Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Notice of Filing of Amendment No. 2 to a Proposed Rule Change and Order Granting Accelerated Approval to a Proposed Rule Change, as Amended, To Establish Rules Governing the Trading of Options on the NASDAQ Options Market; Order Approving a Proposed Rule Change Relating to the LLC Agreement Establishing the NASDAQ Options Market LLC and Delegation Agreement Delegating to NOM LLC the Authority To Operate the NASDAQ Options Market; Order Granting an Application of The NASDAQ Stock Market LLC for an Exemption Pursuant to Section 36(a) of the Exchange Act from the Requirements of Section 19(b) of the Exchange Act; and Order Granting an Exemption for the NASDAQ Options Market LLC from Section 11A(b) of the Exchange Act, 14521-14543 [E8-5320]
Download as PDF
Federal Register / Vol. 73, No. 53 / Tuesday, March 18, 2008 / Notices
mstockstill on PROD1PC66 with NOTICES
fine levels specified with respect to both
individual members and member
organizations, and providing for a
rolling 24-month surveillance period,
will serve as an effective deterrent to
such violative conduct.4
The Commission finds that the
proposed rule change is consistent with
the requirements of the Act and the
rules and regulations thereunder
applicable to a national securities
exchange.5 In particular, the
Commission believes that the proposal
is consistent with Section 6(b)(5) of the
Act,6 which requires that the rules of an
exchange be designed to promote just
and equitable principles of trade, to
facilitate transactions in securities, to
remove impediments to and perfect the
mechanism of a free and open market
and a national market system, and, in
general, to protect investors and the
public interest. The Commission further
believes that ISE’s proposal to impose
sanctions on individuals and member
organizations who fail to submit Advice
Cancel or exercise instructions in a
timely manner is consistent with
Sections 6(b)(1) and 6(b)(6) of the Act,7
which require that the rules of an
exchange enforce compliance with, and
provide appropriate discipline for,
violations of Commission and Exchange
rules. In addition, the Commission finds
that the proposal is consistent with the
public interest, the protection of
investors, or otherwise in furtherance of
the purposes of the Act, as required by
Rule 19d–1(c)(2) under the Act,8 which
governs minor rule violation plans. The
Commission believes that the proposed
rule change should strengthen the
Exchange’s ability to carry out its
oversight and enforcement
responsibilities as an SRO in cases
where full disciplinary proceedings are
unsuitable in view of the minor nature
of the particular violation.
In approving this proposed rule
change, the Commission in no way
4 In addition, as a member of the Intermarket
Surveillance Group, the Exchange, as well as
certain other self-regulatory organizations (‘‘SROs’’)
executed and filed on October 29, 2007 with the
Commission, a final version of an Agreement
pursuant to Section 17(d) of the Act (the ‘‘17d–2
Agreement’’). As set forth in the 17d–2 Agreement,
the SROs have agreed that their respective rules
concerning the filing of Expiring Exercise
Declarations, also referred to as Contrary Exercise
Advices, of options contracts, are common rules. As
a result, the proposal to amend ISE’s MRVP will
result in further consistency in sanctions among the
SROs that are signatories to the 17d–2 Agreement
concerning Contrary Exercise Advice violations.
5 In approving this proposed rule change, the
Commission notes that it has considered the
proposed rule’s impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
6 15 U.S.C. 78f(b)(5).
7 15 U.S.C. 78f(b)(1) and 78f(b)(6).
8 17 CFR 240.19d–1(c)(2).
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minimizes the importance of
compliance with ISE rules and all other
rules subject to the imposition of fines
under the MRVP. The Commission
believes that the violation of any SRO
rules, as well as Commission rules, is a
serious matter. However, the MRVP
provides a reasonable means of
addressing rule violations that do not
rise to the level of requiring formal
disciplinary proceedings, while
providing greater flexibility in handling
certain violations. The Commission
expects that ISE would continue to
conduct surveillance with due diligence
and make a determination based on its
findings, on a case-by-case basis,
whether a fine of more or less than the
recommended amount is appropriate for
a violation under the ISE MRVP or
whether a violation requires formal
disciplinary action.
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act 9 and Rule
19d–1(c)(2) under the Act,10 that the
proposed rule change (SR–ISE–2008–09)
be, and hereby is, approved and
declared effective.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.11
Florence E. Harmon,
Deputy Secretary.
[FR Doc. E8–5351 Filed 3–17–08; 8:45 am]
BILLING CODE 8011–01–P
14521
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–57478; File Nos. SR–
NASDAQ–2007–004 and SR–NASDAQ–
2007–080]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing of Amendment No. 2 to a
Proposed Rule Change and Order
Granting Accelerated Approval to a
Proposed Rule Change, as Amended,
To Establish Rules Governing the
Trading of Options on the NASDAQ
Options Market; Order Approving a
Proposed Rule Change Relating to the
LLC Agreement Establishing the
NASDAQ Options Market LLC and
Delegation Agreement Delegating to
NOM LLC the Authority To Operate the
NASDAQ Options Market; Order
Granting an Application of The
NASDAQ Stock Market LLC for an
Exemption Pursuant to Section 36(a) of
the Exchange Act from the
Requirements of Section 19(b) of the
Exchange Act; and Order Granting an
Exemption for the NASDAQ Options
Market LLC from Section 11A(b) of the
Exchange Act
March 12, 2008.
I. Introduction
On January 30, 2007, The NASDAQ
Stock Market LLC (‘‘Nasdaq’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’),1 and Rule 19b–4
thereunder,2 a proposed rule change
(‘‘Trading Rules Proposal’’) to adopt
rules governing participation in and
trading on The NASDAQ Options
Market (‘‘NOM’’), which will be an
options exchange facility of Nasdaq
operated by The Nasdaq Options Market
LLC (‘‘NOM LLC’’). The proposed rule
change, as modified by Amendment No.
1, was published for comment in the
Federal Register on May 1, 2007.3 The
Commission received five comment
letters regarding the proposed rule
change.4 Nasdaq responded to the
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 55667
(April 25, 2007), 72 FR 23869 (‘‘Trading Rules
Proposal Notice’’).
4 See letters to Nancy M. Morris, Secretary,
Commission, from Stephen Schuler, Managing
Member, Global Electronic Trading Company
(‘‘GETCO’’), and Daniel Tierney, Managing Member,
GETCO, dated July 20, 2007 (‘‘GETCO Letter’’);
Michael J. Simon, Secretary, The International
Securities Exchange, LLC (‘‘ISE’’), dated June 15,
2007 (‘‘ISE Letter’’); John C. Nagel, Director and
Associate General Counsel, Citadel Investment
2 17
9 15
U.S.C. 78s(b)(2).
CFR 240.19d–1(c)(2).
11 17 CFR 200.30–3(a)(12); 17 CFR 200.30–
3(a)(44).
10 17
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commenters in a letter dated December
13, 2007,5 and filed Amendment No. 2
to the proposal on December 13, 2007.
This notice and order provides notice
and solicits comments from interested
persons regarding Amendment No. 2
and approves the Trading Rules
Proposal, as amended, on an accelerated
basis.
Also, on September 17, 2007, the
Exchange filed with the Commission a
proposed rule change, pursuant to
Section 19(b)(1) of the Act 6 and Rule
19b–4 thereunder,7 to establish, through
a limited liability company agreement,
NOM LLC, and to delegate to NOM LLC
the authority to operate NOM as a
facility of Nasdaq (‘‘Corporate Structure
Proposal,’’ and, with the Trading Rules
Proposal, the ‘‘Proposals’’). The
proposed rule change was published for
comment in the Federal Register on
October 12, 2007.8 The Commission
received no comments on the proposal.
This order approves the Corporate
Structure Proposal.
On December 13, 2007, Nasdaq
requested that the Commission grant
NOM LLC a permanent exemption from
the requirement under Section 11A(b) of
the Act and Rule 609 thereunder that a
securities information processor (‘‘SIP’’)
acting as an exclusive processor register
with the Commission.9 Further, on
December 13, 2007, Nasdaq asked the
Commission to exempt Nasdaq from the
rule filing requirements of Section 19(b)
of the Act for changes to NOM rules that
are effected solely by virtue of a change
to a Chicago Board Options Exchange
(‘‘CBOE’’), New York Stock Exchange
(‘‘NYSE’’), or Financial Industry
Regulatory Authority (‘‘FINRA’’) rule
that NOM has incorporated by
reference. This order grants these
exemptions.
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II. Discussion and Commission
Findings
After careful review of the Trading
Rule Proposal, as amended, and
Group L.L.C. (‘‘Citadel’’), dated June 11, 2007
(‘‘Citadel Letter’’); Michael T. Bickford, Senior Vice
President, Options, American Stock Exchange LLC
(‘‘Amex’’), dated May 24, 2007 (‘‘Amex Letter’’);
and Christopher Nagy, Chair, Securities Industry
and Financial Markets Association (‘‘SIFMA’’)
Options Committee, dated May 22, 2007 (‘‘SIFMA
Letter’’).
5 See letter from Jeffrey S. Davis, Vice President
and Deputy General Counsel, Nasdaq, to Nancy M.
Morris, Secretary, Commission, dated December 13,
2007 (‘‘Nasdaq Response’’).
6 15 U.S.C. 78s(b)(1).
7 17 CFR 240.19b–4.
8 See Securities Exchange Act Release No. 56604
(October 3, 2007), 72 FR 58137 (‘‘Corporate
Structure Proposal Notice’’).
9 15 U.S.C. 78k–1(b). Rule 609 under the Act, 17
CFR 242.609, requires that the registration of a
securities information processor be on Form SIP, 17
CFR 249.1001.
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17:39 Mar 17, 2008
Jkt 214001
consideration of the comment letters
and Nasdaq’s response to the
commenters, and the Corporate
Structure Proposal, the Commission
finds that the Trading Rules Proposal, as
amended, and the Corporate Structure
Proposal are consistent with the
requirements of the Act and the rules
and regulations thereunder applicable to
a national securities exchange.10
Specifically, the Commission finds that
the Proposals are consistent with
Section 6(b)(5) of the Act,11 which
requires, among other things, that the
rules of a national securities exchange
be designed to prevent fraudulent and
manipulative acts and practices; to
promote just and equitable principles of
trade; to foster cooperation and
coordination with persons engaged in
regulating, clearing, settling, and
processing information with respect to,
and facilitating transactions in
securities; to remove impediments to
and perfect the mechanism of a free and
open market and a national market
system; and, in general, to protect
investors and the public interest.
Section 6(b)(5) also requires that the
rules of an exchange not be designed to
permit unfair discrimination among
customers, issuers, brokers, or dealers.
Further, the Commission finds that the
Proposals are consistent with Sections
6(b)(1) of the Act,12 which requires,
among other things, that a national
securities exchange be so organized and
have the capacity to carry out the
purposes of the Act, and to comply and
enforce compliance by its members and
persons associated with its members,
with the provisions of the Act, the rules
and regulation thereunder, and the rules
of the exchange, and Section 6(b)(2) of
the Act,13 which requires, in part, that
the rules of an exchange assure a fair
representation of its members in the
selection of its directors and
administration of its affairs.
Overall, the Commission believes that
approving Nasdaq’s Proposals could
confer important benefits on the public
and market participants. In particular,
NOM’s entry into the marketplace could
provide market participants with an
additional venue for executing orders in
standardized options, enhance
innovation, and increase competition
between and among the options
exchanges, resulting in better prices and
executions for investors.
10 In approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. 15 U.S.C. 78c(f).
11 15 U.S.C. 78f(b)(5).
12 15 U.S.C. 78f(b)(1).
13 15 U.S.C. 78f(b)(2).
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This discussion does not review every
detail of the proposed rule changes, but
focuses on the comments received and
the most significant rules and policy
issues considered in review of the
proposals.
A. Corporate Structure
In connection with the establishment
of NOM, Nasdaq has entered into a
limited liability company agreement
(‘‘NOM LLC Agreement’’) to establish
NOM LLC as a Delaware limited
liability company that will operate
NOM as a facility of Nasdaq, as that
term is defined in Section 3(a)(2) of the
Act.14 Nasdaq and NOM LLC also will
enter into a delegation agreement
(‘‘NOM Delegation Agreement’’),
pursuant to which Nasdaq will delegate
to NOM LLC certain limited
responsibilities and obligations with
respect to the operation of NOM as an
options facility of Nasdaq.15
Nasdaq, a registered national
securities exchange, is the whollyowned subsidiary of The NASDAQ
Stock Market, Inc. (‘‘Nasdaq Holding
Company’’). NOM LLC will be a direct,
wholly-owned subsidiary of Nasdaq,
and, pursuant to the NOM LLC
Agreement, Nasdaq may not transfer or
assign, in whole or in part, its interest
in NOM LLC.16 Further, NOM will be
operated as a facility of the Exchange
and Nasdaq will retain self-regulatory
responsibility for NOM.
1. Changes in Control of NOM;
Ownership and Voting Limitations
The Commission notes that the
Nasdaq Holding Company’s Restated
Certificate of Incorporation imposes
limits on direct and indirect changes in
control, which are designed to prevent
any shareholder from exercising undue
control over the operation of the
Exchange and to ensure that the
14 15 U.S.C. 78c(a)(2). Pursuant to Section 3(a)(2),
a ‘‘facility’’ ‘‘with respect to an exchange includes
its premises, tangible or intangible property
whether on the premises or not, any right to the use
of such premises or property or any service thereof
for the purpose of effecting or reporting a
transaction on an exchange (including, among other
things, any system of communication to or from the
exchange, by ticker or otherwise, maintained by or
with the consent of the exchange), and any right of
the exchange to the use of any property or service.’’
15 The form of each of the NOM LLC Agreement
and NOM Delegation Agreement are available at the
Commission’s Web site https://www.sec.gov.
16 See NOM LLC Agreement, Section 19. Also,
Nasdaq Holding Company may not transfer or
assign its interest in Nasdaq, other than to an
affiliate of Nasdaq Holding Company. See Limited
Liability Company Agreement of The NASDAQ
Stock Market LLC, Section 20. Any change to
Nasdaq’s status as the sole member of NOM LLC,
or to Nasdaq Holding Company’s status as the sole
member of Nasdaq, would have to be filed pursuant
to Section 19(b) of the Act. 15 U.S.C. 78s.
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Exchange and the Commission are able
to carry out their regulatory obligations
under the Act. Specifically, no person
who beneficially owns shares of
common stock, preferred stock, or notes
in excess of five percent of the securities
generally entitled to vote may vote
shares in excess of five percent.17
The Exchange’s rules also prohibit
Exchange members and persons
associated with Exchange members from
beneficially owning more than 20
percent of the then-outstanding voting
securities of Nasdaq Holding
Company.18 Members that trade on an
exchange or through the facility of an
exchange traditionally have ownership
interests in such exchange or facility.
The Commission has noted in the past,
however, that a member’s interest in an
exchange could become so large as to
cast doubt on whether the exchange can
fairly and objectively exercise its selfregulatory responsibilities with respect
to that member.19 A member that is a
controlling shareholder of an exchange
might be tempted to exercise that
controlling influence by directing the
exchange to refrain from, or the
exchange may hesitate to, diligently
monitor and surveil the member’s
conduct or diligently enforce its rules
and the federal securities laws with
respect to conduct by the member that
violates such provisions.
The Commission believes that the
proposed corporate structure for NOM is
consistent with the Act. The voting
restrictions imposed on shareholders of
Nasdaq Holding Company will flow
through to NOM LLC by virtue of the
fact that NOM LLC will be a whollyowned subsidiary of Nasdaq, which is a
wholly-owned subsidiary of Nasdaq
Holding Company. The ownership
limitation on members of Nasdaq will
apply to NOM participants by virtue of
the fact that all NOM participants must
be members of the Exchange. These
ownership and voting restrictions are
designed to minimize the potential that
a person could improperly interfere
17 See Nasdaq Holding Company Restated
Certificate of Incorporation, Article Fourth, C. The
Nasdaq Holding Company board of directors may
approve an exemption from the five percent voting
limitation for any person that is not a broker-dealer,
an affiliate of a broker-dealer, or a person subject
to a statutory disqualification under Section 3(a)(39)
of the Act. See id. Any such exemption from the
five percent voting limitation would not be effective
until approved by the Commission pursuant to
Section 19 of the Act. See Nasdaq Holding
Company By-Laws, Article XII, Section 12.5.
18 See Exchange Rule 2130.
19 See Securities Exchange Act Release No. 53128
(January 13, 2006), 71 FR 3550 (January 23, 2006)
(order approving Nasdaq’s application to register as
a national securities exchange) (‘‘Registration
Approval Order’’) at note 42 and accompanying
text.
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17:39 Mar 17, 2008
Jkt 214001
with or attempt to restrict the ability of
the Commission or the Exchange to
effectively carry out their regulatory
oversight responsibilities under the Act.
2. Fair Representation
NOM LLC will not have its own board
of directors or committees separate from
the board and committees of the
Exchange. The Commission believes
that because NOM LLC does not have a
separate board, and because all NOM
participants will be Exchange members,
the composition of and selection
process for the Exchange board
continues to satisfy the requirement in
Section 6(b)(3) of the Act that the rules
of the Exchange provide for the fair
representation of members in the
selection of directors and the
administration of the Exchange.20
3. Regulatory Independence
As noted above, NOM LLC will not
have its own board or committees
separate from those of the Exchange.
Additionally, pursuant to the NOM LLC
Agreement, management of the
company is vested in the Exchange, and
the officers of NOM LLC will be the
officers of the Exchange.21 As a result,
NOM LLC may only act through the
Exchange and its officers and directors.
The Commission notes that certain
provisions of the Exchange’s and
Nasdaq Holding Company’s corporate
documents are designed to maintain the
independence of Nasdaq’s selfregulatory function, enable the
Exchange to operate in a manner that
complies with federal securities laws,
including the objectives of Sections 6(b)
and 19(g) of the Act, and facilitate the
ability of Nasdaq and the Commission to
fulfill their regulatory and oversight
obligations under the Act.22 As a facility
of Nasdaq, the protections afforded by
these provisions in the corporate
documents of the Exchange and Nasdaq
Holding Company extend to the
operation of NOM.
Similar provisions also are included
in the NOM Delegation Agreement. For
example, NOM agrees: (1) To keep
confidential non-public information
20 See Registration Approval Order, supra note
19, at 3553.
21 See NOM LLC Agreement, Sections 9 and 10,
respectively. See also Section 9(b) of the NOM LLC
Agreement which requires NOM LLC and the
Exchange to comply with federal securities laws
and the rules and regulations thereunder, and to
cooperate with the Commission and NOM pursuant
to their regulatory authority.
22 A discussion of Nasdaq’s corporate structure
and the protections afforded by the corporate
documents of Nasdaq and Nasdaq Holding
Company, is set forth in the Registration Approval
Order, supra note 19. The corporate documents of
Nasdaq and Nasdaq Holding Company are not being
amended by this proposed rule change.
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Sfmt 4703
14523
relating to Nasdaq and not to use such
information for any commercial
purposes; (2) to provide the Commission
and Nasdaq access to NOM’s books and
records at all times and to maintain
such books and records within the
United States; (3) that the books,
records, premises, officers, and
employees of NOM shall be deemed to
be those of Nasdaq for purposes of the
Act; and (4) to cooperate with, and take
reasonable steps to cause its agents to
cooperate with, the Commission and
Nasdaq pursuant to their regulatory
authority. In addition, NOM and its
officers and employees submit to the
jurisdiction of the Commission and
agree to give due regard to the
preservation of the self-regulatory
function of Nasdaq.23 Further, the NOM
Delegation Agreement may not be
amended unless such amendment is
filed with, or filed with and approved
by, the Commission pursuant to Section
19 of the Act.24 The Commission
believes that these provisions, which are
designed to assist Nasdaq in fulfilling its
self-regulatory obligations and in
administering and complying with the
requirements of the Act, are consistent
with the Act, in particular Sections
6(b)(1) and 19(g).
B. Status of NOM as a Facility of
Nasdaq and Delegation of Authority to
NOM LLC
As a facility of Nasdaq, NOM will be
subject to the Commission’s oversight
and examination. Consequently, the
Commission will have the same
authority to oversee the premises,
personnel, and records of NOM LLC as
it currently has with respect to Nasdaq.
In addition, Nasdaq will be fully
responsible for all activity that takes
place through NOM, and NOM
participants will be subject to Nasdaq’s
rules and oversight.
