In a letter to Securities and Exchange Commission (SEC) Secretary Brent J. Fields, CFA expresses support for the proposed pilot program to produce data on the effects of equity exchange transaction fees and rebates, and changes to those fees and rebates, on order routing behavior, execution quality, and market quality. We have strongly supported the concept of a pilot program to study the effects of the maker-taker pricing model and we applaud the Commission for taking this critical step toward making such a pilot program a reality. In order to produce the most meaningful information possible, CFA is also suggesting several important changes to the proposal for the pilot.
