Earlier today, the STA filed its comment letter on the SEC's Proposed Amendments to Regulation ATS. On behalf of the STA Board and 24 affiliate organizations, I would like to thank the SEC and its staff for writing an extensive and highly detailed proposal that obviously entailed great amounts of research and due diligence. 

Like many of you, I believe in statements which go along the lines that transparency is the best of disinfectants. But, I do not believe 100% transparency is a goal any industry should strive for as there are costs, both explicit and implicit to the producer and receiver of the information.  To be clear, the STA is very supportive of SEC's Proposal and its worthy policy goal. We believe that they have identified the data points that market participants need for achieving operational transparency on how ATSs operate. However, we are concerned that the amounts of data produced will distract market participants and make it extremely difficult to differentiate between data that is important and that which is not. Our letter highlights this point and we do offer recommendations.  We hope that after the Commission processes all of the industry's comment letters they will find ways to focus and target on what is really required to achieve the policy goal.