On Jan.16, 2024, Partner Kevin Edgar provided comments on behalf of the Equity Markets Association (EMA) regarding proposed Volume-Based Exchange Transaction Pricing for NMS Stocks in a letter to the U.S. Securities and Exchange Commission.
Edgar noted that EMA members are unified in their concerns regarding the proposal because it would “prohibit national securities exchanges from offering volume-based transaction pricing in connection with the execution of agency or riskless principal orders in NMS stocks,” which would ultimately damage the U.S. equity markets by undermining incentives that promote liquidity, among other concerns. He also stated that the commission relied on input from the Investors Exchange and the Healthy Markets Association when justifying its proposal but failed to solicit input from the EMA for consideration at the same time.