On March 20, the Financial Industry Regulatory Authority, Inc. (FINRA) released Regulatory Notice 19-09, which reminds members of their obligations under Securities Exchange Act Rule 15c2-11 and FINRA Rule 6432 (Compliance with the Information Requirements of Rule 15c2-11). Rule 15c2-11 prohibits a broker-dealer from publishing (or submitting for publication) a quotation in an unlisted security

The Securities and Exchange Commission has proposed to issue an interpretation with respect to the definition of “automated quotation” under Regulation NMS. Rule 611 under Regulation NMS protects the best automated quotations of exchanges by prohibiting other exchanges from allowing trades to be executed at inferior prices, or “traded through.” To be deemed an “automated quotation,” a quotation must be, among other things, immediately executed and/or cancelled, transmitted and displayed, as appropriate. In the adopting release for Regulation NMS, the SEC provided that an “immediate” response meant the fastest response possible without any programmed delay. Any quotation that does not meet the requirements of an automatic quotation is deemed to be a “manual quotation.”
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