SEC invites comments on NYSE plans to introduce Capital Commitment Order

Maria Nikolova

The purpose of the proposed CCO is the same as CCS – a tool for DMMs to provide additional, non-displayed liquidity in their assigned securities.

The United States Securities and Exchange Commission (SEC) is inviting comments on a proposal by New York Stock Exchange LLC (NYSE) to add a new order type, Capital Commitment Order.

The proposed new order type, Capital Commitment Order (CCO) is based in part on the current Capital Commitment Schedule (CCS), which is currently available only to Designated Market Makers (DMMs) trading in Exchange-listed securities.

The proposed CCO would be available to DMMs when the Exchange transitions Exchange-listed securities to Pillar. Like CCS interest, the CCO would enable DMMs to provide additional, non-displayed liquidity at specific price points in their assigned securities on the Pillar trading platform.

Among other things, unlike CCS, the proposed CCO would be an order type that includes a limit price, rather than a schedule of non-displayed liquidity, and would be eligible to execute only at its limit price on an order-by-order basis. Whereas the purpose of the CCO is the same as CCS – a tool for DMMs to provide additional, non-displayed liquidity in their assigned securities – the operation of CCOs would be based in part on how Tracking Orders function on the Exchange’s affiliated exchanges that currently operate on Pillar, NYSE Arca, Inc. and NYSE National, Inc.

The amended rules would specify that a CCO is a Limit Order that is not displayed, does not route, must be entered in a minimum of one round lot, and must be designated Day. This proposed rule text is based in part on how the CCS currently functions, but unlike CCS, the proposed CCO would be a Limit Order rather than a schedule of non-displayed liquidity.

The Exchange proposes to implement this proposed rule change when the Exchange transitions NYSE-listed securities to the Pillar trading platform, which is anticipated to begin in the third quarter of 2019.

The Exchange believes that the proposed CCO would remove impediments to, and perfect the mechanisms of, a free and open market and a national market system and, in general, protect investors and the public interest because it would provide DMMs with functionality currently available on the Exchange when Exchange-listed securities transition to Pillar. The proposed CCO would therefore promote continuity for the DMMs in the tools they have available to meet their affirmative obligation to maintain depth and continuity.

Those willing to submit electronic comments may do so via the Commission’s Internet comment form (; or send an e-mail to [email protected]. Please include File Number SR-NYSE-2019-22 on the subject line.

Paper comments should be sent in triplicate to Secretary, Securities and Exchange Commission, 100 F Street, NE, Washington, DC 20549-1090. All submissions should refer to File Number SR-NYSE-2019-22. 

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