June 28, 2010
Lime Brokerage strongly endorses the NYSE's (and AMEX's)proposed amendments to incorporate odd-lots and the odd-lot portion of a partial round lot in the round lot market. Having a separate process to execute odd lots and odd lot portions of PRLs has placed a significant burden on firms to demonstrate that there was no impropriety when routine odd lot orders were placed in the ordinary course of business. The separate process for odd lot orders has created an impediment to efficiency. We applaud the NYSE for looking to modify the odd-lot process, and recognizing that the current process is no longer the optimal model.