In a comment letter, the Financial Information Forum ("FIF") provided recommendations to the SEC on modernizing Regulation NMS Rule 605 (Disclosure of Order Execution Information).
The FIF believes that the SEC should consider revising Rule 605 to better reflect the best practices created by industry participants since the rule's adoption. The FIF recommended:
- expanding the scope of covered orders;
- broadening the "granularity of reporting";
- instituting a "Marketable Benchmark" statistic, which would better inform investors of the size of the order relative to the consolidated national best bid and national best offer; and
- establishing a "Non-Marketable Benchmark" to give investors transparency into the number of shares executed in the market while the order was live.
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