Comments on NASD Rulemaking

Self-Regulatory Organizations; National Association of Securities Dealers, Inc.; Notice of Filing of a Proposed Rule Change and Amendment No. 1 Thereto Relating to Sub-Penny Restrictions for Non-Nasdaq Over-the-Counter Equity Securities

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Date Received
Date Letter Type Commenter Name
Public Comment Andrew B. Stevens, Assistant General Counsel, NYSE Group, Inc., and Greg O'Connor, Director of Compliance, Archipelago Trading Services, Inc.
Public Comment Pershing LLC
Public Comment Patrick E. Brake, Jr., General Counsel; Hill, Thompson, Magid & Co., Inc.
Public Comment Jerry O'Connell, Chairman , Trading Committee, Securities Industry Association
Public Comment William Yancey, Chairman and John C. Giesea, President and CEO, Security Traders Association
Public Comment Leonard J. Amoruso, Knight Capital Group, Inc.
Public Comment Michael Santucci, President; Kimberly Unger, Esq., Executive Director; and Stephen J. Nelson, Esq., Co-Chair, Security Traders Association of New York, Inc., Trading Issues Committee
Public Comment Phylis M. Esposito, Executive Vice President, Chief Strategy Officer, Ameritrade, Inc.
Public Comment R. Cromwell Coulson, Chief Executive Officer, Pink Sheets LLC
Public Comment Phylis M. Esposito, Executive Vice President, Chief Strategy Officer, Ameritrade, Inc.
Public Comment Kevin J. P. O'Hara, Chief Administrative Officer & General Counsel, Archipelago Trading Services, Inc.

Last Reviewed or Updated: Dec. 18, 2025

File Number
SR-NASD-2005-095
Release Number
34-52280
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