Comment Text:
As part of establishing procedures for determining off-SEF, large notional and block trades, I feel similar requirement exemptions/considerations should be made for small notional and odd-lot trades. Executed trades in index product where the notional amount is US$10mm or less, do not necessarily carry the same 'weight' and/or price/spread influence as would a 'round lot' index trade; and in terms of price discovery/transparency, could do more to distort and obfuscate the market then help it while simultaneously disadvantaging smaller notional or odd-lot flow.
