December 7, 2017
I would like to comment on the definition of an institutional order. I believe that any order designation should be kept hidden from the market until after the trade is executed because knowing whether the order is "institutional" could affect how other market participants interact with the order. On one hand, institutional orders are more likely to attract buyers and sellers because institutional liquidity is more likely to stay on the book as opposed to high-frequency liquidity. Trades would therefore be more favorable to trading with institutional orders. On the other hand, knowing that a trade is made by an institution would allow others insight into what securities the institution is looking to trade, and they could potentially front-run the trade and affect the overall trade's execution price. If the Committee wishes to designate orders as "institutional", it should keep this information hidden until the trade is executed.
Also, I feel as if adding a size component to the definition of "institutional order" would help make it clearer. A tiered system, where the minimum size definition changes based on the value of the stock, would be most beneficial. A % of volume traded metric would also be helpful for evaluating whether a trade in an illiquid NMS security is considered "institutional".