As described in detail in the Notice,
the NOM Delegation Agreement
provides that Nasdaq will delegate to
NOM LLC performance of certain
limited responsibilities and obligations
of Nasdaq with respect to the operation
of NOM as an options trading facility.
Nasdaq, however, expressly retains
ultimate responsibility for the
fulfillment of its statutory and selfregulatory obligations under the Act.
Accordingly, as described more fully
below, Nasdaq will retain ultimate
responsibility for such delegated
responsibilities and functions, and any
actions taken pursuant to delegated
authority will remain subject to review,
approval or rejections by Nasdaq’s board
23 See
24 See
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NOM Delegation Agreement, II.B.
NOM Delegation Agreement, III.
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Federal Register / Vol. 73, No. 53 / Tuesday, March 18, 2008 / Notices
mstockstill on PROD1PC66 with NOTICES
of directors in accordance with
procedures established by Nasdaq’s
board of directors. Nasdaq has filed the
NOM Delegation Agreement as part of
its rules.
Pursuant to the Delegation
Agreement, Nasdaq expressly retains the
authority to (1) delegate authority to
NOM LLC to take actions on behalf of
the Exchange, and (2) direct NOM LLC
to take action necessary to effectuate the
purposes and functions of Nasdaq,
consistent with the independence of
Nasdaq’s regulatory functions, exchange
rules, policies and procedures, and the
federal securities laws.25 NOM LLC will
have delegated authority to, among
other things, operate NOM, develop and
adopt governing listing standards
applicable to options listed on NOM in
consultation with Nasdaq, and establish
and assess listing fees, transaction fees,
market data fees and other fees for the
products and services offered by
NOM.26 In addition, NOM LLC will
have the authority to act as a SIP for
quotations and transaction information
related to securities traded on NOM and
any trading facilities operated by NOM
LLC.27
NOM LLC also will have authority to
develop, adopt, and administer rules
governing participation in NOM,28 but
the Exchange represents that it will have
ultimate responsibility for the
operations, rules and regulations
developed by NOM LLC, as well as their
enforcement. Further, the Exchange
represents that actions taken by NOM
LLC pursuant to its delegated authority
will remain subject to review, approval
or rejection by the Exchange’s board of
directors.29 In addition, NOM LLC will
be responsible for referring to Nasdaq
any complaints of a regulatory nature
involving potential rule violations by
member organizations or employees,30
and Nasdaq will retain overall
responsibility for ensuring that the
statutory and self-regulatory functions
of the Exchange are fulfilled.31
The Commission finds that it is
consistent with the Act for Nasdaq to
delegate the operation of NOM to NOM
LLC, while retaining ultimate
responsibility for statutory and selfregulatory obligations and ensuring that
25 See Corporate Structure Proposal Notice, supra
note 8, at 58140 and NOM Delegation Agreement,
I.
26 See Corporate Structure Proposal Notice, supra
note 8, at 58140 and NOM Delegation Agreement,
II.A.
27 See NOM Delegation Agreement, II.A.3.
28 Id.
29 See Corporate Structure Proposal Notice, supra
note 8, at 58140.
30 See NOM Delegation Agreement, II.A.9.
31 See NOM Delegation Agreement, I.1.
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17:39 Mar 17, 2008
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NOM’s business is conducted in a
manner consistent with the
requirements of the Act.
C. Access to NOM
Only Options Participants (‘‘Options
Participants’’ or ‘‘Participants’’) may
transact business on NOM via the
System.32 There are two categories of
Participants: (1) Options Order Entry
Firms (‘‘OEFs’’), which represent
customer orders as agent or conduct
proprietary trading; and (2) Options
Market Makers (‘‘Options Market
Makers’’ or ‘‘Market Makers’’). A
Participant must be a member of Nasdaq
and of another registered options
exchange that is not registered solely
under Section 6(g) of the Act.33 As
Nasdaq members, Participants must
satisfy the requirements of the Nasdaq
Rule 1000 Series (Membership,
Registration, and Qualification
Requirements), as well as additional
requirements set forth in the NOM
rules.34 Further, an OEF may transact
business with Public Customers only if
it is a member of another registered
national securities exchange or
association with which Nasdaq has
entered into an agreement under Rule
17d–2 under the Act 35 pursuant to
which the other exchange or association
is the designated options examining
authority for the OEF.36 In addition,
Options Participants that transact
32 See NOM Rules, Chapter II, Section 1(a). An
Options Participant is a firm or organization
registered with Nasdaq pursuant to Chapter II of the
NOM Rules for purposes of participating in options
trading on NOM as an Order Entry Firm or Options
Market Maker. See NOM Rules, Chapter I, Section
1(a)(40).
33 15 U.S.C. 78f(g). See NOM Rules, Chapter II,
Sections 1(a)(iii) and 2(f). In Amendment No. 2,
Nasdaq proposes to eliminate from Chapter II,
Section 1(b)(iii) a provision stating that a Nasdaq
member would automatically become a NOM
Participant upon completing a NOM Application
and paying the applicable fees. Nasdaq believes that
this provision did not accurately reflect the
intended scope of review of NOM applicants, and
that eliminating the provision will improve the
quality of regulation of NOM. The Commission
finds that this change is consistent with the Act.
34 See NOM Rules, Chapter II. Nasdaq’s rules
apply to Participants unless a specific NOM rule
governs or unless the context otherwise requires.
See NOM Rules, Chapter I, Section 2. Among
others, Participants will be able to provide
sponsored access to NOM to a non-member
(‘‘Sponsored Participant’’) pursuant to Nasdaq Rule
4611(d), which Nasdaq adopted in 2007. See
Securities Exchange Act Release Nos. 55061
(January 8, 2007), 72 FR 2052 (January 17, 2007)
(notice of filing and immediate effectiveness of File
No. SR–Nasdaq–2006–061) (adopting Nasdaq Rule
4611(d)); and 55550 (March 28, 2007), 72 FR 16389
(April 4, 2007) (notice of filing and immediate
effectiveness of File No. SR–Nasdaq–2007–010)
(revising Nasdaq Rule 4211(d)).
35 17 CFR 240.17d–2.
36 See NOM Rules, Chapter XI, Section 1. See also
notes 240 to 241, infra, and accompanying text for
a discussion of Rule 17d–2.
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business with customers must be
members of FINRA.37
Among other things, each Participant
must be registered as a broker-dealer
and have as the principal purpose of
being a Participant the conduct of a
securities business, which shall be
deemed to exist if and so long as: (1)
The Participant has qualified and acts in
respect of its business on NOM as either
an OEF or an Options Market Maker or
both; and (2) all transactions effected by
the Participant are in compliance with
Section 11(a) of the Act 38 and the rules
and regulations thereunder.39
Participants may trade options for their
own proprietary accounts or, if
authorized to do so under applicable
law, may conduct business on behalf of
customers.40
1. OEFs
OEFs are Participants representing
customer orders as agent on NOM or
trading as principal on NOM.41 OEFs
also may register as Market Makers. A
Market Maker that engages in specified
Other Business Activities, or that is
affiliated with a broker-dealer that
engages in Other Business Activities,
including functioning as an OEF, must
have an Information Barrier between the
market making activities and the Other
Business Activities.42
One commenter believes that the
ability of OEFs, like Market Makers, to
enter orders on both sides of the market
for the same customer raises questions
concerning the rights and
responsibilities of the OEF and the
customer. In particular, the commenter
asks whether Market Makers will have
exclusive access to certain NOM
systems or other tools, or otherwise
have rights that differ from the rights of
these customers. The commenter also
asserts that NOM’s proposal lacks
clarity regarding its Participants’
responsibility for surveillance of the
activities of these market participants.43
In response, Nasdaq stated its belief
that the NOM market model is similar
to Nasdaq’s equity market structure and
does not raise any unique or challenging
issues for order entry firms and
investors. Nasdaq further believes that
most Participants will be familiar with
the regulatory and surveillance
requirements associated with access to
NOM from their businesses in equity
securities.44 Nasdaq represents that,
37 See
NOM Rules, Chapter II, Section 2(f).
U.S.C. 78k(a).
39 See NOM Rules, Chapter II, Section 2(e).
40 See NOM Rules, Chapter II, Section 1(a).
41 See NOM Rules, Chapter VII, Section 1.
42 See NOM Rules, Chapter VII, Section 10.
43 See SIFMA Letter, supra note 4, at 2.
44 See Nasdaq Response, supra note 5, at 2.
38 15
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within the System, Market Makers will
not have any special priorities or other
privileges.45
The Commission believes that it is
consistent with the Act for an options
exchange not to prohibit a user of its
market from effectively operating as a
market maker by holding itself out as
willing to buy and sell options contracts
on a regular or continuous basis without
registering as a market maker.46 The
Commission notes that although an
entity that effectively acts as a market
maker but is not registered as such will
not be required to comply with any
rules applicable to a Market Maker, it
also will not be eligible to receive
certain benefits of being a Market
Maker.47 The Commission also agrees
with Nasdaq’s assertion that NOM does
not raise any unique issues related to
surveillance or the responsibilities of
OEFs, and notes that all Options
Participants must also be members of
Nasdaq. Further, the Commission notes
that an entity that acts as a ‘‘dealer,’’ as
defined in Section 3(a)(5) of the Act,48
would be required to register with the
Commission under Section 15 of the
Act,49 and the rules and regulations
thereunder, or qualify for any exception
or exemption from registration.50
2. Market Makers
a. Registration of Market Makers
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An Options Market Maker is a
Participant registered with Nasdaq as a
Market Maker.51 To register as a Market
Maker, a Participant must file a written
45 45 Id. at 5. Registered market makers do,
however, receive certain benefits for carrying out
their responsibilities. For example, a lender may
extend credit to a broker-dealer without regard to
the restrictions in Regulation T of the Board of
Governors of the Federal Reserve System if the
credit is used to finance the broker-dealer’s
activities as a specialist or market maker on a
national securities exchange (see 12 CFR
221.5(c)(6)). In addition, market makers are
excepted from the prohibition in Section 11(a) of
the Act.
46 See Securities Exchange Act Release No. 38054
(December 16, 1996), 61 FR 67365 (December 20,
1996) (order approving File No. SR-CBOE–95–48).
47 See infra notes 76 and 84 and accompanying
text.
48 15 U.S.C. 78c(a)(5).
49 15 U.S.C. 78o.
50 Activity that may cause a person to be deemed
a dealer includes ‘‘’quoting a market in or
publishing quotes for securities (other than quotes
on one side of the market on a quotations system
generally available to non-broker-dealers, such as a
retail screen broker for government securities).’’’
See Definition of Terms in and Specific Exemptions
for Banks, Savings Associations, and Savings Banks
Under Sections 3(a)(4) and 3(a)(5) of the Securities
Exchange Act of 1934, Securities Exchange Act
Release No. 47364, 68 FR 8685, 8689, note 26
(February 24, 2003) (quoting OTC Derivatives
Dealers, Securities Exchange Act Release No. 40594,
63 FR 59362, 59370, note 61 (November 3, 1998)).
51 See NOM Rules, Chapter VII, Section 2.
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application with Nasdaq Regulation,
which will consider an applicant’s
market making ability and other factors
it deems appropriate in determining
whether to approve an applicant’s
registration.52 All Market Makers are
designated as specialists on NOM for all
purposes under the Act or rules
thereunder.53 The NOM Rules place no
limit on the number of qualifying
entities that may become Market
Makers.54 The good standing of a Market
Maker may be suspended, terminated,
or withdrawn if the conditions for
approval cease to be maintained or the
Market Maker violates any of its
agreements with Nasdaq or any
provisions of the NOM Rules.55 A
Participant that has qualified as a
Market Maker may register to make
markets in individual series of
options.56
The Commission finds that NOM
Market Maker qualifications
requirements are consistent with the
Act, and notes that they are similar to
those of other options exchanges.57
Further, the Commission believes that
allowing NOM Market Makers to
register by series, rather than by class,
will permit Market Makers to select the
options series they are most interested
in trading. This is designed to help to
reduce the number of quotes submitted
by such Market Makers, and therefore
could help to mitigate NOM’s quote
message traffic and capacity.58
b. Market Maker Obligations
Pursuant to NOM rules, the
transactions of a Market Maker in its
market making capacity must constitute
a course of dealings reasonably
calculated to contribute to the
maintenance of a fair and orderly
52 See
NOM Rules, Chapter VII, Section 2(a).
NOM Rules, Chapter VII, Section 2.
54 See NOM Rules, Chapter VII, Rule 2(c).
However, Nasdaq may limit access to the System
based on system constraints, capacity restrictions,
or other factors relevant to protecting the integrity
of the System, pending action required to address
the issue of concern. To the extent that Nasdaq
places limitations on access to the System on any
Participant(s), such limits shall be objectively
determined and submitted to the Commission for
approval pursuant to a rule change filed under
Section 19(b) of the Act. See NOM Rules, Chapter
VII, Section 2(c).
55 See NOM Rules, Chapter VII, Section 4(b).
56 See NOM Rules, Chapter VII, Section 3(a).
57 See, e.g., BOX Rules, Chapter VI, Section 2 and
ISE Rule 804.
58 See Securities Exchange Act Release No. See
Securities Exchange Act Release No. 55027
(December 29, 2006), 72 FR 1358 (January 11, 2007)
(order approving File No. SR-Phlx-2006–53).
Further, one commenter believes that series-byseries registration will allow market makers to
target the series for which they are most apt to
provide liquidity, which in turn will create greater
liquidity across the entire market. See GETCO
Letter, supra note 4, at 2.
53 See
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14525
market.59 Further, among other things, a
Market Maker must: (1) On a daily basis
participate in the pre-opening phase and
maintain a two-sided market on a
continuous basis in at least 75% of the
options series in which it is registered;60
(2) enter a size of at least ten contracts
for its best bid and its best offer;61 and
(3) maintain minimum net capital in
accordance with Commission and
Nasdaq rules.62 In addition, Nasdaq may
call upon a Market Maker to submit a
single bid or offer or to maintain
continuous bids and offers in one or
more of the series in which the Market
Maker is registered if, in Nasdaq’s
judgment, it is necessary to do so in the
interest of fair and orderly markets.63 If
Nasdaq finds any substantial or
continued failure by a Market Maker to
engage in a course of dealings as
specified in Chapter VII, Section 5(a) of
the NOM Rules, such Market Maker will
be subject to disciplinary action or
suspension or revocation of registration
in one or more of the securities in which
the Market Maker is registered.64
One commenter notes that NOM’s
rules do not appear to assure that there
will be continuous quotes in a particular
series because a Market Maker could
cease disseminating quotes for a series
at any time during the trading day, and
requests that Nasdaq clarify a market
maker’s continuous quoting
obligations.65 In response, Nasdaq notes
that other options markets face the
possibility that a registered market
maker will withdraw its quotes during
the trading day, and that NOM’s rules
permit Nasdaq to require a market
maker to quote continuously in a series
in which it is registered.66 Nasdaq
further notes that it intends to provide
functionality that will allow its Market
Makers to instruct the NOM System to
automatically input a quotation on the
side of the market that has been
depleted. In addition, Nasdaq represents
that it will bring an appropriate
disciplinary action against a Market
59 See NOM Rules, Chapter VII, Section 5(a).
Amendment No. 2 replaces the provisions in the
NOM proposal related to the Exchange’s ability to
automatically cancel all bids and offers posted by
a Market Maker under certain circumstances with
provisions allowing any Options Participant to ask
NOM staff to simultaneously cancel all of the
Options Participant’s bids, offers, and orders in all
series. See NOM Rules, Chapter VII, Section 11. The
Commission believes that the proposed change is
reasonably designed to enable Participants to limit
their risk and is consistent with the Act.
60 See NOM Rules, Chapter VII, Section 6(d)(i).
61 See NOM Rules, Chapter VII, Section 6(a).
62 See NOM Rules, Chapter VII, Section 4(a)(i).
63 See NOM Rules, Chapter VII, Section 6(d)(ii).
64 See NOM Rules, Chapter VII, Section 5(c).
65 See SIFMA Letter, supra note 4, at 1.
66 See Nasdaq Response, supra note 5, at 3, and
NOM Rules, Chapter VII, Section 6(d)(ii).
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Maker that fails to meet its quoting
obligations.67
This commenter also requests
clarification of NOM’s treatment of
options series without a Market Maker.
In particular, the commenter questions
the actions NOM will take if a Market
Maker withdraws from making markets
in a series, including whether NOM will
continue to match orders in the series.68
To the extent that the commenter is
questioning what will happen if a
Market Maker registered in a series does
not have a quote in that series (as
opposed to the Market Maker
withdrawing from registration in the
series),69 Nasdaq states that NOM will
continue to route and execute orders in
that series. In addition, Nasdaq states
that, if an order is received by NOM
when its quote is not at the NBBO, NOM
will route the order automatically to a
market at the NBBO. An order displayed
on NOM that becomes marketable will
be accessible through the Linkage.70
The definition of a ‘‘market maker’’
includes a dealer who holds itself out as
being willing to buy and sell a security
for his account on a regular or
continuous basis.71 Therefore, although
under NOM’s proposal certain series
may not have continuous quotes
disseminated by NOM, the Commission
believes that the obligations imposed by
the NOM Rules on Market Makers fall
within the definition of market maker
because they will require a NOM Market
Maker to hold itself out as being willing
to buy and sell a security for its account
on a regular basis. The Commission
therefore believes that the obligations
imposed by the NOM Rules on Market
Makers are consistent with the Act.72
The commenter also asserts that other
options exchanges generally require
market makers to provide two-sided
quotations for 80% of the classes in
which a market maker is registered, and
that uniform quotation requirements
67 See
Nasdaq Response, supra note 5, at 3.
SIFMA Letter, supra note 4, at 2.
69 See discussion infra notes 77 to 79 and
accompanying text.
70 See Nasdaq Response, supra note 5, at 3.
71 See 15 U.S.C. 78c(a)(38) (definition of ‘‘market
maker’’).
72 The Commission notes that in approving the
rules of the Boston Options Exchange (‘‘BOX’’), the
Commission acknowledged that certain options
series might not have continuous quotes
disseminated by BOX, but concluded that the
obligations imposed on market makers under the
BOX Rules were consistent with the Act. The
Commission also noted that the CBOE’s Hybrid
trading system had market maker obligations
comparable to those proposed for BOX and also did
not require market makers to quote all series. See
Securities Exchange Act Release No. 49068 (January
13, 2004), 69 FR 2775 (January 20, 2004) (order
approving File No. SR–BSE–2002–15) (‘‘BOX
Approval Order’’).
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68 See
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among the options markets would be
desirable.73 In its response letter,
Nasdaq states that NOM’s Market Maker
participation standard, which will allow
Market Makers to register in particular
options series rather than an entire
class, should result in active
participation in all series for which a
Market Maker registers voluntarily.74 In
addition, Nasdaq maintains that its
approach is numerically superior to
other options exchanges, noting that the
BOX Rules effectively require market
makers to maintain continuous twosided quotes in only 72% of the series
in which they are registered, or at times
in only 60% of the series in which they
are registered.75
Market makers receive certain benefits
for carrying out their responsibilities.
For example, a lender may extend credit
to a broker-dealer without regard to the
restrictions in Regulation T of the Board
of Governors of the Federal Reserve
System if the credit is used to finance
the broker-dealer’s activities as a
specialist or market maker on a national
securities exchange.76 In addition,
market makers are excepted from the
prohibition in Section 11(a) of the Act.
The Commission believes that a market
maker must have sufficient affirmative
obligations, including the obligation to
hold itself out as willing to buy and sell
options for its own account on a regular
or continuous basis, to justify this
favorable treatment. The Commission
further believes that the rules of all U.S.
options markets need not provide the
same standards for market maker
participation, so long as they impose
affirmative obligations that are
consistent with the Act. The
Commission believes that NOM’s
market maker participation
requirements impose sufficient
affirmative obligations on NOM Market
Makers and, accordingly, that NOM’s
requirements are consistent with the
Act.
Nasdaq will open trading in an
options series only if there is at least
one Market Maker registered for trading
in that series.77 One commenter requests
clarification of NOM’s treatment of
options series without a Market Maker.
In particular, the commenter questions
the actions NOM will take if a Market
Maker withdraws from making markets
in a series, including whether NOM will
continue to match orders in the series.78
73 See
SIFMA Letter, supra note 4, at 2.
