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STANY is the voice of the trading community in the Great New York City area. STANY represents individuals, engaged in the buying, selling and trading of securities. As such, we are uniquely qualified to discuss rules and regulations affecting the purchase and sale of securities. STANY does not represent a single business or business model, but rather provides a forum for trading professionals from institutions, broker-dealers, ECNs, ATSs and systems providers to share their unique perspectives on issues facing the securities markets. Our members work together to promote their shared interest in efficient, liquid markets, as well as their concern for investor protection. We believe that strong and efficient markets require an appropriate balance between effective regulation and innovation and competition. STANY has consistently been an advocate for reasoned regulation aimed at solving real problems and improving US capital markets. We have also opposed regulation for regulation’s sake. Despite our members’ diverse backgrounds and member firms’ differing business models, our members’ primary concern is promoting strong and robust markets that offer investors the best choices, provide businesses advantageous capital formation tools, and ensure the US its premier place as a world leader in the financial markets. We desire a market that instills investor confidence and fosters investor participation.
STANY Comment Letters
Industry Response to Unusual Trading of May 6th SEC to File Limit Up Limit Down Rules April 6, 2011 On Wall Street article discussing the proposal SEC Announcement of Limit Up Limit Down Proposal SEC Chairman, Mary Schapiro's Testimony on the Events of May 6th Click here for the May 20th testimony. SEC to Publish for Public Comment Stock-by-Stock Circuit Breaker Rule Proposals. Click here for press release May 18, 2010. STANY's letter to SEC Chairman Mary Schapiro and the Senate Banking Committee STANY supplemental letter May 6 2010 Knight's Perspective on the market event of May 6, 2010 from Thomas M. Joyce, Chairman & CEO, Knight Capital Group Click Here. SEC's statement on the events of May 6th Click here. STANY files Comment Letter on Risk Managment Controls for Brokers or Dealers with Market Access Click Here for STANYComment Letter Market Access March 29 STANY and STA File Comments on SEC's Non-Public Liquidity Proposal Click here for STANY's Comment STANY_Comment_Dark_Pools_February_17_2010 Click here for STA's Comment STA Non-Public Displayed Liquidity FINAL SEC asks Exchanges to devise new trading rules Click here for story. Exchanges agree in principle to uniform circuit breakers Click here for story. STANY Comments on FINRA QCF STANY files letter with SEC opposing FINRA's proposal to create a Quotation Consolidation Facility STANY Comment FINRA QCF-Jan-13 2010 FINRA Proposal Riles OTC Market- for article click here. STANY and STA file comments to SEC's proposed amendments to Reg SHO See STANY's Letter in response to SEC's Supplemental Request for Comment STANY_Comment_Reg_Sho_9-21-09 See STA's Letter in response to SEC's Supplemental Request for Comment
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Senate Finance Committee Hearing “The President's Proposed Fee on Financial Institutions Regarding TARP, Part 2.”
5/5/2010 12:00:00 AM
On May 4, the Senate Finance Committee held a hearing to consider “The President's Proposed Fee on Financial Institutions Regarding TARP, Part 2.” As described by Treasury Secretary Geithner, the proposed fee (also know as a TARP fee), would be assessed on financial institutions that have over $50 billion in assets and were eligible for the emergency assistance programs put in place to resolve the crisis. He stressed that the fee would capture assets held off-balance sheet, including derivatives. He stated that the fee was designed so that it would fall most heavily on firms that fund riskier activities with less stable forms of funding. He explained that firms would pay a fixed percentage of their assets adjusted for risk, minus their capital, insured deposits, and certain insurance policy reserves. Secretary Geithner further suggested that this fee would be “an important complement to the financial reforms now under consideration on the Senate floor.” Chairman Baucus (D-MT) stressed the need to determine who should pay TARP fees and what effect the fee would have on small business and the economy. He questioned whether or not banks would pass the cost of the fee on to customers. A number of Republican Committee members spoke in opposition to the proposed TARP fee. Ranking Member Grassley (R-IA), Senator Hatch (R-UT) and Senator Crapo (R-ID) expressed displeasure that GM, Chrysler, Fannie Mae, Freddie Mac and hedge funds like Paulson and Co., Inc. are not expected to be covered by (e.g., subject to paying) the TARP fee, but firms which did not receive TARP funds would be subject to the fee. Ranking Member Grassley (R-IA), Senator Enzi (R-WY), Senator Snowe (R-ME) and Senator Roberts (R-KS) expressed concern that the proposed fee would reduce the availability and increase the cost of credit for small businesses. Ranking Member Grassley (R-IA) and Senator Bunning (R-KY) argued that the President should have waited until 2013 to propose a plan to recoup TARP funds. They suggested that there will be more accurate estimates of TARP losses in 2013. Topics discussed at this hearing included, but were not limited to: (1) TARP Fee; (2) Auto Industry; (3) Ex-Ante Fees; (4) Off-Balance Sheet Assets; (5) Insurance Companies/Scope of the Fee; (6) Fannie Mae and Freddie Mac; (7) AIG; (8) Small Business/Community Banks; (9) Derivatives; (10) Conflicts of Interest; and (11) Financial Regulatory Reform. Insurance Companies/Scope of the Fee - Senator Bingaman (D-NM) asked how the fee would apply to insurance companies, including to those which own thrift(s). Secretary Geithner stated that in order to be covered by the fee a firm must meet two tests: 1) it must be larger that $50 billion in assets; and 2) it must have been directly eligible for the emergency programs offered by the Treasury, the FDIC and the Federal Reserve. He indicated that some insurance companies structured as thrift holding companies would be covered by the fee. Senator Kerry (D-MA) expressed concern that some institutions would be covered by the fee because a small percentage of their assets are in a thrift or broker-dealer. Secretary Geithner stated that the fee would apply to companies which are primary dealers, but not to companies whose broker-dealers were not primary dealers. Kerry asked if mutual funds which have thrifts purely for trust purposes would be covered by the fee. Geithner indicated that he was unsure of how to deal with such situations. For a more expanded report of the meeting click here: 05 04 10 - Senate Finance - TARP Fee(2) (1)
Williams and Jensen
Regulatory
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