its long-overdue reconsideration of certain now-common discriminatory practices in exchange pricing.
HMA comments to FINRA regarding its proposal to require brokers to publish execution quality on their website.
HMA comments to the Securities and Exchange Commission regarding the regulation of Market Data collected and disseminated by Registered Clearing
Agencies and Their affiliates.
HMA comments to the Securities and Exchange Commission on the two tiered pricing filings by the Cboe family of exchanges, which were suspended by the Commission.
HMA in conjunction with the CFA Institute and Council of Institutional Investors write jointly to congress to express strong opposition to H.R. 2622 which would codify the SIFMA MiFID II no action letter.
HMA writes to the House Financial Services Committee to express opposition to H.R. 2622, which claims to amend the Investment Advisers Act of 1940 to codify certain Securities and Exchange Commission no-action letters that exclude brokers and dealers compensated for certain research services from the definition of investment adviser, and for other purposes.
HMA comments to the Securities and Exchange Commission on the seventh MEMX market data filing.
Read HMA's letter commenting on the four Securities and Exchange Commission equity proposals.
HMA in conjunction with the CFA Institute and Council of Institutional Investors write jointly to urge the Securities and Exchange Commission to allow the SIFMA No-Action letter on MiFID II expire and to promote investor choice.
HMA supplements comments to the SEC regarding a filing by FINRA to add ATS Intelligent Cross to the Alternative Display Facility.
HMA submits testimony to the Legislative hearing Exploring Reforms to Make Our Public Markets Attractive for Small and Emerging Companies Raising Capital pursuant to discussion draft legislation noticed in connection with the hearing on MiFID no action reforms.
HMA comments to the Securities and Exchange Commission on its Open-End Fund Liquidity Risk Management Programs and Swing Pricing; Form N–PORT Reporting rule proposal.
HMA comments to the Securities and Exchange Commission on the sixth market data filing by the MEMX exchange.
HMA supplement our prior letters to the Securities and Exchange Commission regarding the now remanded Commission approval of FINRA’s rule to establish a corporate bond reference data service.
HMA comments to the SEC regarding a filing by FINRA to add ATS Intelligent Cross to the Alternative Display Facility.
HMA supplements comments to the SEC regarding Private Fund Advisers and documentation of Registered Investment Adviser Compliance Reviews.
HMA comments to the SEC on the fifth market data filing by MEMX.
HMA supplements prior letters to the Commission on potential reforms to routing incentives and transaction pricing fees.
HMA supplements prior letters to the Commission regarding the now remanded Commission approval of FINRA’s rule to establish a corporate bond reference data service.
HMA offers a Written Statement in connection with the Senate Agriculture Committee’s September 15, 2022 hearing on S.4760, the Digital Commodities Consumer Protection Act.
Yet again, Healthy Markets Association comments to the Securities and Exchange Commission regarding the 7th immediatly effective MEMX exchange filing to charge for Connectivity.
The Healthy Markets Association sends a letter to Treasury Secretary Janet Yellen to urge the Department of the Treasury to work with the Securities and Exchange Commission (“SEC”) and other regulators to adopt rules and guidance to enhance the stability, integrity, and oversight of the markets for US Treasury Securities.
The Healthy Markets Association sends a letter to Senator Jack Reed in support of his legislation regarding the Private Markets Transparency and Accountability Act.
The Healthy Markets Association comments to the SEC to supplement our January 2022 letter regarding the application of Rule 15c2-11 to trading in fixed income securities.
The Healthy Markets Association writes to urge FINRA to finalize its Proposal to shorten the period within which brokers must report transactions in many TRACE-Eligible Securities from fifteen minutes to one minute.
Healthy Markets Association again comments to the Securities and Exchange Commission regarding recent MEMX exchange filings to charge for Market Data and Connectivity.
Healthy Markets Association together with the CFA Institute write to urge the Commission to propose rules or guidance to enhance oversight of third parties that provide investment advisory services.
Healthy Markets comments to the U.S. Securities and Exchange Commission regarding a filing by MEMX to revert from faster data feeds to slower data feeds.
Healthy Markets joins a broad coalition of leading consumer and investor advocates to urge the U.S. Securities and Exchange Commission (SEC) to revise its self-regulatory organization (SRO) rule and fee change filing processes regarding national securities exchanges to ensure that fee filings comply with the Securities Exchange Act of 1934 and Commission rules to better protect investors and other market participants.
Healthy Markets comments to the Securities Information Processor Operating Committees for the CTA and UTP Plans to once again urge the
Committees to add odd lot quotations to the Plans without further delay.
