Abstract of the Study Quoted Directly from the Study: "The regulatory debate concerning high frequency trading (HFT) emphasizes the importance of distinguishing different HFT strategies and their influence on market quality. Using unique data from NASDAQ OMX Stockholm, we are the first to empirically provide such a distinction for equity markets. Comparing the behavior of market making HFTs to opportunistic HFTs (arbitrage and momentum HFT strategies), we find that market makers constitute the lion's share of HFT trading volume (63‐72%) and limit order traffic (81‐86%). Furthermore, market

SIFMA and the Financial Services Roundtable submitted comments to the SEC declaring unwavering support for (i) the elimination of the prohibition against general solicitation and general advertising in certain offerings, and (ii) the SEC's decision not to prescribe specific steps to meet the requirement to take "reasonable steps to verify the purchasers of the securities are accredited investors". Separately, SIFMA requested that the SEC work with the CFTC for the purpose of encouraging the CFTC to amend its various rules relating to private pools, e.g., CFTC Rule 4.7, so as to allow such

SIFMA submitted the attached comments to the SEC expressing opposition to a BYX-proposed rule change to adopt a retail price improvement program. Among other things, SIFMA commented substantively on the proposal to favor retail investors over other investors, and procedurally on the fact that the rule was being approved by SEC Staff pursuant to delegated authority rather than by the SEC Commissioners. View comment letter here (links externally to SIFMA website).

SIFMA submitted the attached comments to the SEC regarding a proposed Nasdaq rule change to establish "benchmark orders" under NASDAQ Rule 4751(f). SIFMA urged the SEC to disapprove NASDAQ's proposed rule change. Lofchie Comment: This is actually a pretty interesting letter, as it argues that the order type proposed to be provided by Nasdaq is inherently a "broker-dealer" function rather than an "exchange" function. SIFMA argues, among other things, that if exchanges are performing broker-dealer functions, they ought not to benefit from limitations on their liability to others in the event of

NASAA has issued a request for comment on proposed changes to Model Rule 102(f)-3 under the Uniform Securities Act of 1956, and Model Rule 502(c) under the Uniform Securities Act of 2002 (the “performance fee model rules” or the “Model Rules”). These changes will conform these rules to the current exemption under SEC Advisers Act Rule 205-3 for performance fees charged to certain “qualified clients.#8221; Comments Due: December 10, 2012. Cross Reference(s): 1956 Model Rule with Proposed Revisions;2002 Model Rule with Proposed Revisions Parness Comment: These changes will be extremely helpful