SUPERMONTAGE DOWNLOAD

However, the Commission emphasizes that this exemption will terminate if and when SuperMontage accepts orders in the display that are not controlled by or represented by market centers that have a reporting obligation under the Rule for such orders. Instinet recognizes the Commission's interest in disentangling Nasdaq's matching facility from the regulatory benefits Nasdaq has acquired in its years of operating as an arm of a self-regulatory body and exclusive securities information processor. Part I of this letter discusses the continuing involuntary nature of SuperMontage and the steps that should be taken to separate the SuperMontage matching facility from the NASD and the exclusive securities information processor for Nasdaq stocks. In addition, Nasdaq has requested an exemption from reporting on all orders that another market center displays in SuperMontage because the other market center is already required under the Rule to publish a report of those orders. The non-directed order process will be the default execution process for marketable orders entered into SuperMontage.

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supermontage

We understand that Nasdaq seeks to wupermontage response times from the moment when an order leaves the "outer edge" of Nasdaq's system to the time of its return to that system. The only effective means of preserving investor standing on Nasdaq is adoption of a SuperMontage proposal that rejects biased order interaction priorities and precludes market makers from stepping ahead of investor orders on ECNs.

An independent and neutral third party should operate the exclusive securities information processor for Nasdaq stocks - in an independent and neutral manner.

Instinet Corporation "Instinet" 1 appreciates the opportunity to offer its comments to the Securities and Exchange Commission the "Commission" on Amendment No. In addition, SuperMontage will allow market centers to enter into and maintain in the system multiple quotes and orders at the same or different price levels that are either attributed to the market center i.

Supermontage - Wikipedia

Second, on November 19,the Commission approved Amendment No. As noted in our prior comment letters, these access fees generally are less than the minimum increment in Nasdaq and frequently are less than the price improvement offered by ECNs. The Rule has been in effect for all national market system securities since October 1, See Instinet comment letter dated September 14, at Part III speaks to certain operational issues raised by the proposal in its amended form.

In Instinet's view, however, the Commission should not allow SuperMontage to move forward until a neutral and viable alternative facility for all Nasdaq stocks has become a reality. The securities information processor must have sufficient technological resources to permit market centers utilizing its facilities to satisfy applicable regulatory and related requirements.

Notably, formation of a securities information processor along the lines described above 8 - a processor that does not favor Nasdaq or any other comparable exchange, ECN or other market center - would lead to establishment of the neutral securities information processor envisioned by Congress at the time of the Securities Act Amendments of In addition, the Letter states that any Nasdaq member is free to offer a competing execution service, and may even use the Nasdaq service as one of its options.

These requirements include technologically up-to-date facilities for order display, order routing and trade reporting as mandated by Commission rules.

At the same time, orders that SuperSoes Participants receive through SelectNet from exchanges that trade Nasdaq securities pursuant to unlisted trading privileges were exempted from the Rule. Part II describes the manner in which the new order matching priorities of Amendment No.

Retrieved from " https: See Instinet comment letter dated February 16, and Instinet comment letter dated September 14, Only an unbiased body, such as the Commission, should have this power. Unless the market center to which a directed order is supermontahe sent has agreed to accept directed liability orders, a directed order must be a non-liability order and must be designated as: We also consider it essential that the Commission, before approving SuperMontage, assess the substantive and procedural implications supermntage a reported "agreement" between Bloomberg Tradebook LLC and Nasdaq.

Nasdaq is of the view that it should be obligated to report under Rule 11Ac on all orders that it receives through the non-directed order process. However, the Commission does agree that covered orders displayed in SuperMontage already should be subject to reporting under the Rule by the market center displaying the order.

Standing is significant to investors because, when an investor places an order in the Nasdaq market, the investor is in effect "showing its cards" by giving valuable information away to all other market participants, including especially market makers who internalize order flow.

Would the answer change if trading in that stock is unusually heavy or if virtually all ECNs were experiencing similar problems? Our skpermontage letter of September 14, elaborates upon the Exchange Act standards applicable in determining whether the Commission may approve the Nasdaq proposal as do a number of other comment letters cited therein.

Please help improve this article by adding citations to reliable sources. The theoretical "choice" of a UTP Exchange to participate in SuperMontage is wholly undermined by Nasdaq's continued operation of the exclusive securities information processor in a manner that ensures that such exchanges cannot effectively interact with the remainder of the market unless they use Nasdaq's non-UTP plan systems, which in the future, of course, would be operated as part of "SuperMontage.

SuperMontage will manage the execution of all orders received through the non-directed order process, either by carrying out the execution directly or delivering it as a liability order requiring execution under Nasdaq's rules with limited exceptions.

Nasdaq believes that SuperMontage, which is a facility sulermontage Nasdaq, will meet the definition of a market center and as such will have a reporting obligation provided that it received covered orders for execution from any person. Accordingly, the Letter seeks exemptive relief and interpretive guidance in connection with Nasdaq's reporting obligations under the Rule with respect to SuperMontage.

Third, under Amendment No. SelectNet The Letter states that two events have occurred since the June 22, letter that bring a number of transactions not currently covered by the June 22, letter within the scope of the Rule's reporting requirements for SuperSoes Participants. The Commission therefore finds that the exemption is necessary or appropriate in the public interest, and is consistent superrmontage the protection of investors.