Nasdaq Response, supra note 5, at 5.
75 See id. and BOX Rules, Chapter VI, Section
6(d)(i).
76 12 CFR 221.5(c)(6).
77 See NOM Rules, Chapter IV, Section 5.
78 See SIFMA Letter, supra note 4, at 2.
74 See
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In response, Nasdaq states that it is
amending proposed Chapter IV, Section
5 to provide that, in the event a sole
Market Maker for a series withdraws its
registration and ceases making markets,
NOM will place the series in a nonregulatory suspension and halt trading
until such time as a member registers to
make markets in that series.79
In addition, the commenter notes that
the proposal does not address a Market
Maker’s use of the matching system for
new customer orders after it has
withdrawn as a Market Maker.80 To the
extent that the commenter is asking
whether a Market Maker can enter a
customer order when it is not quoting in
a series in which it is registered, Nasdaq
notes that the NOM Rules require that,
if a Market Maker enters a bid in a series
in which he is registered, he must also
enter an offer,81 and that therefore a
Market Maker will not be able to enter
customer orders without submitting a
quote on the other side of the market
from the customer order.82 Further,
Nasdaq notes that the NOM Rules
prohibit a Market Maker from acting as
an OEF without instituting appropriate
information barriers.83 To the extent
that the commenter is asking whether an
entity that withdraws as a Market Maker
in a series can then act as an OEF in that
series, Nasdaq notes that a Participant
that has withdrawn as a Market Maker
and is participating in NOM as an OEF
would not receive favorable margin
treatment under Regulation T.84
The Commission believes that Nasdaq
has adequately clarified NOM’s
treatment of options series when either:
(1) A registered Market Maker is not
quoting in that series or (2) a registered
Market Maker withdraws from
registration in the series.
c. Single Market Maker Requirement
One commenter believes that Nasdaq
should require at least two market
makers for an options series to be listed
and traded on NOM so that adequate
depth and liquidity will be available to
market participants.85 The commenter
79 See Nasdaq Response, supra note 5, at 3.
Nasdaq further notes that, in Amendment No. 2, it
proposes to clarify that in such circumstances,
NOM will not execute orders on its book and will
have no rights and privileges under the Linkage
Plan to accept inbound orders from away markets.
Nasdaq will continue to accept and route
Participant orders that are designated for routing
and execution at the best price in away markets. Id.
80 See SIFMA Letter, supra note 4, at 2.
81 See NOM Rules, Chapter VII, Section 6(b),
which states that a Market Maker that enters a bid
(offer) in a series in which he is registered on NOM
must enter an offer (bid).
82 See Nasdaq Response, supra note 5, at 4.
83 See NOM Rules, Chapter VII, Section 10.
84 See Nasdaq Response, supra note 5, at 4.
85 See Amex Letter, supra note 4, at 2.
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mstockstill on PROD1PC66 with NOTICES
also believes that, in the context of the
order exposure requirements established
in Chapter VII, Section 14 of the NOM
Rules,86 there will not be meaningful
order exposure with a ‘‘trading crowd’’
of fewer than two market makers.87 In
addition, the commenter believes that
the term ‘‘trading crowd’’ may be a
misnomer if the trading crowd consists
of only one market maker.88
In response, Nasdaq asserts that
neither the Act nor Commission rules
require a market to provide for more
than one market maker, and, in fact, the
specialist system is an example of a one
market maker market model.89 Nasdaq
believes that the NOM structure fulfills
the objectives of Section 11A of the Act
by providing a trading platform that will
allow customer orders to meet without
the intervention of a dealer.90 Nasdaq
further maintains that lower barriers to
participation will attract liquidity and
market depth from order entry firms and
other market participants. Nasdaq also
notes that it intends to provide an
environment whereby robust
competition between multiple market
makers will provide depth and
liquidity, but that it does not believe
market participants should be prevented
from trading directly with one another
due to the absence of multiple dealers.91
The Commission agrees that the Act
does not mandate a particular market
model for national securities exchanges,
and believes that many different types
of market models could satisfy the
requirements of the Act. The
Commission does not believe that the
Act requires an exchange to have market
makers.92 Although Market Makers
could be an important source of
liquidity on NOM, they likely will not
be the only source. In particular, the
NOM System is designed to match
86 Amendment No. 2 renumbers this provision as
Chapter VII, Section 12 of the NOM Rules.
87 See Amex Letter, supra note 4, at 1.
88 Id. at 2. Amex also questions the meaning of
the term ‘‘trading crowd’’ in Chapter III, Section 4(f)
of the NOM Rules. Nasdaq notes that it has deleted
the term ‘‘trading crowd’’ from this rule to make
clear that the electronic crowd will be composed of
all NOM Participants, as is the case for other
electronic markets. See Nasdaq Response, supra
note 5, at note 9.
89 See Nasdaq Response, supra note 5, at 8 to 9.
90 Id. at 8.
91 Id. at 9.
92 In its release adopting Regulation ATS, the
Commission rejected the suggestion that a
guaranteed source of liquidity was a necessary
component of an exchange. See Securities Exchange
Act Release No. 40760 (December 8, 1998), 63 FR
70844 (December 22, 1998) (‘‘Regulation ATS
Release’’). See also Securities Exchange Act Release
No. 44983 (October 25, 2001), 66 FR 55225
(November 1, 2001) (File No. SR–PCX–00–25)
(order approving Archipelago Exchange as the
equities trading facility of the Pacific Exchange), at
Section IV.B.
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buying and selling interest of all
Participants on NOM. The Commission
therefore believes that the NOM
structure is consistent with the Act.
D. NOM Trading System
1. Overview
NOM will be a fully automated
electronic system (‘‘System’’) for trading
standardized options, and will be a
facility of Nasdaq, as defined in Section
3(a)(2) of the Act.93 Participants will be
able to enter Displayed Orders on NOM
at single and multiple price levels for
the following order types: 94 Market
Orders; Limit Orders; Reserve Orders; 95
Minimum Quantity Orders; 96
Discretionary Orders; 97 and Price
93 15 U.S.C. 78c(a)(2). The System includes: (1)
An order execution service that allows Participants
to automatically execute transactions in securities
listed and traded on NOM; (2) a trade reporting
service that submits locked-in trades to a registered
clearing agency for clearance and settlement,
transmits last sale reports to the Options Price
Reporting Authority, if required, for dissemination
to the public and industry, and provides
Participants with monitoring and risk management
capabilities; and (3) a data feed(s) that can be used
to display without attribution to Participants’
MPIDs Displayed Orders on both the bid and offer
side of the market for price levels within NOM
using the minimum price variation applicable to the
security. See NOM Rules, Chapter VI, Section 1(a).
See Trading Rules Proposal Notice, supra note 3, for
a more complete description of NOM operation and
rules. The Commission notes that the Plan for
Reporting of Consolidated Options Last Sale
Reports and Quotation Information (‘‘OPRA Plan’’)
requires each party to the plan to collect and
promptly transmit to OPRA all last sale reports
relating to its market. See OPRA Plan, Section V(a).
94 NOM does not propose to trade complex orders
at this time. Participants may enter orders with the
following time-in-force designations: Expire Time;
Immediate or Cancel (‘‘IOC’’); DAY; and Good Til
Cancelled. See NOM Rules, Chapter VI, Section
1(g).
95 A Reserve Order is a limit order with displayed
size and an additional non-displayed amount, both
of which are available for execution against
incoming orders. If the displayed portion of a
Reserve Order is executed fully, the System will
replenish the display portion from reserve up to the
size of the original display amount. The System
creates a new time stamp for the replenished
portion of an order each time it is replenished from
reserve, while the reserve portion retains the time
stamp of its original entry. See NOM Rules, Chapter
VI, Section 1(e)(1).
96 A Minimum Quantity Order must be
designated as IOC and requires that a specified
minimum number of contracts be traded. A
Minimum Quantity Order received prior to the
Opening Cross or after the market close will be
cancelled. See NOM Rules, Chapter VI, Section
1(e)(3).
97 A Discretionary Order has both a displayed
price and size and a non-displayed discretionary
price range at which the entering party is willing
to buy or sell. The non-displayed interest is not
entered into the System book but is converted,
along with the displayed size, into an IOC buy (sell)
order at the highest (lowest) price in the
discretionary price range when displayed contracts
become available on the opposite side of the market
or an execution takes place at any price within the
discretionary price range. If more than one
Discretionary Order is available for conversion into
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14527
Improving Orders.98 Participants may
designate orders to be routed to other
market centers when trading interest is
not present on NOM or to be executed
only on NOM.99 Nasdaq also had
originally proposed to allow
Participants to enter Non-Displayed
Orders.100 Commenters expressed
concerns about the use of NonDisplayed Orders in the options
markets.101 Nasdaq in Amendment No.
2 has proposed to eliminate NonDisplayed Orders.102 Because Nasdaq
has proposed to eliminate this order
type, this order does not make any
findings with respect to Non-Displayed
Orders.
All trading interest on NOM will be
automatically executable. The NOM
System and rules provide for the
ranking, display, and execution of all
orders in price/time priority without
regard to the status of the entity entering
an order.103 Displayed Orders will have
priority over non-displayed interest at
the same price.104 Any price
improvement resulting from an
execution in the System will accrue to
the party taking liquidity.105
an IOC order, the System will convert and process
all such orders in the same order as they were
entered. If an IOC order is not executed in full, the
unexecuted portion of the order is reposted
automatically and displayed in the System book
with a new time stamp at its original displayed
price and with its non-displayed discretionary price
range. See NOM Rules, Chapter VI, Section 1(e)(4).
98 A Price Improving Order is an order to buy or
sell an option at a specified price smaller than the
minimum price variation (‘‘MPV’’) in the security.
Price Improving Orders may be entered in
increments as small as one cent. A Price Improving
Order will be displayed at the MPV in that security
and rounded up for sell orders and down for buy
orders. See NOM Rules, Chapter VI, Section 1(e)(6).
99 See NOM Rules, Chapter VI, Section 11(a). See
also Amendment No. 2 and the Trading Rules
Proposal Notice, supra note 3, at 23871.
100 A Non-Displayed Order was defined as a limit
order that is not displayed in the System but is
available for execution against all incoming orders
until executed in full or cancelled.
101 See Citadel Letter, supra note 4, at 3, and
Amex Letter, supra note 4, at 2.
102 Nasdaq has made corresponding changes
throughout the NOM Rules to reflect the deletion
of this order type.
103 See NOM Rules, Chapter VI, Section 10. In
Amendment No. 2, Nasdaq made a technical change
to Chapter VI, Section 10 to clarify that the System
will execute trading interest at the best price in the
System before executing trading interest at the next
best price. This change does not alter the execution
algorithm as it was proposed. See Amendment No.
2.
104 See NOM Rules, Chapter VI, Section 10(1). At
each price, trading interest will be executed in the
following order: (A) Displayed Orders; (B) the NonDisplayed portion of Reserve Orders, in time
priority among such interest; and (C) the
discretionary portion of Discretionary Orders, in
time priority among such interest.
105 See NOM Rules, Chapter VI, Section 10. One
commenter maintains that the original proposal did
not define ‘‘taker of liquidity’’ and failed to specify
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The Commission believes that NOM’s
proposed execution priority rules are
consistent with the Act. The
Commission notes that one commenter
specifically supported NOM’s price/
time priority algorithm, noting its belief
that ‘‘flat and open’’ systems encourage
better executions and provide increased
liquidity to the market.106 The
Commission also believes that NOM’s
proposed order types are consistent
with the Act, and discusses several
particular order types below.
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2. Attributable Orders
A Displayed Order may be entered
with attribution to a Participant’s MPID
(an Attributable Order) or on an
anonymous basis (a Non-Attributable
Order).107 One commenter expresses
concern that Attributable Orders could
result in discrimination against
particular members.108 The commenter
believes, for example, that it is
beneficial for a firm to identify itself
when facilitating customer order flow
since an exchange and its members may
want to allow particular members to
trade against more than the minimum
guaranteed amount of the order to
encourage the member to send more
order flow to that exchange.109
The commenter also expressed
concern that identifying the entering
firm could encourage internalization.
The commenter also asserts that
Attributable Orders would defeat the
anti-internalization function of the
information barriers between a firm’s
market making and customer order
entry activities.110 The commenter
believes that the internalization concern
is particularly significant in the context
of Nasdaq’s ‘‘first-in-first-out’’ market
model, where orders at a given price
will be executed in sequence, with no
priority for customer orders at the best
price or pro rata distribution among
participants quoting at that price. With
no customer priority or pro rata
allocation among Participants quoting at
the best price, the commenter believes
that a Participant that sees its firm’s
order at the top of the book would be
able to execute against, and internalize,
all of the displayed order.111
how price improvement would accrue to the taker
of liquidity. See Amex Letter, supra note 4, at 3. In
response, Amendment No. 2 modifies NOM’s rules
to indicate that any price improvement will accrue
to the party removing liquidity previously posted to
the Book. See NOM Rules, Chapter VI, Section
10(3). The Commission believes that this change
clarifies NOM’s rules and is consistent with the Act.
106 See GETCO Letter, supra note 4, at 1.
107 See NOM Rules, Chapter VI, Section 1(d).
108 See ISE Letter, supra note 4, at 2.
109 Id. at note 3.
110 Id. at 2–3.
111 Id. at 3.
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In its response letter, Nasdaq notes
that Attributable Orders are a voluntary
feature of the System, and that no firm
will be required to reveal its identity.112
Nasdaq also argues that there is no
selective disclosure; Nasdaq will
publish the identity of the NOM
Participant only when the order is
posted on the NOM book, and that
disclosure will be made simultaneously
to all market participants in a
proprietary data feed.113 Further,
Nasdaq notes that information barriers
are designed to prevent a Market Maker
from obtaining and using information
about customer orders prior to
execution, and that OEFs must route
customer orders to the best available
market, even if that is the market
displaying the firm’s Attributable
Order.114 Nasdaq also believes that its
price/time algorithm allows less
internalization than ISE’s pro rata
allocation, which guarantees 40% of the
order to a market maker under certain
conditions. Nasdaq further notes that
there is always the possibility that an
incoming order trades with a Price
Improving Order, rather than a
displayed Attributable Order.
To the extent that a market participant
is concerned that its order would be
discriminated against, as Nasdaq notes,
the market participant can choose to
enter a Non-Attributable Order. In
addition, the Commission does not
believe that it is likely that participants
in a fully electronic market, such as
NOM, will refrain from trading with a
particular Participant’s Attributable
Orders in order to allow that Participant
to do so, particularly in light of their
best execution obligations.
Moreover, the Commission does not
believe that a member’s use of
Attributable Orders, by itself, will cause
a Market Maker to violate NOM’s
information barrier rule. The purpose of
requiring information barriers is to
prohibit the flow of material non-public
information between the market making
activities and other business activities of
a firm. With respect to Attributable
Orders, a Market Maker will learn the
identity of an Attributable Order at the
same time as all other Participants—that
is, once it is displayed on NOM and
disseminated over NOM’s proprietary
data feed. The Market Maker will not
have any knowledge of the order prior
to that time. The Commission does not
believe that allowing Market Makers to
see this information once it is posted on
the book undermines the policy of
having information barriers. The
112 See
Nasdaq Response, supra note 5, at 7.
113 Id.
114 Id.
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Commission might reach a different
conclusion, however, if order attribution
information were disclosed
preferentially to certain Participants or
if Market Makers had a systemic or
other advantage that allowed them to
receive this information in a more
timely manner.
3. Reserve Orders and Price Improving
Orders 115
Nasdaq proposes to allow participants
to enter Reserve Orders, which are limit
orders with displayed size and an
additional non-displayed amount, both
of which are available for execution
against incoming orders. If the
displayed portion of a Reserve Order is
executed fully, the System will
replenish the display portion from
reserve up to the size of the original
display amount. The non-displayed
portion of a Reserve Order has lower
priority than any displayed order.
In addition, Nasdaq proposes a new
order type called a Price Improving
Order. A Price Improving Order has a
specified price smaller than the
minimum price variation (‘‘MPV’’) in
the option. Price Improving Orders may
be entered in increments as small as one
cent. Price Improving Orders will be
displayed at the MPV in that security
and rounded up for sell orders and
down for buy orders. For the reasons
discussed below, the Commission finds
Reserve Orders and Price Improving
Orders consistent with the Act.
a. Quote Rule
One commenter argues that Price
Improving Orders would violate Rule
602 of Regulation NMS (the ‘‘Quote
Rule’’) because Nasdaq will not
disseminate its best bid or offer.116
The Quote Rule requires a national
securities exchange to collect, process,
and make available to vendors the best
bid, the best offer, and aggregate
quotation sizes for each subject security
that is communicated on any national
securities exchange by a responsible
broker or dealer. A ‘‘bid’’ or ‘‘offer’’ is
defined as ‘‘the bid price or the offer
price communicated by a member of a
national securities exchange or member
of a national securities association to
any broker or dealer, or to any customer.
115 Nasdaq has proposed in Amendment No. 2 to
eliminate the Non-Displayed Order type. Therefore,
this approval order does not discuss Non-Displayed
Orders. See supra notes 100 to 102 and
accompanying text.
116 See ISE Letter, supra note 4, at 2
(incorporating by reference the commenter’s June 1,
2007, letter from Michael J. Simon, Secretary, ISE,
to Nancy M. Morris, Secretary, Commission,
regarding File No. SR–CBOE–2007–39 (‘‘ISE June
2007 Letter’’)).
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* * * ’’ 117 Because the non-displayed
size of a Reserve Order or the nondisplayed price of a Price Improving
Order is sent to NOM but not
communicated to anyone, it is not a bid,
offer, or quotation. Thus, the Quote Rule
does not require this information to be
disseminated.118
The Quote Rule also requires
responsible brokers and dealers to be
firm for their quotes.119 In Amendment
No. 2 Nasdaq has proposed to modify
Chapter VII, Section 6(c)(1) of the NOM
Rules to explicitly state that all quotes
and orders entered into NOM by
Options Participants, including the nondisplayed portions of Reserve Orders
and Price Improving Orders, must be
firm under NOM rules and Rule 602 of
Regulation NMS.
b. Transparency, Quote Competition,
and Internalization
Several commenters expressed
concern about the impact of Price
Improving Orders and Reserve Orders
on market quality. In particular, one
commenter believes such orders will
undermine transparency in the options
markets and that, because the prices and
sizes of such orders are not
disseminated, it will be impossible for
market participants to know the true
best trading interest on NOM.120 This
commenter argues that Price Improving
Orders will discourage market
participants from quoting their best
prices and submitting displayable limit
orders because contra-side orders could
be ‘‘pennied’’ by Price Improving Orders
at opportune moments. The commenter
believes that these disincentives
ultimately will reduce price competition
in the U.S. options markets.121 Another
commenter expresses a concern that no
one will know the actual prices
communicated to the exchange, which
are prices at which transactions can take
place.122 This commenter is concerned
that if other options markets adopted
similar order types, there would be a
trading environment in which there
would be no way for customers to make
intelligent pricing decisions or for
117 17
CFR 242.600(a)(8).
also Citadel Letter, supra note 4, at 4
supporting this analysis.
119 17 CFR 242.602(b)(2) and (c)(3).
120 See Citadel Letter, supra note 4, at 1–3.
121 See Citadel Letter, supra note 4, at 3. The
commenter further believes that the concerns raised
by Hidden Orders exceed those raised by the
auction facilities on other options exchanges
(including BOX’s PIP and the International
Securities Exchange’s PIM) because Hidden Orders
would be a fundamental component of NOM rather
than a separate auction facility operating parallel to
the regular options market. Id.
122 See ISE Letter, supra note 4, at note 1–2.
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118 See
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broker-dealers to fulfill their best
execution obligations.123
One commenter expresses the concern
that Price Improving Orders will enable
Participants to internalize their order
flow without the possibility of real order
interaction. This commenter argues that
the purpose of the requirement that a
member display a customer order and
wait three seconds before trading
against the order is to provide other
market participants with a chance to
trade with the order before the member
internalizes it. The commenter argues
that, because only the Participant that
enters the Price Improving Order will
know the true price of the order, only
that member can accurately run its
pricing model to determine whether it is
economically viable to trade against the
order. The commenter does not believe
this is a level playing field.124 Similarly,
another commenter asserts that
permitting Price Improving Orders to
satisfy NOM’s order exposure
requirement 125 will ‘‘invite rampant
internalization’’ by Participants, who
will be able to trade with their agency
orders without the market having a
meaningful opportunity to compete for
the orders.126
On the other hand, another
commenter asserts that the use of nondisplayed and reserve orders, which
have been available for years in the
equity markets, has not diminished
competition or liquidity in these
markets.127 This commenter believes
that Reserve Orders will encourage
liquidity providers to bring their interest
to the market in a manner best suited to
their trading requirements. The
commenter further believes that the
increased use of reserve orders in the
options markets would help to mitigate
concerns regarding the effect of penny
increments on institutional investors.128
123 Id.
at 2.