Healthy Markets comments to the Securities and Exchange Commission regarding recent MEMX exchange filings to charge for Market Data and Connectivity.
Healthy Markets comments on Securities and Exchange Commission rule making proposal regarding amendments to Exchange Act Rule 3b-16 on the definition of “Exchange”; Regulation ATS for ATSs that Trade U.S. Government Securities, NMS Stocks, and other securities; Regulation SCI for ATSs that trade U.S. Treasury securities and Agency securities.
Healthy Markets supplement comments on three Securities and Exchange Commission proposals to promote transparency and market efficiencies by modernizing the reporting of beneficial ownership information.
Healthy Markets offers comments to the SEC on Research Payment Practices and urges the SEC to allow for the Expiration of SIFMA No-Action Letter re MiFID II Implementation.
Healthy Markets offers comments on the Securities and Exchange Commission's proposal to better protect investors, as well as promote transparency and market efficiencies in the private fund markets.
Healthy Markets offer comments on the Securities and Exchange Commission's proposal to revise rules on the operation of money market funds.
Healthy Markets offer comments on the Commission’s
proposal to promote transparency and market efficiencies by modernizing the reporting of beneficial ownership information.
Healthy Markets submits comments on the Commission’s proposal to promote transparency and market efficiencies in the securities lending markets.
Healthy Markets submits comments to the SEC regarding three SRO filings.
Healthy Markets submits comments to the SEC regarding amendments to SEC Rule 15c2-11.
Healthy Markets submits comments to the SEC regarding Equity market structure.
Healthy Markets submits comments to the SEC regarding Treasury market structure.
Healthy Markets submits a petition and comments on improvements to the SRO filing process.
Healthy Markets submits a petition and comments on improvements to the SRO filing process.
Healthy Markets submits an amicus brief in support of Bloomberg LP to against the SEC who approved FINRA to establish a corporate bond reference data service.
Healthy Markets submits comments to the Securities and Exchange Commission on Enviromental related issues and climate associated disclosures.
Testimony of Healthy Markets Executive Director Tyler Gellasch before the Securities and Exchange Commission Investor Advisory Committee meeting.
Healthy Markets comments to the SEC regarding the CBOE exchange volatility products.
Healthy Markets welcomes SEC Chairman Gary Gensler and offers suggestions to continue improving the US capital markets, as well as the operations of your new agency.
Healthy Markets offers comments in response to the Commission’s release of the President’s Working Group on Financial Markets, Overview of Recent Events and Potential Reform Options for Money Market Funds.
Healthy Markets submits this Amicus brief to the US District Court arguing the merits of the IEX D-Limit order in a suit that was brought by Citadel.
Healthy Markets submits comments to the Securities and Exchange Commission objecting to Cboe’s efforts to limit its exchanges’ customers’ rights to recourse for past and future billing errors.
Healthy Markets submits comments to the Securities and Exchange Commission to enhance and adopt revisions to Regulation ATS and Regulation SCI for government securities ATSs.
Healthy Markets submits comments to the House Financial Services Committee for the hearing on February 18th entitled "Game Stopped? Who Wins and Loses When Short Sellers, Social Media, and Retail Investors Collide."
Healthy Markets joined a coalition of trade groups as the Biden-Harris Administration prepares to request critical economic stimulus legislation
from Congress, urging the Administration to stop any legislation in financial services or amendments to weaken the federal securities laws or exempt companies from those laws.
Healthy Markets, comments to the CFTC regarding a recent market data historical pricing increase imposed by the CME Futures exchange.
Healthy Markets, comments to the SEC on the Proposed Exemptive Order Granting Conditional Exemption from the Broker Registration Requirements of Section 15(a) of the Securities Exchange Act.
Together, Healthy Markets, The Council of Institutional Investors and the CFA Institute submit comments to the SEC regarding its proposed fund disclosures enhancements.
Healthy Markets submits comments to the SEC regarding the 7th filing by CBOE to raise connectivity fees.
Healthy Markets offers comments to the Ontario Securities Commission regarding the Capital Markets Modernization Taskforce Consultation Report.
Healthy Markets comments to the SEC regarding a proposal by the SEC on Reporting Thresholds for Institutional Investment Managers under 13F.
Healthy Markets supplements comments to the SEC regarding a proposal which seeks to modernize some aspects of the public market data stream.
Healthy Markets comments to the SEC regarding a proposal which seeks to modernize some aspects of the public market data stream.
