October 1, 2015
It is not clear how this policy (proposal to limit issuance of material information during an expanded hourly period, ability to halt trading) affects trading on other platforms, including dark pools. Does a halt of trading on the NYSE, or any single exchange, limit trading and ability to benefit from newly released information on other platforms, including foreign exchanges, dark pools, and other forms of securities trading which may not be affected or limited by a trading limitation on the NYSE. For example, in terms of fairness to retail investors who may have access to a security only through the NYSE, if trading is halted on the NYSE due to favorable or unfavorable material news, are such investors harmed by a halt on the NYSE while others have the ability to trade or transfer securities on other platforms, exchanges or markets including dark pools?
There should be consideration of how this proposed change could be implemented to protect market participants whose only access is through the NYSE, if trading is halted or limited.