ISE June 2007 Letter, supra note 116, at
124 See
3.
125 See NOM Rules, Chapter VII, Section 12.
Chapter VII, Section 12 of the NOM Rules prohibits
a Participant from executing as principal an order
it represents as agent unless (1) the order is exposed
on NOM for at least three seconds, or (2) the
Participant has been bidding or offering on NOM for
at least three seconds prior to receiving the agency
order that is executable against such bid or offer.
126 See Citadel Letter, supra note 4, at 3. This
commenter further argues that Nasdaq should
amend Chapter VII, Section 12, Commentary .04 to
provide that a Participant cannot inform another
Options Participant or any other third party of the
terms of an order submitted to NOM after, as well
as prior to, submitting the order to NOM. Nasdaq
has made this change in Amendment No. 2.
127 See GETCO Letter, supra note 4, at 2–3.
128 Id. at 3. The commenter also notes that the
Commission previously approved a reserve order
type for NYSE Arca Options, citing to NYSE Arca
Options Rule 6.62(c)(3). Id. at note 6 and
accompanying text.
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14529
Price Improving Orders will allow
market participants to submit an order
priced between the MPV that will be
rounded to the nearest MPV for
display.129 Without this order type,
market participants would not be able to
submit orders priced between the MPV.
Instead, orders, if submitted, would be
priced (and displayed) at the MPV.
Thus, the Price Improving Order type
will not ‘‘take away’’ transparency that
would already exist. The Commission
recognizes that Price Improving Orders
will not be displayed at their actual
penny price. Price Improving Orders,
however, will provide for investors the
opportunity to trade at a better price
than would otherwise be available—
inside the disseminated best bid and
offer for a security. The Commission
believes that this opportunity for
investors to receive executions inside
the disseminated best bid or offer could
result in better executions for investors,
and that Price Improving Orders are
consistent with the Act.
In response to a commenter’s concern
about broker-dealers’ ability to fulfill
their best execution obligations,130 as
just discussed, the Commission believes
that Price Improving Orders likely will
provide another opportunity for
investors to receive executions inside
the disseminated best bid or offer for a
security, which could result in better
executions for investors. The
availability of this price improvement
feature will be a factor to be considered
in a broker-dealer’s best execution
routing determination, similar to other
factors a broker-dealer must consider in
connection with its best execution
obligation.
The duty of best execution requires a
broker-dealer to seek the most favorable
terms reasonably available under the
circumstances for a customer’s
transaction.131 The Commission has not
viewed the duty of best execution as
requiring automated routing on an
order-by-order basis to the market with
the best quoted price at that time.
Rather, the duty of best execution
requires broker-dealers to periodically
assess the quality of competing markets
129 Price Improving Orders are defined as orders
to buy or sell at a specified increment smaller than
the MPV in a security, and they may be entered in
increments as small as one cent. See NOM Rules,
Chapter VI, Section 1(e)(6). Because a Price
Improving Order can only be entered in an
increment smaller than the MPV in an options
series, and cannot be entered in an increment
smaller than one cent, Participants will not be able
to enter Price Improving Orders in options series for
which the MPV is a penny.
130 See ISE Letter, supra note 4, at note 1–2.
131 See, e.g., Securities Exchange Act Release No.
37619A (September 6, 1996), 61 FR 48290
(September 12, 1996) (‘‘Order Handling Rules
Release’’).
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to assure that order flow is directed to
markets providing the most beneficial
terms for their customer orders.132
Broker-dealers must examine their
procedures for seeking to obtain best
execution in light of market and
technology changes and modify those
practices if necessary to enable their
customers to obtain the best reasonably
available terms.133 In doing so, brokerdealers must take into account price
improvement opportunities, and
whether different markets may be more
suitable for different types of orders or
particular securities.134
The Commission also believes that
Price Improving Orders will provide
market participants with an additional
tool to submit trading interest to the
Exchange. This order type may serve to
increase liquidity to the extent that
market participants find the order type
to be useful and result in better
executions. Further, market participants
may be incented to compete by putting
forth their best price—priced in a penny
increment—to potentially match or
better any other Price Improving Orders
resident in the System. This may result
in more aggressive, rather than less
aggressive, trading interest.
The Commission also believes that
Reserve Orders will provide market
participants with an additional tool to
submit trading interest to the exchange.
Specifically, the ability to enter an order
with a certain size displayed and
additional size not displayed may
provide market participants greater
choice to submit trading interest in a
manner best suited to their trading
needs. This in turn may encourage
market participants to bring liquidity to
the exchange that they might not
otherwise have submitted.
132 Order Handling Rules Release, 61 FR at
48322–48333 (‘‘In conducting the requisite
evaluation of its internal order handling
procedures, a broker-dealer must regularly and
rigorously examine execution quality likely to be
obtained from different markets or market makers
trading a security.’’). See also Newton v. Merrill,
Lynch, Pierce, Fenner & Smith, Inc., 135 F.3d 266,
at 271, 274 (3d Cir.), cert. denied, 525 U.S. 811
(1998); Payment for Order Flow, Securities
Exchange Act Release No. 34902 (October 27, 1994),
59 FR 55006, at 55009 (November 2, 1994).
133 Order Handling Rules, 61 FR at 48323.
134 Order Handling Rules, 61 FR at 48323. For
example, in connection with orders that are to be
executed at a market opening price, ‘‘[b]rokerdealers are subject to a best execution duty in
executing customer orders at the opening, and
should take into account the alternative methods in
determining how to obtain best execution for their
customer orders.’’ Disclosure of Order Execution
and Routing Practices, Securities Exchange Act
Release No. 43590 (November 17, 2000), 65 FR
75414, 75422 (December 1, 2000) (adopting new
Exchange Act Rules 11Ac1–5 and 11Ac1–6 and
noting that alternative methods offered by some
Nasdaq market centers for pre-open orders included
the mid-point of the spread or at the bid or offer).
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Moreover, the Commission believes
that the ability to ‘‘fish’’ inside the
displayed quote, coupled with the
restriction on the Participant that
initially submitted the Price Improving
Order from trading with that order until
after three seconds has elapsed, will
provide a meaningful opportunity for
interaction prior to the time at which
the submitting Participant can interact
with the order. The Commission also
notes that a Participant that would like
to trade against its customer order runs
the risk that the customer order, if
entered as a Price Improving Order, will
execute against another Price Improving
Order (or Discretionary Order) resident
in the system. The Commission does not
believe that the availability and use of
Price Improving Orders will reduce the
quality or competitiveness of the
options markets by increasing the level
of internalization in the options
markets.
c. Linkage Plan
One commenter believes that the
Trading Rules Proposal fails to address
how Reserve Orders and Price
Improving Orders will interact with the
requirements of the Plan for the Purpose
of Creating and Operating an
Intermarket Options Linkage (‘‘Linkage
Plan’’).135 Specifically, this commenter
notes that, because such orders are not
disseminated, they presumably will not
trigger other options markets’
obligations to avoid trading through or
obligate other markets to send orders to
NOM through the Linkage.136
Accordingly, the commenter believes
that away markets will fail to benefit
from superior prices available on NOM,
and Non-Displayed Orders and Price
Improving Orders will undermine
market-wide trade-through
protection.137
In its response, Nasdaq states that
incoming orders from the intermarket
linkage will interact with Price
Improving Orders. Such incoming
orders will automatically execute
against any such order with a better
price than the displayed bid or offer.138
The Commission believes that NOM’s
Rules adequately address how its
market will interact with the Linkage
Plan. The Linkage Plan, and SRO rules
adopted pursuant to the Plan, provide
trade through protection to the national
135 See Citadel Letter, supra note 4, at 3. Another
commenter generally states its belief that the
concept of a Non-Displayed Order is inconsistent
with the obligations required by the Linkage Plan.
See Amex Letter, supra note 4, at 2.
136 See Citadel Letter, supra note 4, at 3.
137 Id.
138 See Nasdaq Response, supra note 5, at 13.
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best bid and offer (‘‘NBBO’’).139 The
NBBO will not include the nondisplayed price of a Price Improving
Order or the reserve size of a Reserve
Order. Therefore, the non-displayed
price of a Price Improving Order and the
non-displayed size of a Reserve Order
are not subject to trade through
protection under the Linkage Plan.
d. Penny Pilot
One commenter believes that the
Trading Rules Proposal will circumvent
the industry efforts with respect to the
Penny Pilot Program by moving to
hidden penny quoting without the
benefit of careful study of the data
yielded in the Pilot.140 Another
commenter believes that the appropriate
way to address penny pricing in options
is through the current Penny Pilot. This
commenter recommends that the
Commission consider any expansion of
penny quoting only through review of
the experience under the Pilot.141
As discussed above and below, the
Commission finds that the Trading
Rules Proposal, as amended, is
consistent with the Act. The
Commission previously has approved
proposals by other options exchanges to
trade in penny increments.142 The
Commission does not believe it is
appropriate to prohibit Nasdaq from
implementing another initiative
designed to allow limited trading, not
quoting, in penny increments.
4. Opening and Halt Cross
Nasdaq had originally proposed a
single price opening and reopening via
an electronic cross, modeled on the
Opening and Halt Crosses Nasdaq
developed for the trading of equities.143
Nasdaq in Amendment No. 2 proposes
to revise the procedures it will use to
resume trading in an option following
the conclusion of a trading halt in the
underlying security. Specifically, rather
than using a single price reopening
following a trading halt, as originally
139 The national best bid or offer is defined in the
Linkage Plan as the national best bid and offer in
an options series calculated by a Participant. See
Section 2(19) of the Linkage Plan.
140 See Citadel Letter, supra note 4, at 4.
141 See ISE June 2007 Letter, supra note 116, at
3.
142 See, e.g., Securities Exchange Act Release Nos.
54229 (July 27, 2006), 71 FR 44508 (August 3, 2006)
(File No. SRSR–CBOE–2005–90) (order approving
CBOE’s Simple Auction Liaison system); 50819
(December 8, 2004), 69 FR 75093 (December 15,
2004) (File No. SR–ISE–2003–06) (order approving
ISE’s Price Improvement Mechanism); and BOX
Approval Order, supra note 72 (approving BOX’s
Price Improvement Period).
143 See NOM Rules, Chapter VI, Section 8. See
Trading Rules Proposal Notice, supra note 3, for a
detailed description of the proposed Opening and
Halt Crosses.
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proposed, Nasdaq proposes to process
orders in time priority according to the
execution algorithm provided in the
NOM Rules.144 According to Nasdaq,
the proposal to use NOM’s regular
processing following a trading halt is
designed to respond to comments from
industry participants that options prices
are based on the prices of the
underlying security.145
The Commission believes that NOM’s
rules for an Opening Cross will help to
ensure that the opening of NOM is
conducted in a fair and orderly fashion
and is consistent with the Act. The
Commission further believes that the
proposed change to NOM’s procedure
for re-opening trading in an option
following the conclusion of a trading
halt in the underlying security is
reasonably designed to provide for an
orderly re-opening of trading in the
option and is consistent with the Act.
5. Closing Cross
At the close of trading, NOM will
conduct a single price Closing Cross.146
One commenter notes that the rules, as
originally proposed, provided that the
Closing Cross for all options would
occur at 4 p.m., although options on
fund shares and broad-based indexes
trade until 4:15 p.m., and did not
indicate when the Closing Cross would
terminate.147 In response, Nasdaq in
Amendment No. 2 revised Chapter VI,
Section 9(b) of the NOM Rules to
indicate that the Closing Cross for
options on broad-based indexes and
fund shares will occur at 4:15 p.m. In
addition, Nasdaq indicated that the
Closing Cross occurs automatically and
generally takes place in under one
second, although the process may take
several seconds on high-volume trading
days.148 The Commission believes that
these changes adequately clarify the
timing of the Closing Cross.149
One commenter notes that the NOM
Rules indicate that an MOC order might
not be executed. The commenter
believes that an MOC order is a market
order, and the operation of the Closing
Cross will alter the nature of a market
order as generally understood by market
participants. The commenter further
144 See
NOM Rules, Chapter VI, Section 10(4).
Amendment No. 2 at 7.
146 See NOM Rules, Chapter VI, Section 9. See
also Trading Rules Proposal Notice, supra note 3,
for a more detailed description of the proposed
Closing Cross.
147 See Amex Letter, supra note 4, at 3.
148 See Nasdaq Response, supra note 5, at 10.
149 In Amendment No. 2, Nasdaq proposes
changes to the definitions of Imbalance Only (‘‘IO’’),
Market on Close (‘‘MOC’’), and Limit on Close
(‘‘LOC’’) orders to replace certain times specified in
the rules (e.g., 3:50:00 p.m.) with more general
descriptions (e.g., 10 minutes prior to the close).
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believes that Nasdaq should better
explain the operation of MOC orders.150
In response, Nasdaq acknowledges that
MOC orders are not guaranteed to
execute during the Closing Cross but
notes that MOC orders receive the
highest execution priority during the
Closing Cross process.151 Thus, Nasdaq
states that MOC orders should execute
at the cross price provided that there is
adequate trading interest on the other
side of the market.152
As noted above, the NOM Closing
Cross is modeled on the Closing Cross
that Nasdaq uses in its equity market.153
Like the NOM Closing Cross, the Nasdaq
Closing Cross includes MOC orders,
which might not be executed during the
Nasdaq Closing Cross.154 The
Commission believes that NOM’s rules
adequately explain the operation of
MOC orders.
Nasdaq proposes to disseminate in
connection with the Opening Cross and
Closing Cross an Order Imbalance
Indicator.155 The Order Imbalance
Indicator for the Closing Cross will
disseminate, in part, the following
information: (1) A Current Reference
Price, which is the single price that is
at or within the current NOM best bid
and offer at which the maximum
number of contracts of MOC, LOC, IO,
and Close Eligible Interest 156 can be
paired; 157 (2) a Far Clearing Price,
which is an indicative price at which
MOC, LOC, and IO orders would
execute if the Closing Cross were to
occur at that time; and (3) a Near
150 See
Amex Letter, supra note 4, at 3.
Nasdaq Response, supra note 5, at 10 to
11. See also NOM Rules, Chapter VI, Section
9(b)(3).
152 See Nasdaq Response, supra note 5, at 11.
153 See Nasdaq Rule 4754.
154 See Nasdaq Rule 4754(b)(3).
155 See proposed Chapter VI, Sections 8(a)(2) and
9(a)(7) of the NOM Rules. For the Opening Cross,
Nasdaq will disseminate the Order Imbalance
Indicator every five seconds beginning at 9:25 a.m.
For the Closing Cross, Nasdaq will disseminate the
Order Imbalance Indicator every five seconds for 10
minutes prior to the Closing Cross. See proposed
NOM Rules, Chapter VI, Sections 8(a)(2) and 8(b)(1)
and 9(a)(7) and 9(b)(1) for a detailed description of
the Order Imbalance Indicator.
156 Close Eligible Interest is defined to mean any
quotation or any order that may be entered into the
system and designated with a time-in-force of DAY,
GTC, or EXPR. See proposed Chapter VI, Section
9(a)(1) of NOM Rules.
157 If more than one price exists pursuant to this
calculation, the Current Reference Price is the price
that minimizes any Imbalance. If more than one
price exists under that calculation, the Current
Reference Price is the entered price at which
contracts will remain unexecuted in the cross. And,
if more than one price exists under that calculation,
the Current Reference Price is the price that
minimizes the distance from the bid-ask midpoint
of the inside quotation prevailing within the NOM
System at the time of the order imbalance indicator
dissemination. See proposed Chapter VI, Section
9(a)(7)(A) of the NOM Rules.
151 See
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14531
Clearing Price, which is an indicative
price at which MOC, LOC, IO, and Close
Eligible Interest would execute if the
Closing Cross were to occur at that
time.158
One commenter notes that the Order
Imbalance Indicator would show the
price in penny increments at which
certain orders would execute at the time
the Order Imbalance Indicator is
disseminated.159 The commenter
believes that the Order Imbalance
Indicator is inconsistent with the
options Penny Pilot Program and that
the Order Imbalance Indicator should be
disseminated in the applicable
minimum price variation for an option,
rather than in penny increments.160
In its response, Nasdaq states that the
Order Imbalance Indicator will benefit
investors and improve transparency by
providing market participants with
information that will allow them to
route customer orders to the best
market.161 To ensure that the Order
Imbalance Indicator fully complies with
Rule 602 of Regulation NMS, however,
Nasdaq proposes in Amendment No. 2
to modify the proposed NOM Rules
relating to the Closing Cross to state that
the Current Reference Price and Near
Clearing Price 162 will be disseminated
in the minimum price increment
applicable to the option in question and
never at a price that would expose
undisplayed trading interest that is
available for execution on the NOM
Book. Nasdaq states that only the
Current Reference Price and Near
Clearing Price are affected by this
restriction because they are the only
aspects of the Order Imbalance Indicator
that may include information based on
non-displayed orders resting on the
NOM book.163 Nasdaq further states that
the remaining data elements of the
Order Imbalance Indicator do not
transmit information regarding the
158 For the Opening Cross, the Far Clearing Price
and Near Clearing Price will be the same as the
Current Reference Price. See proposed Chapter VI,
Section 8(a)(2)(A) and (E) of the NOM Rules.
159 See Amex Letter, supra note 4, at 2.
160 Id. The Penny Pilot Program of the various
options exchanges allows the exchanges to quote
certain options classes in one-cent or five-cent
increments, depending on the price of the option.
See, e.g., Securities Exchange Act Release No.
56567 (September 28, 2007), 72 FR 56396 (October
3, 2007) (order approving File No. SR–Amex–2007–
96).
161 See Nasdaq Response, supra note 5, at 9.
162 See NOM Rules, Chapter VI, Sections
9(a)(7)(A) and 9(a)(7)(E)(ii).
163 This is because the Current Reference Price
and Near Clearing Price take into account the Close
Eligible Interest, which is defined as any quotation
or any order that may be entered into the System
and designated with a time-in-force of DAY, GTC,
or EXPR. Thus, Close Eligible Interest includes
orders, including non-displayed orders, on the
NOM Book.
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pricing of specific orders and therefore
do not implicate Rule 602 of Regulation
NMS.164
The Commission agrees with Nasdaq’s
analysis and believes that the Order
Imbalance Indicator, as proposed to be
amended in Amendment No. 2, is
consistent with Rule 602 of Regulation
NMS. Nasdaq will not disseminate the
prices of non-displayed orders resting
on the NOM book after the Opening
Cross 165 and therefore, such nondisplayed orders will not be bids or
offers 166 required to be made available
to vendors by the Exchange under Rule
602. Further, the Commission does not
believe that the Order Imbalance
Indicator, as amended, is inconsistent
with the Penny Pilot because it will not
make available during regular trading
hours information in a pricing
increment other than the MPV.
6. Obvious Errors
The Commission believes that in most
circumstances trades that are executed
between parties should be honored. On
rare occasions, the price of the executed
trade indicates an ‘‘obvious error’’ may
exist, suggesting that it is unlikely that
the parties to the trade had come to a
meeting of the minds regarding the
terms of the transaction. In the
Commission’s view, the determination
of whether an ‘‘obvious error’’ has
occurred should be based on specific
and objective criteria and subject to
specific and objective procedures.167
In Amendment No. 2, Nasdaq revised
its proposed rule dealing with options
obvious errors. Specifically, Nasdaq
amended Chapter V, Section 6, Obvious
Errors, to: (1) Apply the obvious error
rule solely to obvious price errors and
to series quoted no bid; (2) streamline
the procedures governing review of
obvious error requests by the Market
Operations Review Committee
(‘‘MORC’’); and (3) add a provision
stating that the MORC must include
representatives of one member engaged
in market making and two industry
164 See
Nasdaq Response, supra note 5, at 6 and
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9.
