We can start with better transparency. The simple fact is that there are systemic issues with the creation of shares to borrow based on future volumes, failures to deliver, and shorting in general. While appreciated, and needed, the solutions to these do not lie in the resolution of transparency alone. Removing the capability to generate future transactions to borrow from, use for offsetting
In the interest of transparency and fairness to the market. I believe it is important to have regular and accurate information keeping and disclosure to encourage retail market participants into the market. Professional firms already have fast, accurate and bespoke trading software and information systems that provide them with a massive advantage in accurately determining price inefficiencies
INFORMATIONAL
Trading Obligations
SUGGESTED ROUTING
KEY TOPICS
Legal & Compliance
Senior Management
Trading & Market Making
Best Execution
Firm Quote Compliance
Locked/Crossed Markets
Executive Summary
As more derivative instruments overlay securities listed on The Nasdaq Stock Market ("Nasdaq") and more Nasdaq-listed securities are included
Market makers should consider the application of SEC Regulation M on market making activity where an issuer with no public market for its common stock is in the process of filing a registration statement and engages the market maker to file a Form 211 for quotation on the OTC Bulletin Board.<br/>
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Publication Date: March 20, 2025Interpretations are marked in blue background beneath the rule text to which they relate. 15c3-3 Customer protection — reserves and custody of securities.Except where otherwise noted, § 240.15c3-3 applies to a broker or dealer registered under section 15(b) of the Act (15 U.S.C. 78o(b)), including a broker or dealer also registered as a security-
SUGGESTED ROUTING
Senior Management
Institutional
Legal & Compliance
Systems
Trading
Executive Summary
On June 5, 1995, the NASD issued Special Notice to Members 95-43 (Special Notice) discussing the expansion of the Limit-Order Protection Interpretation (Interpretation) to Article III, Section 1 of the NASD Rules of Fair Practice that prohibits member firms from
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6100.
SUGGESTED ROUTING:*
Senior ManagementCorporate FinanceInternal AuditLegal & ComplianceResearchSyndicateTradingTraining*These are suggested departments only. Others may be appropriate for your firm.
The National Association of Securities Dealers, Inc., the New York Stock Exchange, Inc., and a committee of the Securities Industry Association have developed a joint memorandum that
SUGGESTED ROUTING
Senior Management Corporate Finance Legal & Compliance Syndicate
Executive Summary
On May 10, 1994, the Securities and Exchange Commission (SEC) approved amendments to Schedule E to the NASD By-Laws (Schedule E) that require compliance with its provisions if a member participating in a distribution of a public offering of debt or equity securities has a conflict
Testimony by Vice Chairman Stephen Luparello Before the Subcommittee on Securities, Insurance, and Investment
