MMI Comment Letter to the SEC Regarding the Proposed Commission Interpretation Regarding Automated Quotations Under Regulation NMS.

MMI believes an exemption to the definition of an automated quotation to allow delays of up to 1,000 microseconds in quotation response times, “whether intentional or not,” will create a trading environment that violates Section 11A of Rule 611 in both letter and spirit. Namely, “economically efficient execution of securities transactions, fair competition among broker-dealers, among exchange markets, and between exchange markets and non-exchange markets; price transparency; (and) best execution of investor orders.”