165 The Commission does not believe that the
Order Imbalance Indicator disseminated prior to the
Opening Cross (and thus disseminated prior to the
9:30 a.m. EST) raises the same issues under the
Quote Rule because the information will be
disseminated prior to the commencement of trading
on the exchange. See Rule 602(a)(1)(i)(B) of
Regulation NMS, 17 CFR 242.602(a)(1)(i)(B).
166 See Rule 600(b)(8) of Regulation NMS, 17 CFR
242.600(b)(8).
167 See, e.g., Securities Exchange Act Release Nos.
54608 (October 16, 2006), 71 FR 62021 (October 20,
2006) (File No. SR–Amex–2005–60) (order
approving changes to Amex’s obvious error rule);
47628 (April 3, 2003), 68 FR 17697 (April 10, 2003)
(File No. SR–CBOE–00–55) (order approving CBOE
Direct); and BOX Approval Order, supra note 72.
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representatives not engaged in market
making, and that at no time shall
members engaged in market making
constitute more than 50% of the MORC.
The Commission believes that the
provisions of Nasdaq’s obvious error
rule, as revised by Amendment No. 2,
are consistent with the Act and, in
particular, with Section 6(b)(5), in that
they provide clear and objective
standards and procedures for
determining whether an obvious error
has occurred. The Commission also
believes that the revised proposed rule
is consistent with obvious error rules
previously approved by the Commission
for other exchanges.168
One commenter seeks clarification as
to who will be responsible for trade
errors in the context of the Linkage.169
Nasdaq states that NOM’s Rules
recognize only Obvious Errors, as
defined in Chapter VI, Section 6 of the
NOM Rules. If a trade does not meet the
definition of an Obvious Error, NOM
will take no action with respect to the
trade. In the event of an Obvious Error
on NOM involving an away market, the
away market is authorized as a party to
the transaction to file with NOM for
review of the Obvious Error. In the
event of an Obvious Error on an away
market, NOM’s Obvious Error rule
authorizes NOM to file for review of that
Obvious Error on behalf of the NOM
Participant. If necessary, NOM will file
for such review through NOS or the
member of the away market which it
used to route the order.170
7. Miscellaneous
One commenter believes that, under
the NOM Rules, quotes are the same as
orders and therefore reads Chapter VI,
Section 5(b) of the NOM Rules to mean
that Nasdaq proposes to trade all
options series on NOM in penny
increments, in violation of the Penny
Pilot Program.171
In response, Nasdaq states that the
commenter has misread the proposal
and that Nasdaq does not propose to
quote all options on NOM in penny
increments. In this regard, Nasdaq notes
that Chapter VI, Section 5(a) of the NOM
168 See, e.g., Securities Exchange Release Nos.
54228 (July 27, 2006), 71 FR 44066 (August 3, 2006)
(File No. SR–ISE–2006–14) (approving current
version of ISE Rule 7.20 (options obvious error
rule)); 54070 (June 29, 2006), 71 FR 38441 (July 6,
2006) (File No. SR–Phlx–2005–73) (approving
current version of Phlx Rule 1092 (options obvious
error rule)); and 56487 (September 20, 2007), 72 FR
54956 (September, 27, 2007) (File No. SR–CBOE–
2007–04) (approving current version of CBOE Rule
6.25 (options obvious error rule)).
169 See SIFMA Letter, supra note 4 at 2.
170 See Nasdaq Response, supra note 5, at 9, and
Amendment No. 2.
171 See Amex Letter, supra note 4, at 2.
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Rules governs quotation increments and
is consistent with the Penny Pilot
Program, while Section 5(b) specifies
the minimum trading increment on
NOM.172 The Commission believes that
Nasdaq has clarified that it does not
propose to quote all options on NOM in
penny increments and that the NOM
Rules are consistent with the Penny
Pilot Program. The Commission also
does not believe that trading in penny
increments is inconsistent with the
Penny Pilot Program.173
In response to questions from
commenters regarding the NOM closing
time,174 Nasdaq in Amendment No. 2
proposes to modify the NOM Rules to
provide that the NOM closing time will
be 4 p.m. ET, except for options on
broad-based indexes and Fund Shares,
which will close at 4:15 p.m. ET.175 The
Commission believes that these
modifications will make NOM’s closing
time consistent with the rules of the
other U.S. options exchanges.176
E. Order Routing
With respect to securities traded on
NOM (‘‘System Securities’’), 177
Participants may designate orders to be
routed to another market center when
trading interest is not available on NOM
or to execute only on NOM.178 Orders
that are designated to be routed will be
routed to another options market when
NOM is not at the NBBO, consistent
with the locked and crossed market and
trade through provisions of the Linkage
Plan.179 Orders routed by the System to
other markets do not retain time priority
with respect to other orders in the
System and the System will continue to
execute other orders while routed orders
are away at another market center.180 If
a routed order is returned, in whole or
in part, that order (or its remainder) will
receive a new time stamp reflecting the
time of its return to the System.181
Participants whose orders are routed to
172 See
Nasdaq Response, supra note 5, at 7.
supra note 142 and accompanying text.
174 See Amex Letter, supra note 4, at 4, and
SIFMA Letter, supra note 4, at 2.
175 See NOM Rules, Chapter VI, Section 2.
176 See, e.g., ISE Rule 700 and CBOE Rules 6.1
and 24.6. In addition, in Amendment No. 2 Nasdaq
proposes to revise Chapter VI, Section 2 of the NOM
Rules to indicate that the System will be available
to accept bids, offers, and orders beginning at 9
a.m., rather than 8 a.m. Similarly, Nasdaq proposes
in Amendment No. 2 to revise Chapter VI, Section
9 of the NOM Rules to indicate that IO orders, LOC
orders, and MOC orders may be entered beginning
at 9 a.m., rather than 8 a.m.
177 See NOM Rules, Chapter VI, Section 1(b).
178 See NOM Rules, Chapter VI, Section 11(a) and
Amendment No. 2.
179 See id. and infra note 195 and accompanying
text.
180 See NOM Rules, Chapter VI, Section 11(c).
181 Id.
173 See
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away markets will be obligated to honor
such trades to the same extent they will
be obligated to honor a trade executed
on NOM.182
One commenter believes that NOM’s
rules, as proposed, provided different
order routing attributes for ‘‘system’’
and ‘‘non-system’’ securities, but failed
to adequately define these terms,
resulting in confusion regarding the
operation of the order routing
mechanism.183
In response, Nasdaq, in Amendment
No. 2, proposes to revise proposed
Chapter VI, Section 1(b) of the NOM
Rules to define ‘‘System Securities’’ as
all options currently trading on NOM,
and to define ‘‘Non-System Securities’’
as all other options. Nasdaq states it will
accept orders in Non-System Securities
for routing but will not execute these
orders in the System.184 Nasdaq
represents that System and Non-System
Securities will be identified clearly via
the NOM data feed and in a daily list
posted on the NOM Web site.185 Nasdaq
further states that the System will be
programmed to differentiate between
System Securities and Non-System
Securities and will process each in
accordance with the NOM Rules.186 The
Commission believes that Nasdaq’s
proposed changes and response
adequately clarify the operation of the
order routing mechanism for ‘‘System
Securities’’ and ‘‘Non-System
Securities.’’
In Amendment No. 2, Nasdaq further
proposes to amend proposed Chapter
VI, Section 11(e) of the NOM Rules to
establish Nasdaq Options Services LLC
(‘‘NOS’’) as NOM’s exclusive order
router. NOS will perform only two
functions, the routing of orders with
respect to System Securities and the
routing of orders with respect to NonSystem Securities. Nasdaq states that
NOS will be a facility of Nasdaq only
with respect to the routing of orders for
System Securities.187 NOS will be
programmed to follow the algorithm and
order type instructions established in
the NOM Rules and will not have
discretion to change the terms of an
order or the order routing
instructions.188
NOS will be a member of an SRO
unaffiliated with Nasdaq that is its
designated examining authority, and
NOM will establish and maintain
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182 See
NOM Rules, Chapter VI, Section 11(d).
Amex Letter, supra note 4, at 3.
184 See Nasdaq Response, supra note 5, at 11. See
also NOM Rules, Chapter VI, Section 11(a).
185 See Nasdaq Response, supra note 5, at 11.
186 Id.
187 See NOM Rules, Chapter VI, Section 11(e) and
Nasdaq Response, supra note 5, at 11.
188 See Nasdaq Response, supra note 5, at 11.
183 See
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procedures and internal controls
reasonably designed to restrict the flow
of confidential and proprietary
information between Nasdaq and its
facilities, including NOS, and any other
entity.189 In addition, the books,
records, premises, officers, directors,
agents, and employees of NOS, as a
facility of Nasdaq, will be deemed to be
those of the Exchange for purposes of
and subject to oversight pursuant to the
Act.190 Further, Participants are not
required to use NOS to route orders, and
a Participant may route its orders
through any available router it
selects.191
The Commission agrees with the
Exchange that routing with respect to
System Securities will be a ‘‘facility’’ of
the Exchange, and, consequently, the
operation of NOS in this capacity will
be subject to Exchange oversight, as well
as Commission oversight. The
Commission notes that the functionality
to be provided by NOS is not the
exclusive means for accessing betterpriced orders in other market centers.
Accordingly, NOS’s routing services are
optional, and a NOM Participant is free
to route its orders to other market
centers through alternative means. In
light of the protections discussed above,
including the regulation of NOS as a
facility of the Exchange with respect to
the routing of orders for System
Securities, the Commission believes that
Nasdaq’s rules and procedures regarding
the use of NOS to route orders to away
markets are consistent with the Act.192
F. Linkage
As described above, Nasdaq proposes
to use NOS to route orders to other
options exchanges. NOM will, however,
participate in the Linkage Plan to
receive orders from options exchanges
that use the Linkage to route orders. To
receive orders through the Linkage,
Nasdaq proposes to adopt rules relating
to the Linkage Plan that are
substantially similar to the rules of the
other options exchanges that participate
in the Linkage Plan. In general, the
proposed rules include relevant
definitions; establish the conditions
189 See
NOM Rules, Chapter VI, Section 11(e).
In addition, the books and records of NOS,
as a facility of the Exchange, will be subject at all
times to inspection and copying by the Exchange
and the Commission. Id.
191 See Nasdaq Response, supra note 5, at 11. See
also NOM Rules, Chapter VI, Section 1(b) (allowing
Participants to designate orders as available for
routing or not available for routing).
192 In addition, the Commission notes that the
Nasdaq rules and procedures applicable to NOS are
similar to the rules and procedures adopted by
other exchanges to govern their order routers. See,
e.g., ISE Rule 2108; NYSE Rule 17; and Phlx Rule
185(g).
190 Id.
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14533
pursuant to which Market Makers may
enter Linkage orders; impose obligations
on the Exchange regarding how it must
process incoming Linkage orders;
establish a general standard that
Participants should avoid tradethroughs; establish potential regulatory
liability for Participants that engage in
a pattern or practice of trading through
other exchanges; and establish
obligations with respect to locked and
crossed markets.193
One commenter questioned how
NOM will ensure that orders designated
for execution solely on NOM will not
create a trade-through or locked or
crossed market. In particular, the
commenter requests clarification
regarding the treatment of an order that
locks or crosses the NBBO, NOM’s
responsibility for such an order, and the
action NOM will take if the market
already is locked or crossed when it
receives an order.194
In response, Nasdaq states that
Chapter VI, Section 7(b)(3)(C) of the
NOM Rules sets forth the procedures
that NOM will use to ensure compliance
with the trade through and locked and
crossed market provisions of the
Linkage Plan.195 Nasdaq proposes in
Amendment No. 2 to state explicitly in
the NOM Rules that an order will not be
executed at a price that trades through
another market or displayed at a price
that would lock or cross another market.
Nasdaq further proposes to add in
Amendment No. 2 that an order that is
designated as routable will be routed in
compliance with applicable trade
through and locked and crossed markets
restrictions.196 With respect to nonroutable orders, Nasdaq notes that the
System will re-price a Displayed Order
that, at the time of entry, would cause
a locked or crossed market or a trade
through violation, to the current
national best offer (for bids) or the
current national best bid (for offers) and
display the order at one minimum price
variation below (for bids) or above (for
offers) the national best price.197 These
193 See
NOM Rules, Chapter XII.
Amex Letter supra note 4, at 3.
195 See Nasdaq Response, supra note 5, at 10.
196 See NOM Rules, Chapter VI, Section
7(b)(3)(C).
197 See NOM Rules, Chapter VI, Section
7(b)(3)(C). As originally proposed, Chapter VI,
Section 7(b)(3)(C) of the NOM Rules provided that
if a Displayed Order that the entering party has
elected not to make eligible for routing would cause
a locked or crossed market or a trade through
violation at the time of entry, the System would reprice the order to one minimum price variation
(‘‘MPV’’) below the current national best offer (for
bids) or one MPV above the current national best
bid (for offers). In Amendment No. 2, Nasdaq
proposes to revise the rule to provide that the
System will re-price such an order to the current
194 See
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mstockstill on PROD1PC66 with NOTICES
do-not-ship orders will remain on
Nasdaq’s book until cancelled or
executed by another NOM Participant or
market center.198 Nasdaq states that the
System, therefore, will systemically
avoid executing an order at a price that
would trade through a price on another
market and will prevent Nasdaq from
displaying a quotation that would lock
or cross a quotation displayed by
another market.199 In addition, Nasdaq
represents that it will program the
System to avoid joining a locked or
crossed market when the market is
already locked or crossed.200
The Commission believes that Nasdaq
has responded adequately to the
commenter’s questions regarding NOM’s
procedures and rules for complying
with the Linkage Plan, and that NOM’s
rules, as amended, are reasonably
designed to comply with the locked and
crossed market and trade through
provisions of the Linkage Plan.
As noted above, Nasdaq intends to
use NOS to route orders to other
markets. To allow Nasdaq to use the
Linkage to send orders to other markets,
if it wanted to do so, NOM Rules
provide that one Options Market Maker
per eligible series will be designated as
the ‘‘InterMarket Linkage Market
Maker’’ or ‘‘ILM’’ to be responsible for
P/A and Satisfaction orders that would
be sent to away markets through the
Linkage for options trading on NOM.
The ILM responsible for such orders
will be required to adhere to the
responsibilities of an Eligible Market
Maker, as set forth in the Linkage
Plan.201
The ILM will be required to act with
due diligence with regard to the
interests of orders entrusted to it and
fulfill other duties of an agent,
including, but not limited to, ensuring
that such orders, regardless of their size
or source, receive proper representation
and timely execution in accordance
with the terms of the orders and the
rules of the Exchange. The ILM must
provide NOM with written instructions
for the routing of any P/A orders it may
send through the InterMarket Linkage.
national best offer (for bids) or the current national
best bid (for offers) and display the order at one
MPV below (for bids) or above (for offers) the
national best price. Nasdaq believes that the
procedure proposed in Amendment No. 2 is
superior to the original procedure, which would
have converted the re-priced order into a NonDisplayed Order.
198 See Nasdaq Response, supra note 5, at 10.
199 Id.
200 Id.
201 See NOM Rules, Chapter VII, Section 5(a)(ix).
The ILM will perform substantially similar
functions that the BOX InterMarket Linkage Market
Maker performs on BOX. See BOX Rules, Chapter
VI, Section 5(a)(ix), and Chapter XII.
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NOM will immediately route all P/A
orders on behalf of the ILM according to
these instructions.202
One commenter seeks clarification as
to who would fulfill the role of the ILM
if the ILM is excused temporarily from
its responsibilities, and who would be
responsible for trade throughs.203
In response, Nasdaq states that it
intends to use NOS to fulfill Nasdaq’s
order routing obligations under the
Linkage Plan.204 Although Nasdaq
believes that it therefore will rarely, if
ever, need to appoint an ILM, Nasdaq
notes that Chapter VII, Rule 5(a)(ix) of
the NOM Rules provides Nasdaq with
the ability to designate a market maker
as the ILM for a particular series.205 In
the event that the ILM substantially fails
to engage in a course of dealings under
this rule, Nasdaq Regulation may bring
a disciplinary action.206 In addition,
Nasdaq states that neither Nasdaq or any
Participant will face liability for trade
throughs because NOM is programmed
to comply with the requirements of the
Linkage Plan. If NOM has a System
malfunction that results in a trade
through, Nasdaq believes that such an
occurrence would fall under the
exception in Section 8(c)(iii) of the
Linkage Plan. If Nasdaq receives a
Satisfaction Order from an away market,
NOM will execute the order against
trading interest available on the NOM
Book.207
The Commission notes that NOM’s
rules and the NOM System are designed
to comply with the requirements of the
Linkage Plan, including the trade
through requirements. The Commission
believes that the proposed NOM rules
regarding the Intermarket Linkage are
consistent with the requirements of the
Linkage Plan and the Act. The
Commission reminds Nasdaq, however,
that to the extent trades are executed on
NOM that do not comply with the trade
through requirements of the Linkage
Plan, Nasdaq, as a Plan Participant, will
have the obligation to comply with the
requirements of the Linkage Plan,
including responding to Satisfaction
202 The order would be generated automatically
by NOM and routed to the away exchange with the
required clearing information included. Each
execution received from an away exchange would
result in the automatic generation of a trade
execution on NOM between the original order and
the ILM.
203 See SIFMA Letter, supra note 4, at 2.
204 See Nasdaq Response, supra note 5, at 4.
205 See Nasdaq Response, supra note 5, at 4. The
Commission notes that if there is no Market Maker
registered in a particular series, NOM will place
that series in a non-regulatory suspension and halt
trading until such time as a member registers to
make markets in that series. See supra note 79 and
accompanying text.
206 See NOM Rules, Chapter VII, Section 5(c).
207 See Nasdaq Response, supra note 5, at 4.
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Orders. Further, before Nasdaq can
begin operating NOM, Nasdaq must
become a participant in the Linkage
Plan.
G. Strike Prices
Nasdaq proposes to participate in the
$2.50 Strike Price Program 208 and in the
$1 Strike Price Program.209 Amendment
No. 2 proposes to amend the NOM
Rules to reflect the expansion of the
$2.50 Strike Price Program to include
strike prices between $50 and $75 under
certain conditions and to indicate that
NOM’s $1 Strike Price Program will
expire on June 5, 2008, rather than June
5, 2007.210 These changes conform
NOM’s rules to the existing rules of the
other options markets.211
One commenter believes that the
terms of NOM’s participation in the
$2.50 Strike Price Program and the $1
Strike Price Program are unclear.212 In
particular, the commenter questions
whether NOM will trade only those
classes currently included in the $2.50
208 The $2.50 strike price program allows the
options exchanges to list options in up to 200
classes at $2.50 strike price intervals for strike
prices greater than $25 but less than $75. See, e.g.,
Securities Exchange Act Release Nos. 40662
(November 12, 1998), 63 FR 64297 (November 19,
1998) (order approving File Nos. SR–Amex–98–21;
SR–CBOE–98–29; SR–PCX–98–31; and SR–Phlx–
98–26) (‘‘1998 Order’’) and 52893 (December 5,
2005), 70 FR 73488 (December 12, 2005) (order
approving File No. SR–Amex–2005–067). The 200
classes eligible for the $2.50 Strike Price Program
were allocated among the options exchanges
pursuant to a formula approved by the Commission
as part of the permanent approval of the program.
Each options exchange may list options with $2.50
strike price intervals on any options class that
another exchange selects as part of its program. Any
modification to the $2.50 Strike Price Program
would require the filing of a proposed rule change
with the Commission pursuant to Section 19(b) of
the Act.
209 Under the $1 Strike Price Program, each
options exchange may select a total of five
individual stocks on which options series may be
listed at $1 intervals, and each exchange may list
$1 strikes on any options class designated by
another exchange as part of its $1 Strikes Program.
See, e.g., Securities Exchange Act Release No.
55714 (May 7, 2007), 72 FR 26853 (May 11, 2007).
See NOM Rules, Chapter IV, Section 6,
Supplementary Material .03 and Supplementary
Material .02. The Commission notes that several of
the options exchanges have amended their rules, in
part, to allow the exchanges to select a total of ten
individual stocks on which options series may be
listed at $1 intervals. See, e.g., Securities Exchange
Act Release Nos. 57049 (December 27, 2007), 73 FR
528 (January 8, 2008) (order approving File No. SR–
CBOE–2007–125) and 57110 (January 8, 2008)
(notice of filing and order granting accelerated
approval of File No. SR–Amex–2007–141) (together,
the ‘‘1 Strike Price Orders’’).
