On July 17, 2019, the Committee submitted a comment letter to the Securities and Exchange Commission (the “SEC”) regarding a proposed rule change filing by Cboe EDGA Exchange, Inc. (“EDGA” or the “Exchange”) with the SEC. The Exchange’s proposal would implement an asymmetric speed bump (i.e., one that applies an intentional delay to some order types but not to others) to “all incoming executable orders that would remove liquidity from the EDGA Book.”

The Committee recommended that the SEC not approve the proposed rule change. As the Committee has noted in several comment letters to the SEC and to the Commodities Futures Trading Commission, asymmetric speed bumps “could distort markets and . . . [e]xchanges should . . . not be broadly permitted to adopt intentional delays.” In the Committee’s view, any intentional delays should be “equally applied to all market participants.”

The Committee’s letter can be found here.