April 16, 2014
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OTCBB Limit Order Protection Pilot Delayed

The OTCBB Limit Order Protection pilot, originally scheduled for April 16th, has been temporarily postponed. This is due to the need for additional time to evaluate rules relating to the "trading ahead increment," in the Nasdaq market, based on recent experience with decimalization. It is Nasdaq's intention to apply the same trading ahead increment in the OTCBB that is applied to Nasdaq listed securities. If the OTCBB Limit Order Protection pilot were to be implemented on April 16, as origninally planned, trading ahead increment rules would likely need to be subsequently amended. The decision to postpone implementation is intended to avoid that situation of uncertainty and inconvenience to investors and market makers.

Background
On February 8, 2001, the SEC approved the Limit Order Protection Pilot for the OTCBB. The rule change will, for a pilot period, prohibit Market Makers from "trading ahead" of customer limit orders in the 300 pilot securities quoted on the OTCBB. As approved, the rule states that Members cannot avoid this obligation through price improvement unless such price improvement is for a minimum of $0.05 (5 cents) or one-half the inside spread, whichever is less. In conjunction with the implementation of decimals, the trade-through increment for Nasdaq-listed securities was changed to $0.01 (one cent). Therefore, Nasdaq has decided to delay the pilot program in the OTCBB while it determines how it can provide limit order protection in the OTCBB in a manner consistent with the protection available to investors in Nasdaq-listed securities.

The OTCBB will announce a new schedule for the implementation of the pilot program as soon as it becomes available. If you have further questions about the postponement of the pilot, please contact Liz Heese at liz.heese@nasdaq.com.


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