210 See NOM Rules, Chapter IV, Section 6,
Supplementary Material .03(b) and Supplementary
Material .02.
211 The Commission notes that several of the
options exchanges have recently amended their
rules to make the $1 Strike Price Program
permanent. See, e.g., $1 Strike Price Orders, supra
note 209.
212 See Amex Letter, supra note 4, at 3–4.
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Strike Price Program and in the $1
Strike Price Program.213 NOM’s rules
provide that it may list $1 strikes in
options classes on five individual
stocks, as designated by NOM, as well
as any options class specifically
designated by another exchange that
employs a similar $1 strike price
program.214 NOM’s rules also provide
that Nasdaq may list series at $2.50
strike price intervals in any multiply
traded option once another exchange
has selected that option to be a part of
the program.215 The Commission
believes that Nasdaq’s proposal, as
amended, makes clear that NOM will
participate in the $2.50 Strike Price
Program and the $1 Strike Price Program
on the same terms and conditions as the
other options exchanges.216 The
Commission also believes that Nasdaq’s
proposed rules relating to the $2.50
Strike Price and $1 Strike Price
Programs will provide investors with
flexibility in tailoring their options
positions to meet their investment
objectives while avoiding the
unnecessary proliferation of illiquid
options series.217
H. Securities Traded on NOM
Nasdaq proposes to adopt initial and
continued listing standards for equity
and index options 218 that are
substantially similar to the listing
standards adopted by other options
exchanges.219 In Amendment No. 2,
Nasdaq proposes to revise proposed
213 Id.
at 4.
NOM Rule, Chapter IV, Section 6,
Supplementary Material .02(a).
215 See NOM Rule, Chapter IV, Section 6,
Supplementary Material .03(a).
216 As noted above, several of the options
exchanges have recently expanded and made
permanent their $1 Strike Price Programs. See supra
notes 209 and 211.
217 See, e.g. 1998 Order, supra note 208, and
Securities Exchange Act Release Nos. 47991 (June
5, 2003), 68 FR 35243 (June 12, 2003) (File No. SR–
CBOE–2001–60) (order approving CBOE’s $1 Strike
Price Program through June 5, 2004) and 48024
(June 12, 2003), 68 FR 36617 (June 18, 2003) (File
No. SR–Amex–2003–36) (order approving Amex’s
$1 Strike Price Program through June 5, 2004).
218 See NOM Rules, Chapters IV and XIV.
219 See, e.g., BOX Rules, Chapters IV and XIV. In
response to a commenter’s concern that its
proposed definition of ‘‘index option’’ could have
included exchange-traded funds, as well as index
options (see Amex Letter, supra note 4, at 4),
Nasdaq proposes in Amendment No. 2 to revise its
definition ‘‘index option’’ to mean an option on a
broad-based, narrow-based, or micro narrow-based
index of equity securities prices. See NOM Rules,
Chapter I, Section 1(a)(21). The Commission finds
that the proposed change is consistent with the Act
because it clarifies the definition of ‘‘index option.’’
In addition, Nasdaq proposes in Amendment No. 2
to revise Chapter IV, Section 5 of the NOM Rules
to indicate that if an options class has been
approved for listing on NOM and there is not at
least one series in that class open for trading, the
listing will be placed in a non-regulatory
suspension until a series is opened in that class.
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214 See
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Chapter IV, Section 3 of the NOM Rules
to allow NOM to list and trade an option
on an underlying equity security that
does not satisfy certain of the criteria for
initial listing in the NOM Rules
provided that: (1) The underlying
security meets the criteria for continued
listing set forth in the NOM Rules; and
(2) options on such underlying security
are listed and traded on at least one
other registered national securities
exchange.220 This proposed change to
the proposed NOM Rules, which is
narrowly tailored to address the
circumstances where an equity option
class is currently ineligible for initial
listing on NOM even though it meets
NOM’s continued listing standards and
is trading on another options exchange,
is substantially similar to rules adopted
by other options exchanges.221
The Commission believes that NOM’s
proposed initial and continued listing
standards, as amended, are consistent
with the Act, including Section 6(b)(5),
in that they are designed to protect
investors and the public interest and to
promote just and equitable principles of
trade. Nasdaq’s operation of NOM as an
options exchange, however, is
conditioned on Nasdaq becoming a Plan
Sponsor in the Plan for the Purpose of
Developing and Implementing
Procedures Designed to Facilitate the
Listing and Trading of Standardized
Options Submitted Pursuant to Section
11A(a)(3)(B) of the Securities Exchange
Act of 1934 (‘‘OLPP’’). In addition,
Nasdaq will need to become a
participant in the Options Clearing
Corporation.
I. Regulation of NOM and Options
Participants
Nasdaq represents that it has the
ability to discharge all regulatory
functions related to the facility that it
has undertaken to perform by virtue of
forming NOM as a facility of Nasdaq.222
In connection with its regulatory
functions, the Exchange represents that
its regulatory oversight committee and
its chief regulatory officer (‘‘CRO’’) will
assume responsibility for regulating
quoting and trading on NOM and
220 See NOM Rules, Chapter IV, Section 3(k) and
Amendment No. 2. Nasdaq also proposes to state
that it shall employ the same procedures to
determine whether a particular underlying security
meets NOM’s continued equity options listing
criteria in this instance as it employs when
determining whether an underlying security meets
NOM’s initial listing criteria. See id.
221 See, e.g., Amex Rule 915, Commentary .01(6);
CBOE Rule 5.3, Interpretation and Policy .01(c); and
ISE Rule 502(b)(6).
222 See Corporate Structure Proposal Notice,
supra note 8, at 58138.
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conduct by NOM participants.223 The
Exchange’s CRO has general supervision
of the regulatory operations of the
Exchange, including overseeing
surveillance, examination, and
enforcement functions, and administers
a regulatory services agreement
(‘‘Regulatory Contract’’) between the
Exchange and FINRA.224
Pursuant to the Regulatory Contract,
FINRA will perform many of the initial
disciplinary processes on behalf of the
Exchange. Additionally, the Exchange’s
By-Laws and rules provide that it has
disciplinary jurisdiction over its
members so that it can enforce its
members’ compliance with its rules and
the federal securities laws.225 The
Exchange’s rules also permit it to
sanction members for violations of its
rules and violations of the federal
securities laws by, among other things,
expelling or suspending members,
limiting members’ activities, functions,
or operations, fining or censuring
members, or suspending or barring a
person from being associated with a
member.226 Nasdaq’s Rules also provide
for the imposition of fines for minor rule
violations in lieu of commencing
disciplinary proceedings.227
Furthermore, the Exchange has an
independent regulatory department,
Nasdaq Regulation, which carries out
many of the Exchange’s regulatory
functions, including administering its
membership and disciplinary rules, and
is functionally separate from the
Exchange’s business lines. Nasdaq
Regulation includes Market Watch,
which performs real-time intraday
surveillance over all Exchange-listed
companies and all Exchange market
participants. The Exchange represents
that Nasdaq Regulation, including
Market Watch, will perform the same
223 See Corporate Structure Proposal Notice,
supra note 8, at 58139.
224 Pursuant to the RSA, FINRA performs certain
regulatory functions on behalf of the Exchange. In
addition to performing certain membership
functions for the Exchange, FINRA performs certain
disciplinary and enforcement functions for the
Exchange. Generally, FINRA investigates members,
issue complaints, and conducts hearings pursuant
to the Exchange’s rules. Appeals of disciplinary
hearings, however, will be handled by the Nasdaq
Review Council. Id.
225 See e.g. Exchange By-Laws, Article IX, Section
2.
226 See e.g. Exchange Rule 8310. Nasdaq rules
apply to Options Participants and the trading of
options contracts on NOM. See NOM Rules,
Chapter I, Section 2. Prospective Options
Participant must, among other things, be an existing
member or become a member of the Exchange,
pursuant to the Nasdaq 1000 Rule Series, as well
as maintain a membership on at least one other
options national securities exchange. See NOM
Rules, Chapter II, Sections 1(b)(iii) and 2(f).
227 See infra notes 243 to 250 and accompanying
text.
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regulatory role with respect to NOM,
including operating automated
detection systems to perform real-time
surveillance of quoting and trading on
NOM and to maintain a fair and orderly
market.228 Specifically, Nasdaq
Regulation will perform options listing
regulation and will monitor trading on
the NOM on a real-time basis to identify
unusual trading patterns and determine
whether particular trading activity
requires further regulatory investigation
by FINRA. In addition, Nasdaq
Regulation will oversee the process for
determining and implementing trading
halts, identifying and responding to
unusual market conditions, and
administering Nasdaq’s process for
identifying and remediating ‘‘obvious
errors’’ by and among Options
Participants. The NOM rules governing
halts, unusual market conditions,
extraordinary market volatility, and
audit trail are modeled on the approved
rules of BOX.229
The Commission finds that the
Exchange’s proposed rules and
regulatory structure with respect to
NOM are consistent with the
requirements of the Act, and in
particular with Section 6(b)(1) of the
Act, which requires an exchange to be
so organized and have the capacity to be
able to carry out the purposes of the Act
and to comply, and to enforce
compliance by its members and persons
associated with its members, with the
Act and the rules and regulations
thereunder, and the rules of the
Exchange,230 and with Sections 6(b)(6)
and 6(b)(7) of the Act,231 which require
an Exchange to provide fair procedures
for the disciplining of members and
persons associated with members.
Regulatory Contract to capture certain
aspects of regulation of NOM and the
regulation and discipline of Options
Participants.233 The Commission notes
that Nasdaq will continue to bear
ultimate regulatory responsibility for
functions performed on Nasdaq’s behalf
under the Regulatory Contract. Further,
the Exchange retains ultimate legal
responsibility for the regulation of its
members (including those members that
are NOM Participants) and its market
(including its facility, NOM).
The Commission believes that it is
consistent with the Act to and the
public interest to allow the Exchange to
contract with FINRA to perform
membership, disciplinary, and
enforcement functions.234 Membership,
discipline, and enforcement are
fundamental elements to a regulatory
program, and constitute core selfregulatory functions. It is essential to
the public interest and the protection of
investors that these functions are carried
out in an exemplary manner. With
respect to certain regulatory functions
contracted to FINRA by the Exchange,
including membership, disciplinary and
enforcement functions, the Commission
noted in the Registration Approval
Order its belief that FINRA has the
expertise and experience to perform
such functions on behalf of the
Exchange, and that the contracting of
such functions to FINRA is consistent
with the Act and the public interest.235
The Commission continues to believe
this is true with respect to the inclusion
in the Regulatory Contract of regulation
of NOM and the conduct of NOM
Participants.
At the same time, the Exchange,
unless relieved by the Commission of its
responsibility,236 bears the
1. Regulatory Contract
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The Exchange represents that the
Regulatory Contract between the
Exchange and FINRA governs the
Exchange and its facilities. Therefore,
because NOM will be a facility of
Nasdaq, the Regulatory Contract will
govern NOM.232 The Exchange and
FINRA, however, have modified the
228 See Corporate Structure Proposal Notice,
supra note 8, at 58139.
229 See BOX Rules, Chapter V.
230 15 U.S.C. 78f(b)(1).
231 15 U.S.C. 78f(b)(6) and (b)(7).
232 The Commission notes that the NOM
Proposed Rules provide that ‘‘NOM rules that refer
to Nasdaq Regulation, Nasdaq Regulation staff,
NOM staff, and NOM departments should be
understood as also referring to [National
Association of Securities Dealers, Inc.
(‘‘NASD’’) (n/k/a Financial Industry Regulatory
Authority, Inc. or FINRA)], NASD staff, NASD
Regulation staff, and NASD departments acting on
behalf of Nasdaq pursuant to the Regulatory
Contract.’’ See NOM Rules, Chapter 1, Article 3.
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233 Nasdaq and FINRA are parties to an agreement
pursuant to Section 17(d) of the Act and Rule
17d–2 thereunder, dated July 11, 2006 (‘‘Bilateral
17d–2 Agreement’’). A regulatory matter involving
a NOM Participant that is also a FINRA member
that is governed by both the Regulatory Contract
and the Bilateral 17d–2 Agreement will be
administered by FINRA pursuant to the Bilateral
17d–2 Agreement, not the Regulatory Contract.
Telephone conversation between Jeffrey S. Davis,
Vice President and Deputy General Counsel,
Nasdaq, and Heather Seidel, Assistant Director,
Division of Trading and Markets (‘‘Division’’),
Commission, on December 21, 2007.
234 See e.g., Regulation ATS Release, supra note
92. See also Securities Exchange Act Release Nos.
50122 (July 29, 2004), 69 FR 47962 (August 6, 2004)
(order approving File No. SR–Amex–2004–32)
(‘‘Amex Approval Order’’); 42455 (February 24,
2000), 65 FR 11388 (March 2, 2000) (File No. 10–
127) (approving ISE’s registration as a national
securities exchange) (‘‘ISE Exchange Registration
Order’’) at III(D)(2); and Registration Approval
Order, supra note 19.
235 See Registration Approval Order, supra note
19, at notes 10 and 11 and accompanying text.
236 See Section 17(d)(1) of the Act and Rule 17d–
2 thereunder. 15 U.S.C. 78q(d)(1); and 17 CFR
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responsibility for self-regulatory
conduct and primary liability for selfregulatory failures, not the SRO retained
to perform regulatory functions on the
Exchange’s behalf.237 In performing
these functions, however, FINRA may
nonetheless bear liability for causing or
aiding and abetting the failure of the
Exchange to perform its regulatory
functions.238 Accordingly, although
FINRA will not act on its own behalf
under its SRO responsibilities in
carrying out these regulatory services for
Nasdaq relating to the operation of
NOM, FINRA also may have secondary
liability if, for example, the Commission
finds the contracted functions are being
performed so inadequately as to cause a
violation of the federal securities laws
by Nasdaq.239
2. 17d–2 Agreement
Rule 17d–2 allows SROs to file with
the Commission plans under which the
SROs allocate among themselves the
responsibility to receive regulatory
reports from, and examine and enforce
compliance with, specified provisions
of the Act and rules thereunder and
SRO rules by firms that are members of
more than one SRO (‘‘common
members’’). An SRO that is a party to an
effective 17d–2 plan is relieved of
regulatory responsibility as to any
common member for whom
responsibility is allocated under the
plan to another SRO.240
All of the options exchanges, the
NASD, and the NYSE have entered into
the Options Sales Practices Agreement,
a Rule 17d–2 agreement (‘‘17d–2
Agreement’’ or ‘‘Agreement’’). This
Agreement allocates to certain SROs
(‘‘examining SROs’’) regulatory
responsibility for common members
with respect to certain options-related
sales practice matters. For example, the
Agreement allocates responsibility to
conduct options-related sales practice
examinations of a firm, and investigate
240.17d–2. See also infra note 240 and
accompanying text. The Commission notes that it
is not approving the Regulatory Contract.
237 See Registration Approval Order, supra note
19, at notes 112 and 113 and accompanying text;
Amex Approval Order, supra note 234; and ISE
Registration Approval Order, supra note 234, at
III(D)(2).
238 Id.
239 Id.
240 Rule 17d–2 provides that any two or more
SROs may file with the Commission a plan for
allocating among such SROs the responsibility to
receive regulatory reports from persons who are
members or participants of more than one of such
SROs to examine such persons for compliance, or
to enforce compliance by such persons, with
specified provisions of the Act, the rules and
regulations thereunder, and the rules of such SROs,
or to carry out other specified regulatory functions
with respect to such persons. 17 CFR 240.17d–2.
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options-related customer complaints
and terminations for cause of associated
persons of that firm. The Commission
notes that Nasdaq has become a party to
the 17d–2 Agreement,241 which will
cover Nasdaq members acting as
Options Participants.242
3. Minor Rule Violation Plan
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The Commission approved Nasdaq’s
Minor Rule Violation Plan (‘‘MRVP’’) in
2006.243 Nasdaq’s MRVP specifies those
uncontested minor rule violations with
sanctions not exceeding $2,500 that
would not be subject to the provisions
of Rule 19d–1(c)(1) under the Act 244
requiring that an SRO promptly file
notice with the Commission of any final
disciplinary action taken with respect to
any person or organization.245 Nasdaq’s
MRVP includes the policies and
procedures included in Nasdaq Rule
9216(b), ‘‘Procedure for Violations
under Plan Pursuant to SEC Rule 19d–
1(c)(2),’’ and the rule violations
included in Nasdaq IM–9216,
‘‘Violations Appropriate for Disposition
Under Plan Pursuant to SEC Rule 19d–
1(c)(2).’’
The Trading Rules Proposal, as
originally filed, included Chapter X,
Section 7 of the NOM Rules, ‘‘Penalty
for Minor Rule Violations,’’ which lists
the options rules that Nasdaq intended
to include in its MRVP. However, the
Trading Rules Proposal did not propose
a corresponding amendment to Nasdaq
IM–9216 to include the rules in
proposed Chapter X, Section 7 of the
NOM Rules in Nasdaq’s MRVP.
Accordingly, in Amendment No. 2,
Nasdaq proposes to amend Nasdaq IM–
241 The Commission today is approving an
amendment to the 17d–2 Agreement that adds
Nasdaq as a party to the Agreement. See Securities
Exchange Act Release No. 57481 (March 12, 2008)
(File No. S7–966).
242 NOM rules contemplate participation in this
Agreement by requiring that any Options
Participant that transacts business with Public
Customers also be a member of at least one of the
examining SROs. See NOM Rules, Chapter XI,
Section 1.
243 See Securities Exchange Act Release No.
53623 (April 10, 2006), 71 FR 19769 (April 17,
2006) (File No. 4–514) (‘‘MRVP Order’’).
244 17 CFR 240.19d–1(c)(1).
245 The Commission adopted amendments to
paragraph (c) of Rule 19d–1 to allow SROs to
submit for Commission approval plans for the
abbreviated reporting of minor disciplinary
infractions. See Securities Exchange Act Release
No. 21013 (June 1, 1984), 49 FR 23829 (June 8,
1984). Any disciplinary action taken by an SRO
against any person for violation of a rule of the SRO
which has been designated as a minor rule violation
pursuant to such a plan filed with the Commission
will not be considered ‘‘final’’ for purposes of
Section 19(d)(1) of the Act if the sanction imposed
consists of a fine not exceeding $2,500 and the
sanctioned person has not sought an adjudication,
including a hearing, or otherwise exhausted his
administrative remedies.
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9216 to include proposed Chapter X,
Section 7 of the NOM Rules.246 The
Commission believes that this change is
consistent with the Act because it
clarifies that the proposed rules listed in
Chapter X, Section 7 of the NOM Rules
will be included in Nasdaq’s MRVP.
The Commission notes that the rules
included in Chapter X, Section 7 of the
NOM Rules are similar to the rules
included in the MRVPs of other options
exchanges.247 The Commission finds
that Nasdaq’s MRVP, as amended to
include the rules listed in Chapter X,
Section 7 of the NOM Rules, is
consistent with Sections 6(b)(1), 6(b)(5)
and 6(b)(6) of the Act, which require, in
part, that an exchange have the capacity
to enforce compliance with, and provide
appropriate discipline for, violations of
the rules of the Commission and of the
exchange.248 In addition, because
Nasdaq Rule 9216(b) will offer
procedural rights to a person sanctioned
for a violation listed in Chapter X,
Section 7 of the NOM Rules, the
Commission believes that Nasdaq’s
rules provides a fair procedure for the
disciplining of members and associated
persons, consistent with Section 6(b)(7)
of the Act.249
The Commission also finds that the
proposal to include the rules listed in
Chapter X, Section 7 of the NOM Rules
in Nasdaq’s MRVP is consistent with the
public interest, the protection of
investors, or otherwise in furtherance of
the purposes of the Act, as required by
Rule 19d–1(c)(2) under the Act,250
because it should strengthen Nasdaq’s
ability to carry out its oversight and
enforcement responsibilities as an SRO
in cases where full disciplinary
proceedings are unsuitable in view of
the minor nature of the particular
violation.
In approving the proposed change to
Nasdaq’s MRVP, the Commission in no
way minimizes the importance of
compliance with NOM rules and all
other rules subject to the imposition of
fines under Nasdaq’s MRVP. The
Commission believes that the violation
of any SRO rules, as well as
Commission rules, is a serious matter.
