As greater attention is devoted to the role of decimalization and other market structure changes in the decline of smaller company IPOs, we wanted to share this white paper authored by Leslie Seff, http://www.mofo.com/files/Uploads/Images/121124-IPOs-Decimalization-Need-for-Better-Regulation.pdf. The paper puts into perspective the various regulations that had an effect on market making activity, and recommends a more nuanced approach, including the introduction of a pilot program, compared to those approaches discussed to date that would begin to address some of these market structure issues.
Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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