December 14, 2010
In the summary of the proposed rule, it is noted that a "large trader would be defined as a person whose transactions in NMS securities equal or exceed two million shares or $20 million during any calendar day, or 20 million shares or $200 million during any calendar month." I would like to know how the numbers 20m/day or 200m/month were chosen, because it seems unfair to arbitrarily choose some dollar limit and enforce rules based off it. Also, I think if the rule were passed, we might start to see some traders limit themselves to 19.9m/day and 199m/month in trades (maybe this is the goal of the proposed rule). Lastly, the proposal that "Registered broker-dealers would be required to maintain transaction records for each large trader, and would be required to report that information to the Commission" seems like it could be another very expensive regulation for American firms. I would also be concerned that rather than trying to stay under these trading limits, large trading firms might just decide to incorporate in other off-shore locations, where there is much less regulation and ways to protect investors.