September 14, 2009
RE: Release No. 34-60515 File No. SR-FINRA-2009-054
Dear Ms. Murphy:
On behalf of the members of the Security Traders Association of New York, Inc. (STANY), I would respectfully request that the Securities and Exchange Commission (SEC or Commission) grant a brief extension to the comment period regarding the above captioned release.
While STANY is prepared to file a comment by the due date of September 16, 2009, in speaking with our members and representatives of their firms, we have become aware that not all of the interested and potentially affected have had time to formulate a response. With the publication of this proposal in late August and the late date of the Labor Day holiday this year, many people were on vacation and thus missed valuable time to formulate and submit comments.
Additionally and significantly, FINRAs announcement this morning that it is seeking to change its role from operating the OTCBB to acting as the consolidator and disseminator of all quotation and trade information for unlisted equity securities and FINRAs proposal to divest itself of the ownership and operation of the OTCBB may change opinions on this important rule proposal. We think it in the best interests of all participants in the OTC market to allow an extension of time to comment on the proposed changes so that the comments take into consideration todays announcement by FINRA and what impact, it will have on the OTC market.
If you have any questions, please do not hesitate to contact us.