The Financial Information Forum ("FIF") offered recommendations to streamline the Regulation ATS-N submission process. The process requires broker-dealers to publicly post Form ATS-N filings on the SEC's website.
In a comment letter to the SEC, FIF recommended:
- permitting alternative trading systems ("ATSs") to submit disclosure information in formats other than narrative form when applicable (e.g., in tables, charts and bullets);
- allowing ATSs to "cut and paste from internal documents," which would mitigate possible transcription mistakes;
- incorporating a "comment" field in Form ATS-N to allow ATSs to provide additional explanations;
- granting ATSs the ability to reference and link prior disclosures of public information;
- allowing ATSs to reference previous responses that sufficiently answer subsequent questions; and
- supplying clear guidance as it relates to which version of Adobe the EDGAR system can accept, or expanding the number of acceptable attachment formats that EDGAR can accept.
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