1. Vice President & Managing Dir., Gen. Counsel, Managed Funds Ass'n, to David Stawick;Stuart J Letter From;Commodity Futures Trading Comm'n &,2011
2. While fees may also be tiered, in practice, the spread between high-and low-volume tiers for fees is much smaller than the spread for rebates. Email from Haim Bodek, Managing Principal, Decimus Capital Mkts., LLC, to author;& Riordan;AM EST) (on file with author),2014
3. This proposal further exposed the conflict between MTPM and traditional trading venues, including the "flash order" controversy, but, ultimately, this regulatory measure was not adopted. For clashing views illustrating this conflict, see Comments on Proposed Rule on the Proposed Amendments to Rule 610 of Regulation;Supra Bodek;The SEC also considered creating a similar fee cap for options. See Proposed Amendments to Rule 610 of Regulation NMS, Exchange Act Release No. 61,2010