However, the Nasdaq MRVP provides a
reasonable means of addressing rule
violations that do not rise to the level of
J. Quote Mitigation
Nasdaq originally proposed a rule that
would provide for the bundling of
certain order and quote updates sent to
OPRA for low volume options that have
been listed on NOM for more than ten
trading days.251 In Amendment No. 2,
Nasdaq proposes to eliminate the rule as
proposed and provide that: (1) On a
monthly basis, NOM will determine the
average daily volume (‘‘ADV’’) of each
series listed on NOM and delist the
current series and not list the next series
after expiration where the ADV is less
than 100 contracts; 252 (2) NOM will
implement a ‘‘replace on queue’’
functionality that will monitor outgoing
messages and will not send a message
that is about to be sent if a more current
message for the same series is available
for sending; 253 (3) NOM will prioritize
price update messages and send out
price updates before sending size
update messages; and (4) when the size
associated with a bid or offer increases
by an amount less than or equal to a
percentage (never to exceed 20%) of the
size associated with a previously
disseminated bid or offer, NOM will not
disseminate the new bid or offer.254
Nasdaq also represents that when NOM
detects that a Participant is
disseminating significantly more quotes
than is normal for that Participant, NOM
will contact that Participant and alert it
to such activity. Such monitoring may
reveal that the Participant may have
internal system issues or incorrectly-set
system parameters that are not
immediately apparent. NOM believes
that, even without uncovering problems,
alerting a Participant to possible
excessive quoting will lead the
246 In the MRVP Order, the Commission noted
that Nasdaq proposed that any amendments to IM–
9216 made pursuant to a rule filing submitted
under Rule 19b–4 of the Act would automatically
be deemed a request by Nasdaq for Commission
approval of a modification to its MRVP. See MRVP
Order, supra note 243, at note 6.
247 See, e.g., BOX Rules, Chapter X, Section 2, and
ISE Rule 1614.
248 15 U.S.C. 78f(b)(1), 78f(b)(5) and 78f(b)(6).
249 15 U.S.C. 78f(b)(7).
250 17 CFR 240.19d–1(c)(2).
251 The period for which updates would be
bundled would not have exceeded one second. This
rule was based on a similar rule of BOX. See BOX
Rules, Chapter V, Section 32.
252 The ADV refers to the ADV on NOM.
Telephone conversation between Heather Seidel,
Assistant Director, Division of Trading and Markets,
and Jeffrey S. Davis, Vice President and Deputy
General Counsel, Nasdaq, on January 9, 2008.
253 This functionality will be applied in real time
and will not delay the sending of any messages.
254 See NOM Rules, Chapter VI, Section 17.
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requiring formal disciplinary
proceedings, while providing greater
flexibility in handling certain violations.
The Commission expects that Nasdaq
will continue to conduct surveillance
with due diligence and make a
determination based on its findings, on
a case-by-case basis, whether a fine of
more or less than the recommended
amount is appropriate for a violation
under Nasdaq’s MRVP or whether a
violation requires a formal disciplinary
action under the Nasdaq Rule 9200
Series.
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Participant to take steps to reduce the
number of its quotes.255
The Commission notes that several of
the options exchanges have adopted
similar rules that provide for the
delisting of options classes when the
ADV of the class falls below a certain
threshold.256 In addition, Nasdaq’s
proposal to not disseminate a new bid
or offer when the size associated with a
bid or offer increases by an amount less
than or equal to a percentage (never to
exceed 20%) of the size associated with
a previously disseminated bid or offer is
substantially similar to a Phlx rule
previously approved by the
Commission.257 Further, Nasdaq’s
monitoring strategy is substantially
similar to a policy adopted by ISE.258
The Commission also believes that
Nasdaq’s proposed ‘‘replace on queue’’
functionality and its proposal to
prioritize price update messages and
send out price updates before sending
size update messages are reasonable
measures to attempt to mitigate quote
message traffic because they will more
efficiently provide for the dissemination
of the most recent quote information.
Although Nasdaq’s rules do not
include a ‘‘holdback timer’’ or similar
quote mitigation strategy like those
adopted by four of the other options
exchanges,259 the Commission believes
that the totality of Nasdaq’s proposed
255 See
Amendment No. 2 at 9.
Securities Exchange Act Release Nos.
55161 (January 24, 2007), 72 FR 4754 (February 1,
2007) (File No. SR–ISE–2006–62) (ISE Penny Pilot
Approval Order) (approving ISE policy to delist
equity options with an ADV of less than 20
contracts, but noting that ISE’s current policy is to
do so for options with an ADV of less than 50
contracts); 55162 (January 24, 2007), 72 FR 4738
(February 1, 2007) (File No. SR–Amex–2006–106)
(Amex Penny Pilot Approval Order) (approving
Amex policy to delist options classes with an ADV
of less than 25 contracts); 55154 (January 23, 2007),
72 FR 4743 (February 1, 2007) (File No. SR–CBOE–
2006–92) (CBOE Penny Pilot Approval Order)
(approving CBOE policy to delist equity option
classes with an ADV of less than 20 contracts); and
56154 (July 27, 2007), 72 FR 43303 (August 3, 2007)
(File No. SR–CBOE–2007–85) (approving an
exception to CBOE’s delisting policy if the option
class scheduled for delisting experiences a
significant increase in trading volume).
257 See Securities Exchange Act Release No.
55153 (January 23, 2007), 72 FR 4553 (January 31,
2007) (File No. SR–Phlx–2006–74) (order
approving, in part, a Phlx rule providing that it will
disseminate an updated bid or offer when, among
other things, the size associated with it’s bid or offer
increases by an amount greater than or equal to a
percentage (never to exceed 20%)).
258 See ISE Penny Pilot Approval Order, supra
note 256. See also CBOE Penny Pilot Approval
Order and Amex Penny Pilot Approval Order, supra
note 256.
259 See Amex Penny Pilot Approval Order, CBOE
Penny Pilot Approval Order, and ISE Penny Pilot
Approval Order, supra note 256; and Securities
Exchange Act Release No. 55155 (January 23, 2007),
72 FR 4741 (February 1, 2007) (File No. SR–BSE–
2006–49) (approving BOX’s Penny Pilot program).
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256 See
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market structure, market making
obligations, and quote mitigation
strategies are comparable to the quote
mitigation efforts of the other options
markets. More specifically, Nasdaq has
proposed to allow Market Makers to
register by series, as opposed to class.
As noted above, the Commission
believes that this will permit Market
Makers to select the options series in
which they are most interested. This is
designed to reduce the number of quotes
submitted by such Market Makers, and
therefore likely will help to mitigate
NOM’s quote message traffic and
capacity.260 In addition, NOM Rules
provide that a market maker’s
continuous quoting obligations will not
be applicable in options series until the
time to expiration is less than nine
months.261
Further, Nasdaq has proposed that it
will open at least one expiration month
for each class of option open for trading
on NOM, and a minimum of one series
of options in that class.262 These
requirements provide for fewer
mandatory expiration months and series
than the rules of other options
exchanges, and may therefore contribute
to less quote message traffic on NOM to
the extent that NOM has fewer series
open for trading. And, as detailed above,
Nasdaq has proposed four quote
mitigation strategies, several of which
are substantially similar to those in
place at other markets.
K. Section 11(a) of the Act
Section 11(a)(1) of the Act 263
prohibits a member of a national
securities exchange from effecting
transactions on that exchange for its
own account, the account of an
associated person, or an account over
which it or its associated person
exercises discretion (collectively,
‘‘covered accounts’’) unless an
exception applies. Rule 11a2–2(T) 264
under the Act, known as the ‘‘effect
versus execute’’ rule, provides exchange
members with an exemption from the
Section 11(a)(1) prohibition. Rule 11a2–
2(T) permits an exchange member,
260 See
supra notes 57 to 58 and accompanying
text.
261 See NOM Rules, Chapter IV, Section 8(a). See
also CBOE Rule 8.7; PHLX Rule 1014(b)(ii)(D)(4);
and Amex Rules 993–ANTE(c)(ii) and 994–
ANTE(c)(iv).
262 See NOM Rules, Chapter IV, Sections 6(b) and
6(e). In Amendment No. 2, Nasdaq proposes to
revise Chapter IV, Section 6(b) of the NOM Rules
to provide that at the commencement of trading of
an options class, NOM will list a minimum of one
options series in that class, rather than a minimum
of three series for each expiration month in the
class, as originally proposed.
263 15 U.S.C. 78k(a)(1).
264 17 CFR 240.11a2–2(T).
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subject to certain conditions, to effect
transactions for covered accounts by
arranging for an unaffiliated member to
execute transactions on the exchange.
To comply with Rule 11a2–2(T)’s
conditions, a member: (i) Must transmit
the order from off the exchange floor;
(ii) may not participate in the execution
of the transaction once it has been
transmitted to the member performing
the execution; 265 (iii) may not be
affiliated with the executing member;
and (iv) with respect to an account over
which the member has investment
discretion, neither the member nor its
associated person may retain any
compensation in connection with
effecting the transaction except as
provided in the Rule.
In a letter to the Commission, Nasdaq
requests that the Commission concur
with Nasdaq’s conclusion that
Participants that enter orders into NOM
satisfy the requirements of Rule 11a2–
2(T).266 For the reasons set forth below,
the Commission believes that
Participants entering orders into NOM
would satisfy the conditions of the Rule.
The Rule’s first condition is that
orders for covered accounts be
transmitted from off the exchange floor.
The NOM System receives orders
electronically through remote terminals
or computer-to-computer interfaces. In
the context of other automated trading
systems, the Commission has found that
the off-floor transmission requirement is
met if a covered account order is
transmitted from a remote location
directly to an exchange’s floor by
electronic means.267 Because the NOM
System receives orders electronically
through remote terminals or computerto-computer interfaces, the Commission
265 The member may, however, participate in
clearing and settling the transaction.
266 See letter from Jeffrey S. Davis, Vice President
and Deputy General Counsel, Nasdaq, to Nancy M.
Morris, Secretary, Commission, dated December 13,
2007 (‘‘Nasdaq 11(a) Letter’’).
267 See, e.g., Registration Approval Order, supra
note 19; BOX Approval Order, supra note 72; and
Securities Exchange Act Release Nos. 44983
(October 25, 2001), 66 FR 55225 (November 1, 2001)
(order approving the Archipelago Exchange as an
electronic trading facility of the Pacific Exchange
(‘‘PCX’’)); 29237 (May 24, 1991), 56 FR 24853 (May
31, 1991) (regarding NYSE’s Off-Hours Trading
Facility); 15533 (January 29, 1979), 44 FR 6084
(January 31, 1979) (regarding the American Stock
Exchange (‘‘Amex’’) Post Execution Reporting
System, the Amex Switching System, the
Intermarket Trading System, the Multiple Dealer
Trading Facility of the Cincinnati Stock Exchange,
the PCX Communications and Execution System,
and the Philadelphia Stock Exchange’s Automated
Communications and Execution System (‘‘1979
Release’’)); and 14563 (March 14, 1978) 43 FR
11542 (March 17, 1978) (regarding the NYSE’s
Designated Order Turnaround System (‘‘1978
Release’’)).
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believes that the NOM System satisfies
the off-floor transmission requirement.
Second, the Rule requires that the
member not participate in the execution
of its order. Nasdaq represented that at
no time following the submission of an
order is a Participant able to acquire
control or influence over the result or
timing of an order’s execution.
According to Nasdaq, the execution of a
member’s order is determined solely by
what other orders, bids, or offers are
present in the NOM System at the time
the Participant submits the order and on
the priority of those orders, bids, and
offers.268 Accordingly, the Commission
believes that a Participant does not
participate in the execution of an order
submitted to the NOM System.
Third, Rule 11a2–2(T) requires that
the order be executed by an exchange
member who is unaffiliated with the
member initiating the order. The
Commission has stated that this
requirement is satisfied when
automated exchange facilities, such as
the NOM System, are used, as long as
the design of these systems ensures that
members do not possess any special or
unique trading advantages in handling
their orders after transmitting them to
the exchange.269 Nasdaq has
represented that the design of the NOM
System ensures that no member has any
special or unique trading advantage in
the handling of its orders after
transmitting its orders to the
Exchange.270 Based on Nasdaq’s
representation, the Commission believes
that the NOM System satisfies this
requirement.
Fourth, in the case of a transaction
effected for an account with respect to
268 See Nasdaq 11(a) Letter, supra note 266, at 7.
The Participant may cancel or modify the order, or
modify the instruction for executing the order, but
only from off the floor. The Commission has stated
that the non-participation requirement is satisfied
under such circumstances so long as such
modifications or cancellations are also transmitted
from off the floor. See 1978 Release, supra note 267
(stating that the ‘‘non-participation requirement
does not prevent initiating members from canceling
or modifying orders (or the instructions pursuant to
which the initiating member wishes orders to be
executed) after the orders have been transmitted to
the executing member, provided that any such
instructions are also transmitted from off the
floor’’).
269 In considering the operation of automated
execution systems operated by an exchange, the
Commission noted that while there is not an
independent executing exchange member, the
execution of an order is automatic once it has been
transmitted into the systems. Because the design of
these systems ensures that members do not possess
any special or unique trading advantages in
handling their orders after transmitting them to the
exchange, the Commission has stated that
executions obtained through these systems satisfy
the independent execution requirement of Rule
11a2–2(T). See 1979 Release, supra note 267.
270 See Nasdaq 11(a) Letter, supra note 266, at 8.
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which the initiating member or an
associated person thereof exercises
investment discretion, neither the
initiating member nor any associated
person thereof may retain any
compensation in connection with
effecting the transaction, unless the
person authorized to transact business
for the account has expressly provided
otherwise by written contract referring
to Section 11(a) of the Act and Rule
11a2–2(T).271 Nasdaq represents that
Participants trading for covered
accounts over which they exercise
investment discretion must comply with
this condition in order to rely on the
rule’s exemption.272
III. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning Amendment No.
2, including whether Amendment No. 2
is consistent with the Act. Comments
may be submitted by any of the
following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–NASDAQ–2007–004 on the
subject line.
Paper Comments
• Send paper comments in triplicate
to Nancy M. Morris, Secretary,
Securities and Exchange Commission,
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–NASDAQ–2007–004. This
file number should be included on the
subject line if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
271 17 CFR 240.11a2–2(T)(a)(2)(iv). In addition,
Rule 11a2–2(T)(d) requires a member or associated
person authorized by written contract to retain
compensation, in connection with effecting
transactions for covered accounts over which such
member or associated persons thereof exercises
investment discretion, to furnish at least annually
to the person authorized to transact business for the
account a statement setting forth the total amount
of compensation retained by the member in
connection with effecting transactions for the
account during the period covered by the statement.
See 17 CFR 240.11a2–2(T)(d). See also 1978
Release, supra note 267 (stating ‘‘[t]he contractual
and disclosure requirements are designed to assure
that accounts electing to permit transaction-related
compensation do so only after deciding that such
arrangements are suitable to their interests’’).
272 See Nasdaq 11(a) Letter, supra note 266, at 8.
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14539
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for inspection and copying in
the Commission’s Public Reference
Room, 100 F Street, NE., Washington,
DC 20549, on official business days
between the hours of 10 a.m. and 3 p.m.
Copies of such filing also will be
available for inspection and copying at
the principal office of the Amex. All
comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–NASDAQ–2007–004 and
should be submitted on or before April
8, 2008.
IV. Exemption From Section 19(b) of the
Act With Regard to CBOE, NYSE, and
FINRA Rules Incorporated by
Reference
Nasdaq proposes to incorporate by
reference as NOM Rules certain rules of
the CBOE, NYSE, and FINRA.273 Thus,
for certain NOM rules, NOM members
will comply with a NOM rule by
complying with the CBOE, NYSE, or
FINRA rule referenced. In connection
with its proposal to incorporate CBOE,
NYSE, and FINRA rules by reference,
Nasdaq requested, pursuant to Rule
273 Specifically, Nasdaq proposes to incorporate
by reference: (1) CBOE rules governing position and
exercise limits for equity and index options, which
are cross-referenced in Chapter III, Sections 7 and
9 of the NOM Rules and Chapter XIV, Sections 5
and 7 of the NOM Rules, respectively; (2) the
margin rules of the CBOE or the NYSE, which are
referenced in Chapter XIII, Section 3 of the NOM
Rules; and (3) FINRA’s rules governing
communications with the public, which are
referenced in Chapter XI, Section 22 of the NOM
Rules. With respect to position limits, one
commenter believes that each options exchange
should be required to develop its own expertise and
establish specific requirements in its own rules to
provide for proper disclosure to members and to
further the exchange’s compliance and surveillance
functions. See Amex Letter, supra note 4, at 4.
Nasdaq believes that its reliance on the position and
exercise limit rules of CBOE assures equal
regulation among markets. See Nasdaq Response,
supra note 5, at 2. The Commission does not believe
that requiring each options exchange to develop its
own position limits would promote the efficient use
of SRO and Commission resources. In addition, as
discussed below, Nasdaq will notify Participants
whenever the CBOE proposes to change a position
limit rule that has been incorporated by reference
into the NOM Rules.
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240.0–12,274 an exemption under
Section 36 of the Act from the rule filing
requirements of Section 19(b) of the Act
for changes to those NOM rules that are
effected solely by virtue of a change to
a cross-referenced CBOE, NYSE, or
FINRA rule.275 Nasdaq proposes to
incorporate by reference categories of
rules (rather than individual rules
within a category) that are not trading
rules. Nasdaq agrees to provide written
notice to Participants prior to the launch
of NOM of the specific CBOE, NYSE,
and FINFRA rules that it will
incorporate by reference.276 In addition,
Nasdaq will notify Participants
whenever CBOE, NYSE, or FINRA
proposes a change to a cross-referenced
CBOE, NYSE, or FINRA rule.277
Using its authority under Section 36
of the Act, the Commission previously
exempted certain SROs from the
requirement to file proposed rule
changes under Section 19(b) of the
Act.278 Each such exempt SRO agreed to
be governed by the incorporated rules,
as amended from time to time, but is not
required to file a separate proposed rule
change with the Commission each time
the SRO whose rules are incorporated
by reference seeks to modify its rules.
In addition, each SRO incorporated by
reference only regulatory rules (e.g.,
margin, suitability, arbitration), not
trading rules, and incorporated by
reference whole categories of rules (i.e.,
did not ‘‘cherry-pick’’ certain individual
rules within a category). Each exempt
SRO had reasonable procedures in place
to provide written notice to its members
each time a change is proposed to the
incorporated rules of another SRO in
order to provide its members with
notice of a proposed rule change that
affects their interests, so that they would
have an opportunity to comment on it.
The Commission is granting Nasdaq’s
request for exemption, pursuant to
Section 36 of the Act, from the rule
filing requirements of Section 19(b) of
the Act with respect to the rules that
274 17
CFR 240.0–12.
letter from Jeffrey S. Davis, Vice President
and Deputy General Counsel, Nasdaq, to Nancy
Morris, Secretary, Commission, dated December 13,
2007 (‘‘Nasdaq 19(b) Exemption Letter’’).
276 See Nasdaq 19(b) Exemption Letter, supra note
275, at 2.
277 NOM will provide such notice through a
posting on the same web site location where NOM
will post its own rule filings pursuant to Rule 19b–
4(l) under Act, within the time frame required by
that Rule. The web site posting will include a link
to the location on the CBOE, NYSE, or FINRA web
site where those SROs’ proposed rule changes are
posted. See Nasdaq 19(b) Exemption Letter, supra
note 275, at note 4 and accompanying text.
278 See Securities Exchange Act Release No.
49260 (February 17, 2004), 69 FR 8500 (February
24, 2004). See also Registration Approval Order,
supra note 19.
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Nasdaq proposes to incorporate by
reference into NOM’s Rules.279 This
exemption is conditioned upon Nasdaq
providing written notice to NOM
participants whenever the CBOE, NYSE,
or FINRA proposes to change a rule that
NOM has incorporated by reference.
The Commission believes that this
exemption is appropriate in the public
interest and consistent with the
protection of investors because it will
promote more efficient use of
Commission and SRO resources by
avoiding duplicative rule filings based
on simultaneous changes to identical
rule text sought by more than one SRO.
