On behalf of the Financial Information Services Division (FISD) of the Software & Information Industry Association (SIIA) requests that the Securities and Exchange Commission (the Commission) extend the implementation period for compliance with the round lot and odd lot information definitions originally adopted on December 9, 2020. While we appreciate the benefits that these changes will provide in terms of improved market transparency, for the reasons stated herein, implementation will present challenges and require tailored solutions that will take longer than 90 days to fully realize.
Requiring accelerated implementation of the new odd-lot and round lot definitions risks undermining the very real transparency benefits that these changes will provide. While the SEC is correct that these technical changes are similar to functions currently performed by securities information processors (SIPs), successful implementation of the changes will involve significant actions throughout the multiple links in the real-time market data distribution chain.
To accommodate the needs and advance full and successful implementation of the new round lot and odd-lot definitions, FISD requests that the Commission provide for a multi stakeholder industry consultation period following publication of the final rule to develop a coordinated plan for implementing the definitional changes proposed in the MDI adopting release and not adopt the 90-day period recommended in Regulation NMS.
Background on FISD and SIIA
FISD was established over thirty years ago to facilitate member thought leadership, education, networking, and the development of win-win solutions to common challenges facing the financial information industry. Our members – over 250 organizations worldwide – include all significant actors in the financial information ecosystem, including major global exchanges and securities markets; content creators and aggregators such as S&P, Moody’s, and Morningstar; data redistributors like Bloomberg and LSEG Refinitiv; and consumers of financial information including major global banks, investment management firms, and hedge funds. Given the diversity of interests in this community, FISD does not typically adopt or promote consensus positions on public policy issues.
FISD is part of SIIA, which is the principal trade association for companies in the business of information. SIIA’s membership of over 450 companies includes firms reflecting the broad and diverse landscape of digital content providers and users in academic publishing, education technology, and financial information, along with creators of software and platforms used by millions worldwide, and companies specializing in data analytics and information services.
