Partner Kevin Edgar submitted a second letter to the Securities and Exchange Commission regarding proposed Volume-Based Exchange Transaction Pricing for NMS Stocks and Regulation NMS: Minimum Pricing Increments, Access Fees and Transparency of Better Priced Orders on behalf of the Equity Markets Association. Dated Feb. 7, 2024, it is in response to a letter from J.W. Verret of the George Mason University Antonin Scalia Law School and refutes several misstatements and misrepresentations, while suggesting that the letter should not be taken into consideration for the purposes of the two rulemakings.