Healthy Markets comments to the CFTC regarding a proposal which seeks to (1) implement a uniform 48-hour delay in reporting of all block trades, and (2) modify the definition of block trades.
Healthy Markets supplements comments to the SEC regarding a proposal by IEX to institute a new order-type called D-Limit.
Healthy Markets comments to the SEC on the CBOE exchange filing which seeks to increase connectivity fees.
Healthy Markets comments on Nasdaq's proposal to eliminate Unlisted Trading Priviledges via the SEC's inviation for exchanges to submit innovative proposals for thinly traded securities.
Healthy Markets comments to the CFTC on a proposal to implement a uniform 48-hour delay in
reporting of all block trades, and modify the definition of block trades.
Healthy Markets comments on proposals to modify the definition of an “accredited investor” and other efforts to modify the exemptions and exceptions to the registration and reporting requirements of the federal securities laws
Healthy Markets again submits comments to the SEC regarding a a second immediatly effective filing by NYSE National to establish fees for the NYSE National Integrated Market Data Feed.
Healthy Markets comments to the SEC regarding an immediatly effective filing by NYSE family of exchanges to establish new wireless connectivity fee offerings.
Healthy Markets comments to the CFTC on a proposal to prohibit the practice of post-trade name give-up on swaps that are anonymously executed on SEFs that are intended to be cleared.
Healthy Markets submits comments to the SEC regarding a filing by NMS Plan participants to develop a new data plan, enhance conflict disclosures and adopt confidentiality rules.
Healthy Markets submits comments to the SEC a proposal by IEX to institute a new order-type called D-Limit.
Healthy Markets submits comments to the SEC regarding an immediatly effective filing by NYSE National to establish fees for the NYSE National Integrated Market Data Feed.
Healthy Markets submits comments to the SEC regarding a proposal to provide revisions to market data plans under Regulation NMS.
Healthy Markets submits comments to the SEC regarding its proposal to remove immediate effectiveness from NMS Rule filings.
Healthy Markets submits comments regarding a filing by CBOE to link market data fees to volume.
Healthy Markets Executive Director Tyler Gellasch testifies before the SEC's Investor Advisory Committee on enhancing public markets. In the following video Mr. Gellasch's testimony begins at 3:01:22
Healthy Markets comments to the CTA/UTP plan operators request for comments regarding the inclusion of odd lots into the Securities Information Processor
Healthy Markets supplements comments regarding a FINRA proposal on Corporate Bond data.
Healthy Markets submits second comment letter to the SEC regarding a proposal by CBOE EDGA to introduce an asymmetric time delay on its market.
Healthy Markets comments to the SEC regarding its concept release on the harmonization of securities offering exemptions.
Healthy Market submits testimony to the House Financial Services Committee on the Public Versus Private market debate.
Healthy Market comments to the SEC regarding industry pushback to seek an additional extension to Rule 606 compliance.
Healthy Market comments on proposals by the BOX and MIAX exchanges regarding connectivity costs.
Healthy Market supplements comments to the SEC on a FINRA proposed Corporate Bond New Issue Reference Data Service.
Healthy Market comments on an SEC suspension order for a Cboe proposal to institute a Trading Rights Fee.
Healthy Market comments to the SEC on a Cboe proposal to institute an asymmetric delay on its EDGA exchange.
Healthy Market joins Council of Institutional Investors and CFA Institute in calling on the SEC to enhance disclosures of research practices.
Healthy Market comments on FINRA proposed change to establish a Pilot Program to study recommended changes to Corporate Bond Block Trade dissemination.
Healthy Market comments on FINRA proposed change to establish a Corporate Bond New Issue Reference Data Service.
Healthy Market supplements comments to the SEC regarding MiFID.
Healthy Market submits comment letter regarding MIAX Exchange connectivity fees (Release No. 34-85318).
Healthy Market submits comments to the SEC Investor Advisory Committee regarding MiFID II.
Healthy Market submits comments and Testimony to the SEC Investor Advisory Committee regarding the regulation of Exchanges.
Healthy Market submits third comment letter regarding BOX Exchange connectivity fees (Release No. 34-85201).
Healthy Market submits comments regarding odd lots to the SEC's Market Data and Market Access Rountable (Release No. 4-729).
Healthy Market submits third comment letter to SEC Chair Jay Clayton on issues related to MiFIDII.
Letter to Manisha Kimmel, Senior Policy Advisor, Securities and Exchange Commission regarding the Consolidated Audit Trail.
