Comment Letters/Testimony

• February 5, 2021
  Letter in Response to the FCA’s Consultation Paper on a New UK Prudential Regime for MiFID Investment Firms


• February 1, 2021:
  Letter in Response to the FTC's Proposal to Expand the Scope of the Application of the Hart-Scott Rodino Act


• January 11, 2021
  Letter in Response to ESMA’s Draft Guidelines on the MiFID II/MiFIR Obligations on Market Data


• November 12, 2020:
  Letter in Response to the SEC’s Publication of the New Consolidated Data Plan


• October 26, 2020:
  Letter in Response to IOSCO’s Consultation on Artificial Intelligence and Machine Learning


• October 1, 2020:
  Letter in Response to IOSCO’s Principles on Outsourcing Consultation Report


• September 28, 2020:
  Letter in Response to the SEC’s Proposed Rule on Reporting Threshold for Institutional Managers


• September 18, 2020:
  Letter in Response to the Financial Conduct Authority’s Discussion Paper on a New UK Prudential Regime for MiFID Investment Firms


• September 4, 2020:
  Letter in Response to European Banking Authority's Consultation Paper on Draft RTS Prudential Requirements for Investment Firms


• September 1, 2020:
  Letter in Response to ESMA Draft Guidelines on Outsourcing to Cloud Services Providers


• August 24, 2020:
  Letter in Response to the CFTC's Proposed Rulemaking Relating to Electronic Trading Risk Principles


• July 31, 2020:
  Letter in response to the Financial Stability Board's Guidance on financial resources to support CCP resolution and on the treatment of CCP equity in resolution


• July 29, 2020:
  Follow-Up Letter in Response to the SEC Statement on Market Structure Innovation for Thinly Traded Securities


• July 13, 2020:
  Letter in Response to CFTC's Proposal to Update Part 190 Bankruptcy Regulations


• May 26, 2020:
  Letter in Response to SEC’s Proposed Rule on Market Data Infrastructure


• May 01, 2020:
  Letter in Response to SEC's Proposed Rule on Use of Derivatives by Funds


• April 30, 2020:
  Letter in Response to SEC regarding the Global COVID-19 Pandemic


• February 28, 2020:
  Letter in Response to SEC Proposed Order related to the governance structure of the NMS plans responsible for the dissemination of U.S. equity market data through the consolidated tape


• February 25, 2020:
  Joint Letter in Response to the Basel Committee on Banking Supervision's Consultation on Credit Valuation Adjustment Risk


• December 20, 2019:
  Letter in Response to the SEC Statement on Market Structure Innovation for Thinly Traded Securities


• September 13, 2019:
  Letter in Response to the CFTC Proposal on DCO Notice Period for Clearing New Products


• August 26, 2019:
  Letter in Response to the SEC and CFTC Proposal on Customer Margin Rules Relating to Security Futures


• March 18, 2019:
  Letter in Response to the Federal Reserve, FDIC, and OCC Proposal to Adopt the Standardized Approach to Counterparty Credit Risk (SA-CCR)


• March 14, 2019:
  Letter in Response to the CFTC Proposal on Swap Execution Facilities and Trade Execution Requirements


• February 01, 2019:
  Letter in Response to IOSCO's Consultation on Leverage in Funds


• January 16, 2019:
  Letter in Response to the Basel Committee on Banking Supervision's consultation on the Leverage Ratio's Treatment of Client Cleared Derivatives


• October 01, 2018:
  Letter in Response to SEC's Proposal to Permit Certain ETFs to Operate Without Obtaining an Exemptive Order


• September 28, 2018:
  Second Letter in Response to SEC's Proposed Transaction Fee Pilot for NMS Stocks


• September 7, 2018:
  Letter in Response to the Financial Stability Board, Basel Committee on Banking Supervision, Committee on Payments and Market Infrastructures, and International Organization of Securities Commissions Consultation on Incentives to Centrally Clear Over-the-counter (OTC) Derivatives


• June 04, 2018:
  Joint Letter with SIFMA and The STA on Options Market Structure


• May 25, 2018:
  Letter in Response to SEC's Proposed Transaction Fee Pilot for NMS Stocks


• March 23, 2018:
  Letter in Response to SEC Staff Letter: Engaging on Fund Innovation and Cryptocurrency-Related Holdings


• February 14, 2018:
  Statement for the Record, Capital Markets, Securities, and Investment Subcommittee hearing entitled "Legislative Proposals Concerning Derivatives"


• November 22, 2017:
  Letter in Response to FINRA's Regulatory Notice 17-14 Request for Comments Regarding FINRA Rules Impacting Capital Formation


• October 13, 2017:
  Joint Letter on EMSAC Recommendation for an Access Fee Pilot


• June 27, 2017:
  Testimony of Chris Concannon before the Subcommittee on Capital Markets, Securities and Investment - U.S. House Committee on Financial Services - Hearing entitled "U.S. Equity Market Structure Part I: A Review of the Evolution of Today's Equity Market Structure and How We Got Here"


• May 1, 2017:
  Letter in Response to CFTC's Regulation Automated Trading Proposal


• April 24, 2017:
  Letter in Response to AMEX's Speedbump Proposal


• September 23, 2016:
  Joint Letter in Response to SEC's Proposed Amendment to SEC Rule 15b9-1


• July 21, 2016:
  Letter on SEC's Consolidated Audit Trail (CAT) Proposal


• July 6, 2016:
  Joint Letter in Response to the Basel Committee on Banking Supervision Consultation on Revisions to the Basel III Leverage Ratio Framework


• July 1, 2016:
  Letter to the SEC Regarding Semi-transparent ETFs


• June 7, 2016:
  Testimony of Edward Provost Before the Illinois House Revenue and Finance Committee and the Illinois Senate Revenue Committee Regarding a Proposed Financial Transaction Tax


• March 31, 2016:
  Letter in Response to SEC Proposed Rule 18F-4 (Use of Derivatives)


• March 16, 2016:
  Letter in Response to CFTC's Proposed Regulation Automated Trading


• March 01, 2016:
  Letter in Response to SEC's Proposed Amendments to Regulation ATS


• February 10, 2016:
  Letter to Members of the House Financial Services Committee Regarding NMS Plan Governance


• January 28, 2016:
  Second Letter to SEC's Equity Market Structure Advisory Committee


• January 28, 2016:
  Letter in Response to Federal Reserve Board's Total Loss-Absorbing Capacity (T-LAC) Proposal


• January 14, 2016:
  Letter in Response to SEC's Request for Comments on Exchange-Traded Products


• October 27, 2015:
  Letter to the Basel Committee on Banking Supervision, Financial Stability Board and European Commission Regarding the Unintended Consequences of the Leverage Ratio


• September 8, 2015:
  Letter in Response to SEC's in Response to Request for Comments on Exchange-Traded Products


• July 20, 2015:
  Letter in Response to Department of Labor's Fiduciary and BIC Exemption Proposals


• June 10, 2015:
  Letter in Response to SEC's Proposed Amendments to SEC Rule 15b9-1


• May 11, 2015:
  Letter to SEC's Equity Market Structure Advisory Committee


• October 2, 2014:
  Letter to the SEC Regarding Copycat OTC Derivatives