April 2022
STA Comment Letter on SEC Short Sale and Short Position Rule Proposal

In situations where there is a pattern of enforcement or regular inquiries, it is a responsibility of the primary regulator to determine if the rule in question is clearly defined. We do not believe the BFMM exception is clearly defined, therefore, we believe the more pressing need is for the SEC to clarify its views on the scope of the BFMM exception. 
STA Comment Letter on Amendments Regarding the Definition of "Exchange" and ATS's

More recently, and acutely as it pertains to the Proposal, the Commission has significantly altered its approach on a rulemaking process that has served investors well for close to 90 years. The combination of numerous rule filings, many of which are complex and would lead to major market structure changes; new terminologies and amendments introduced late into the rulemaking process; and short comment periods and lack of clarity of proposed rules, gives us concern that the notice and comment process of rulemaking is being devalued. Our markets, while not perfect, are operating efficiently. We hope that the Commission can return to its historical norm because doing so is in the best interests of the markets and the investors who rely on them for their financial wellbeing. 
STA Comment Letter on Grayscale Bitcoin ETF

We appreciate the Commission’s recent decision to allow the listing and trading of ETFs that hold Bitcoin futures contracts. However, we recognize the need for similar regulatory treatment of Bitcoin futures ETFs registered under the Exchange Act and spot Bitcoin ETFs given they share the same characteristics in relevant respects. In particular, both types of products use similar processes for determining price on the underlying spot cash Bitcoin markets.
Joint Trade Associations Comment Letter on the Importance of Appropriate Length of Comment Periods

The rules crafted and enforced by the Commission are the vital foundation of the Commission’s critical mission objectives. The Associations, however, are concerned that meaningful public input into the rulemaking process, a pivotal element of ensuring that the Commission’s rules are appropriately tailored and that the Commission is meeting its statutory obligations and tripartite mission, is at risk of being lost in the Commission’s current rulemaking agenda.
STA Open Call

FinTech & Digital Assets: State of Play

On March 30, 2022, STA hosted its annual Washington DC Spring Update that featured various congressional members and business leaders. Among the topics discussed were the regulatory regime for FinTech companies and Digital Assets, and the need for congressional action.

To help educate the broader industry, STA is pleased to provide a replay of the interview with Rep. Warren Davidson moderated by Josh Beck, KeyBanc Capital Markets Equity Research Group, and a fireside discussion on the state of play of digital assets with industry experts from Hudson River Trading, Grayscale Investments and the Association of Digital Assets Markets (ADAM).
STA Women in Finance
Women in the Workforce with Rep. Ann Wagner
by Lindsey Patterson, Account Executive
Forefront Communications

At last month’s Washington DC Spring Update, STA hosted a prestigious group of legislators, regulators and business leaders for a series of discussions on the most pressing issues facing the securities industry. Among the speakers was Congresswoman Ann Wagner, who has served the second congressional district of Missouri since January 2013.
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in-home gym equipment, personalized fitness, nutrition programs
and a peer support network.
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