MMI Comment Letter to the SEC Regarding Regulation National Market System

We propose a review of the Reg NMS in light of technology and efficiencies that have made some measures unnecessary or contributed to market inefficiency.  In our letter, we propose a review of the effectiveness of The Order Protection Rule, the prohibition on locking or crossing quotations and consideration of a competing consolidators model for market data.  While our letter outlines some specific aspects of the regulation that we believe need immediate reconsideration, we strongly support a holistic, data-driven review of all of Reg NMS.