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Re: Amendments to Exchange Act Rule 3b-16 Regarding the Definition of “Exchange”; Regulation ATS for ATSs That Trade U.S. Government Securities, NMS Stocks, and Other Securities; Regulation SCI for ATSs That Trade U.S. Treasury Securities

This letter is on behalf of the Federal Regulation of Securities Committee of the Business Law Section of the ABA in response to the request for comments by the SEC regarding its proposal to amend rule 3b-16 under the Securities Exchange Act of 1934.

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