Letter to U.S. House Committee on Financial Services Chairwoman Maxine Waters and Ranking Member Patrick McHenry supporting H.R. 624
Letter to the Securities and Exchange Commission regarding BOX connectivity filings and related suspension orders.
Letter to the Securities and Exchange Commission Chairman Jay Clayton regarding recommendations on MiFID II and the SIFMA No-Action letter.
Letter to the Securities and Exchange Commission regarding NYSE's proposal to make the Retail Liquidity Pilot Program permanent.
Letter to the Securities and Exchange Commission Trading & Markets Director Brett Redfrearn with recommendations to bolster Order Handling Release
Letter to the Securities and Exchange Commission regarding Cboe EDGA pricing changes. Release No. 34-84599; File No. SR-CboeEDGA-2018-017
Letter to the Securities and Exchange Commission regarding NYSE Tier pricing filing. Release No. 34-84444; File No. SR-NYSE-2018-49
Statement and Comments to the Securities and Exchange Commission at the Market Data Roundtable.
Letter to the Securities and Exchange Commission regarding NYSE Tier pricing filing. Release No. 34-84097; File No. SR-NYSE-2018-40
Letter to the Securities and Exchange Commission regarding best execution standards for investment advisers. Release No. IA-4889; File No. S7-09-18
Letter to the Securities and Exchange Commission regarding a filing by CBOE to increase physical connectivity fees up to 25%.
Letter to the Securities and Exchange Commission regarding its transaction fee pilot proposal.
Letter to the Securities and Exchange Commission regarding TRACE reporting of treasuries.
Letter to the Securities and Exchange Commission regarding its transaction fee pilot proposal.
Testimony before the House Financial Services Committee, Subcommittee on Capital Markets, Securities, and Investment.
Letter to the Securities and Exchange Commission regarding market data reforms.
Letter to SEC Chairman Clayton, regarding implementation of MiFID II and impact on payments for research.
Letter to SEC Chairman Clayton et al, regarding market data reforms.
Testimony of Tyler Gellasch to the House Financial Services Committee on the Consolidated Audit Trail.
Letter to House Financial Services Committee Chairman Jeb Hensarling and Ranking Member Maxine Waters regarding capital formation bills, delays to the consolidated audit trail, and market structure reforms.
Letter to SEC Chairman Clayton regarding implementation of MiFID II and impact on payments for research.
Letter to Treasury Secretary regarding Presidential Report on Capital Markets Reforms.
Letter and statement to the House Financial Services Committee, Subcommittee on Capital Markets, Securities, and Investment, Hearing “U.S. Equity Market Structure Part I: A Review of the Evolution of Today’s Equity Market Structure and How We Got Here."
Comment letter to the SEC Chairman Clayton and SEC's Equity Market Structure Advisory Committee regarding market structure reforms and risks of "capital formation reforms".
Comment letter to the SEC's Equity Market Structure Advisory Committee regarding, Rule 611, Order Disclosure, NMS Plans and incentives.
Comment letter to the Securities and Exchange Commission regarding the Chicago Stock Exchange proposal to adopt a LEAD access delay.
Comment letter to the Securities and Exchange Commission regarding the Chicago Stock Exchange proposal to adopt a LEAD access delay.
Comment letter to the Securities and Exchange Commission regarding Order Handling Disclosure rules.
Comment letter to Securities and Exchange Commission regarding an Access Fee Pilot program.
Comment letter to the Securities and Exchange Commission regarding the CHX proposal for an access delay.
Comment letter to the Securities and Exchange Commission regarding the new proposal for Order Handling Disclosure rules.
Testimony before the SEC Equity Market Structure Advisory Committee regarding reforms to SEC Rules 605 and 606.
Proposal to SEC's Equity Market Structure Advisory Committee regarding NMS Market Making Standards.
Comment letter to the Securities and Exchange Commission regarding the proposed interpretation of "Automated Quotation."
Comment letter to the Securities and Exchange Commission regarding the synchronization tolerance for computer clocks.
Comment letter to the Securities and Exchange Commission regarding the Regulation of NMS Stock ATSs.
Comment letter to the Securities and Exchange Commission regarding IEX's Form 1 application for registration as an exchange.
Comment letter to the Securities and Exchange Commission regarding the composition and governance of the Equity Market Structure Advisory Committee.
Comment letter to the Financial Industry Regulatory Authority regarding clock synchronization.
Comment letter to the Securities and Exchange Commission regarding the Tick Size Pilot.
Comment letter to the Securities and Exchange Commission regarding accelerating data-driven regulation.