Harvard Law School

Abstract

I am grateful for the opportunity to comment on the recommendation of the Market Structure Subcommittee (the “MSS”) of the IAC with respect to decimalization and tick sizes (the “Recommendation”). 1 The purpose of this letter is to urge the MSS to adopt Alternative Recommendation #1, as set forth in the dissenting opinion of MSS member Stephen Holmes, which calls for a pilot program for small-capitalization public companies to trade at wider ticksizes and limited trading increments within the tick.