Consequently, the Commission grants
Nasdaq’s exemption request for NOM.
V. Exemption From the Requirement To
Register as a SIP
As described above, NOM LLC will be
delegated the authority to act as a SIP
for quotations and transaction
information related to securities traded
on NOM and any trading facilities
operated by NOM LLC. In a letter dated
December 13, 2007 (‘‘Request
Letter’’) 280 submitted in conjunction
with Nasdaq’s proposal, Nasdaq, on
behalf of NOM LLC, requested that the
Commission grant NOM LLC a
permanent exemption from the
requirement under Section 11A(b) of the
Act and Rule 609 thereunder that a
securities information processor acting
as an exclusive processor register with
the Commission.281 For the reasons
discussed below, the Commission grants
the requested exemption, subject to the
conditions specified in this order.
A. Overview
Pursuant to Nasdaq’s proposal being
approved today, NOM LLC will be a
wholly owned subsidiary, established
for the purpose of operating a Nasdaq
facility for the trading of options.
Nasdaq will delegate the performance of
certain of its market functions to NOM
LLC with respect to the quoting and
trading of options, including the
authority to act as a securities
information processor for quoting and
trading information related to options
traded on NOM and any trading
facilities operated by NOM LLC.
279 As discussed above, Nasdaq has represented
that it will notify Participants whenever the CBOE,
NYSE, or FINRA proposes a change to a crossreferenced CBOE, NYSE, or FINRA rule. See supra
note 277 and accompanying text.
280 See letter from Edward S. Knight, Executive
Vice President and General Counsel, Nasdaq, to Dr.
Erik Sirri, Director, Division of Trading and
Markets, Commission, dated December 13, 2007.
281 15 U.S.C. 78k–1(b). Rule 609 under the Act,
17 CFR 242.609, requires that the registration of a
securities information processor be on Form SIP, 17
CFR 249.1001.
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Because NOM LLC will be engaging, on
an exclusive basis on behalf of Nasdaq,
in collecting, processing, or preparing
for distribution or publication
information with respect to transactions
or quotations on, or effected or made by
means of, a facility of Nasdaq, it will be
an exclusive processor required to
register pursuant to Section 11A(b) of
the Act. Nevertheless, as further
described in the Request Letter, Nasdaq
and NOM LLC believe that the purposes
of Section 11A(b) of the Act are not
served by requiring NOM LLC to register
as an exclusive processor under Section
11A(b) of the Act because Section
11A(b) subjects registered securities
information processor to a regulatory
regime to which NOM will be subject in
all material respects as a facility of a
registered national securities exchange.
B. Discussion
Sections 11A(b)(1) and (2) of the Act
and Rule 609 thereunder (formerly Rule
11Ab2–1) provide that a securities
information processor 282 that is acting
as an exclusive processor 283 register
with the Commission by filing an
application for registration on Form SIP.
Section 11A(b)(1) of the Act and Rule
609(c) thereunder allow the
Commission, by rule or order, to
conditionally or unconditionally
exempt any securities information
processor from any provision of Section
11A(b) of the Act or the rules or
regulations thereunder, if the
Commission finds that such exemption
is consistent with the public interest,
the protection of investors, and the
purposes of Section 11A(b).284
282 Section 3(a)(22) of the Act, 15 U.S.C.
78c(a)(22)(A), defines the term securities
information processor to mean any person engaged
in the business of (i) collecting, processing, or
preparing for distribution or publication, or
assisting, participating in, or coordinating the
distribution or publication of, information with
respect to transactions in or quotations for any
security (other than an exempted security) or (ii)
distributing or publishing (whether by means of a
ticker tape, a communications network, a terminal
display device, or otherwise) on a current and
continuing basis, information with respect to such
transactions or quotations.
283 Under Section 3(a)(22)(B) of the Act, 15 U.S.C.
78c(a)(22)(B), an exclusive processor is defined as
any securities information processor or selfregulatory organization which, directly or
indirectly, engages on an exclusive basis on behalf
of any national securities exchange or registered
securities association, or any national securities
exchange or registered securities association which
engages on an exclusive basis on its own behalf, in
collecting, processing, or preparing for distribution
or publication any information with respect to (i)
transactions or quotations on or effected or made by
means of any facility of such exchange or (ii)
quotations distributed or published by means of any
electronic system operated or controlled by such
association.
284 See 15 U.S.C. 78k–1(b)(1) and 17 CFR
242.609(c).
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In its release adopting Rule 609, the
Commission provides a framework for
the consideration of exemption requests
pursuant to Section 11A(b)(1) of the
Act.285 Specifically, the Commission
indicates that the need for registration of
an exclusive processor should be
considered in respect of Sections
11A(b)(1), (b)(3) and (b)(5) and Sections
17(a) and (b) of the Act, insofar as they
provide a framework for the
surveillance and regulation of registered
securities information processors. The
Commission stated that any application
for an exemption from registration
should show not only how such
exemption would be consistent with the
statutory purposes discussed in the
release, but also should demonstrate
why, by virtue of the applicant’s
organization, operation or other
characteristics, the applicant should be
exempted from registration, the
requirements of Section 11A(b) and the
Commission’s authority under Sections
17(a) and 17(b) of the Act.286
The Commission believes that NOM
LLC will be acting as an exclusive
processor as defined in Section
3(a)(22)(B) of the Act because it will
engage on an exclusive basis on behalf
of Nasdaq, in collecting, processing, or
preparing for distribution or publication
information with respect to transactions
or quotations on, or effected or made by
means of, a facility of Nasdaq. Further,
NOM LLC, in carrying out market
functions of Nasdaq, will operate (and
will be regulated) as a facility of Nasdaq,
which is a national securities exchange
registered under Section 6 of the Act
and the rules and regulations
thereunder.287 In the Request Letter,
Nasdaq represents that NOM LLC will
not perform any exclusive processor
functions other than in its capacity as a
facility for Nasdaq.288
As discussed below, with respect to
its operation as a facility of a registered
national securities exchange, NOM LLC
already will be subject to regulation and
Commission oversight under the Act as
285 See Securities Exchange Act Release No.
11673 (September 23, 1975), 40 FR 45422 (October
2, 1975) (adopting Commission Rule 11Ab2–1,
which has been redesignated as Rule 609).
286 Id. at 45423.
287 Section 3(a)(2) of the Act, 15 U.S.C. 78c(a)(2),
defines the term facility, with respect to an
exchange, to include its premises, tangible or
intangible property whether on the premises or not,
any right to use such premises or property or any
service thereof for the purpose of effecting or
reporting a transaction on an exchange (including,
among other things, any system of communication
to or from the exchange, by ticker or otherwise,
maintained by or with the consent of the exchange),
and any right of the exchange to the use of any
property or service.
288 Request Letter, supra note 280, at 3.
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a facility of a registered exchange.289
Oversight and regulation of registered
exchanges encompass and exceed the
oversight and regulation to which NOM
LLC will be subject pursuant to
registration under Section 11A(b)(1) of
the Act and the rules and regulations
thereunder. Accordingly, the
Commission believes that registration of
NOM LLC as an exclusive processor
under Section 11A(b)(1) of the Act with
respect to those functions that it will
carry out as a facility of Nasdaq would
not further the purposes of the Act.
1. Denial of Access to Services Provided
by a Securities Information Processor or
a National Securities Exchange
Section 11A(b)(5)(A) of the Act (1)
requires a registered securities
information processor to promptly file
notice with the Commission if the
processor prohibits or limits any person
in respect of access to services offered,
directly or indirectly, by the processor,
and (2) provides that any such
prohibition or limitation will be subject
to Commission review, on its own
motion or upon application by any
person aggrieved.290 If the prohibition
or limitation is reviewed, the
Commission shall dismiss the
proceeding if it finds (after notice and
opportunity of a hearing) that such
prohibition or limitation is consistent
with the provisions of the Act and the
rules and regulations thereunder and
that such person has not been
discriminated against unfairly. If the
Commission does not make such a
finding, or if it finds that such
prohibition or limitation imposes any
burden on competition not necessary or
appropriate in furtherance of the
purposes of the Act, the Commission
shall set aside the prohibition or
limitation and require the securities
information processor to permit such
person access to services offered by the
processor.291
NOM LLC, however, will be subject to
similar Commission regulation and
oversight pursuant to Sections 6(b)(7),
6(d), 19(d), and 19(f) of the Act with
respect to its activities as a facility of
Nasdaq.292 Section 19(d)(1) requires, in
part, that an exchange promptly file
notice with the Commission if the
exchange prohibits or limits any person
289 The definition of an exchange under the Act
includes ‘‘the market facilities maintained by such
exchange.’’ See Section 3(a)(1) of the Act, 15 U.S.C.
78c(a)(1). The functions and operation of a national
securities exchange encompass the collection,
processing, and dissemination of information
related to securities trading.
290 See 15 U.S.C. 78k–1(b)(5)(A).
291 See Section 11A(b)(5)(B) under the Act, 15
U.S.C. 78k–1(b)(5)(B).
292 15 U.S.C. 78f(b)(7) and (d) and 78s(d) and (f).
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Frm 00113
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Sfmt 4703
14541
in respect to access to services offered
by such exchange or member thereof.293
Any such action for which the exchange
must file notice is subject to
Commission review.294
Section 19(f) of the Act, among other
things, allows the Commission to set
aside an SRO’s prohibition or limitation
with respect to access to services offered
by the SRO if the Commission finds that
the prohibition or limitation imposes
any burden on competition not
necessary or appropriate in furtherance
of the purposes of the Act.
Section 6(b)(7) of the Act provides
that the rules of an exchange, among
other things, must provide a fair
procedure for the prohibition or
limitation by the exchange of any
person with respect to access to services
offered by the exchange or a member
thereof.295
Section 6(d) of the Act requires,
among other things, that a national
securities exchange that initiates a
proceeding to determine whether to
prohibit or limit a person’s access to
services offered by the exchange notify
the person of the specific grounds for
the prohibition or limitation and
provide an opportunity to be heard. In
addition, Section 6(d) provides that an
exchange’s determination to prohibit or
limit a person’s access to the exchange’s
services must be supported by a
statement setting for the specific
grounds on which the prohibition or
limitation is based.
The Commission therefore believes
that regulation of Nasdaq as a national
securities exchange provides for
equivalent regulation and Commission
oversight of actions that NOM LLC may
take in its capacity as a facility to deny
access to services as would be the case
were it to register as an exclusive
processor under Section 11A(b) of the
Act.
2. Limitation on Activities of a
Securities Information Processor or a
National Securities Exchange
Section 11A(b)(6) of the Act grants the
Commission authority to censure or
place limitations on the activities,
functions, or operations of any
registered securities information
processor or suspend for a period not
exceeding twelve months or revoke the
registration of any such processor.296
Likewise, Section 19(h)(1) of the Act
grants the Commission authority to
293 15
U.S.C. 78s(d)(1).
U.S.C. 78s(d)(2). See also Section 19(f) of
the Act, 15 U.S.C. 78s(f).
295 15 U.S.C. 78f(b)(7). Section 6(d)(2), 15 U.S.C.
78f(d)(2), provides procedural requirements for any
such proceeding by an exchange.
296 15 U.S.C. 78k–1(b)(6).
294 15
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Federal Register / Vol. 73, No. 53 / Tuesday, March 18, 2008 / Notices
suspend for a period not exceeding
twelve months or revoke the registration
of an exchange, or to censure or impose
limitations upon the activities,
functions, and operations of an
exchange.297 The Commission therefore
has the authority to place limitations on
the activities of NOM LLC as a facility
of a registered national securities
exchange.
3. Access to Books and Records of a
Securities Information Processor or a
National Securities Exchange
Section 17(a)(1) of the Act requires
that national securities exchanges and
registered securities information
processors make and keep for prescribed
periods such records, furnish such
copies thereof, and make and
disseminate such reports as the
Commission, by rule, prescribes as
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of the Act.298 Section 17(b) of
the Act requires that such records be
subject at any time, or from time to time,
to such reasonable periodic, special, or
other examinations by representatives of
the Commission and the appropriate
regulatory agency for such persons.299
The record retention and production
requirements set out in Sections 17(a)
and (b) of the Act therefore will be
applicable to NOM LLC with respect to
its activities as a facility of Nasdaq.
Thus, requiring NOM LLC to register as
an exclusive processor with respect to
its activities as a facility of a registered
exchange would serve no additional
regulatory purpose in this instance.
mstockstill on PROD1PC66 with NOTICES
C. Conclusion
On the basis of the foregoing, the
Commission finds that, with respect to
its activities as a facility of Nasdaq,
granting an exemption to NOM LLC
297 15 U.S.C. 78s(h)(1). See also Sections 19(h)(2),
(h)(3), and (h)(4) of the Act, 15 U.S.C. 78s(h)(2),
(h)(3), and (h)(4).
298 15 U.S.C. 78q(a). The Commission has
promulgated rules pursuant to Section 17(a) of the
Act that apply to national securities exchanges, but
not registered securities information processors.
See, e.g., Rule 17a–1 under the Act, 17 CFR
240.17a–1 (requiring in part a national securities
exchange to preserve, for a period of not less than
five years, the first two in an easily accessible place,
at least one copy of all documents that are made
or received by it in the course of its business as
such and in the conduct of its self-regulatory
activity, and to furnish copies of such records to
any representative of the Commission upon
request). Form SIP, the application for registration
of a securities information processor, does require
that a securities information processor provide the
Commission with certain information relating to its
business organization, financial information,
operational capability, and access to services. 17
CFR 249.1001.
299 15 U.S.C. 78q(b).
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17:39 Mar 17, 2008
Jkt 214001
from the requirement to register as a
securities information processor
pursuant to Section 11A(b) of the Act is
consistent with the public interest, the
protection of investors, and the
purposes of Section 11A(b) of the Act,
including maintenance of fair and
orderly markets in securities and the
removal of impediments to, and
perfection of the mechanism of, a
national market system. This exemption
is limited only to the exclusive
processor activities that NOM LLC
performs as a facility of Nasdaq.
VI. Accelerated Approval of the
Trading Rules Proposal, as Amended
The Commission finds good cause for
approving the Trading Rules Proposal,
as amended, prior to the thirtieth day
after the date of publication of notice of
filing of the amended proposal in the
Federal Register.
As discussed above, the Commission
believes that the changes proposed in
Amendment No. 2 strengthen and
clarify the Trading Rules Proposal. In
addition to making non-substantive and
technical changes, Amendment No. 2
incorporates changes designed to make
NOM’s rules consistent with or
substantially similar to rules adopted by
the other options exchanges or the
provisions of the Linkage Plan.300 Other
changes in Amendment No. 2 are
designed to clarify NOM’s rules,301
provide additional protections,302
300 See, e.g., the addition of rules in Chapter II
providing for registration as a Limited Principal and
as a Limited Representative in options and security
futures; changes in Chapter IV, Section 3, to allow
NOM to list an option that does not meet its initial
listing standards if the option is listed on another
national securities exchange and meets certain
other conditions (see supra notes 220 to 221 and
accompanying text); changes to Chapter IV,
Commentaries .02 and .03, relating to the $1 Strike
Price Program and the $2.50 Strike Price Program,
respectively (see supra notes 208 to 213 and
accompanying text); changes to the obvious error
provisions of Chapter V, Section 6 (see supra note
168 and accompanying text); and changes to various
provisions of the Intermarket Linkage Rules in
Chapter XII to require a response time of five
seconds rather than three seconds.
301 See, e.g., revisions to Nasdaq IM–9216 to
include Chapter X, Section 7 of the NOM Rules in
Nasdaq’s MRVP (see supra notes 243 to 249 and
accompanying text); changes to Chapter I, Section
1 to clarify the definition of ‘‘primary market;’’
changes to Chapter III, Section 15 to clarify that the
provisions of the rule apply only to options clearing
Participants; changes to Chapter VI, Section 10 to
more clearly articulate NOM’s price/time execution
algorithm; the deletion of a proposed provision in
Chapter VII relating to short sales by options market
makers; and changes to Chapter VIII, Sections 1(b)
and 1(d) to require Participants to submit contrary
exercise advices to the Options Clearing
Corporation rather than to NOM.
302 See, e.g., changes to Chapter III, Section 4(f)
to prohibit a Participant with knowledge of an order
being facilitated or submitted to NOM for price
improvement (e.g., price improving orders) from
entering an order to buy or sell the underlying
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Frm 00114
Fmt 4703
Sfmt 4703
address non-substantive issues or
address concerns raised by
commenters.303 For these reasons, the
Commission finds good cause for
approving the Trading Rules Proposal,
as amended, on an accelerated basis,
pursuant to Section 19(b)(2) of the Act.
VII. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,304 that the
Trading Rules Proposal (SR–NASDAQ–
2007–004), as amended, be, and hereby
is, approved on an accelerated basis,
except for the $1 Strike Price Program,
which is approved on a pilot basis
through June 5, 2008; and that the
Corporate Structure Proposal (SR–
security, as provided in the rule; a modification to
the position and exercise limits in Chapter III,
Sections 7 and 9 to clarify that the incorporation of
CBOE rules applies to the trading of options listed
on both CBOE and Nasdaq; modifications to the
Closing Cross procedures in Chapter VI, Section 9
that, among other things, provide that the Current
Reference Price and the Near Clearing Price will be
disseminated in an option’s minimum price
variation and never at a price that would expose
undisplayed interest on the NOM book (see supra
notes 162 to 164 and accompanying text); additions
to Chapter VI, Section 11 relating to NOS as a
facility of Nasdaq, which, among other things,
require that an SRO other than Nasdaq be the
designated examining authority for NOS, and that
NOM establish procedures and controls designed to
restrict the flow of confidential and proprietary
information between Nasdaq and its facilities,
including NOS (see supra notes 187 to 191 and
accompanying text); the addition to Chapter VI,
Section 11 of a requirement that Participants whose
orders are routed to away markets honor such
trades to the same extent that they would be
obligated to honor a trade executed on NOM; a
change to Chapter XI, Section 21 to state that a
Participant must expedite the transfer of a
customer’s account pursuant to Nasdaq Rules IM–
2110–7 and 11870; changes to Chapter XIV to add
position limit provisions for Micro-Narrow Based
Index options and to refer to the applicable NOM
rules for position limits on broad-based index
options traded on NOM but not on the CBOE.
303 See, e.g., the proposed change to eliminate
Non-Displayed Orders (see supra notes 100 to 102
and accompanying text); the revised definition of
‘‘index option’’ (see supra note 219); the changes in
Chapter IV, Section 5 to clarify NOM’s procedures
and status with respect to the Linkage Plan when
an options class that has been approved for listing
on NOM has no series open for trading, and when
the sole Market Maker in a series withdraws its
registration (see supra notes 78 to 79 and
accompanying text); the changes in Chapter VI to
clarify the definitions and order routing procedures
for ‘‘System Securities’’ and ‘‘Non-System
Securities’’ (see supra notes 183 to 186 and
accompanying text); the clarification in Chapter VI,
Section 9 of the time of the Closing Cross for
options on fund shares and broad-based indexes
(see supra notes 147 to 149 and accompanying text);
the change in Chapter VI, Section 10, to identify the
taker of liquidity as the party that removes liquidity
previously posted to the Book; and the change in
Chapter VII, Section 12, Commentary .04 to indicate
that a Participant may not inform another
Participant or other third party of any of the terms
of an order after submitting the order to NOM.
304 15 U.S.C. 78s(b)(2).
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Federal Register / Vol. 73, No. 53 / Tuesday, March 18, 2008 / Notices
NASDAQ–2007–080) be, and hereby is,
approved.
Although the Commission’s approval
of the Trading Rules Proposal, as
amended, and the Corporate Structure
Proposal is final and the proposed rules
are therefore effective,305 it is further
ordered that the operation of NOM is
conditioned on the satisfaction of the
requirements below:
A. Participation in National Market
System Plans Relating to Options
Trading. Nasdaq must join the Options
Price Reporting Authority; the OLPP;
the Linkage Plan; and the National
Market System Plan of the Options
Regulatory Surveillance Authority.
B. Examination by the Commission.
Nasdaq must have, and represent in a
letter to the staff in the Commission’s
Office of Compliance Inspections and
Examinations (‘‘OCIE’’) that it has,
adequate surveillance procedures and
programs in place to effectively regulate
NOM.
C. Delegation Agreement. Nasdaq and
NOM LLC must enter into the
Delegation Agreement as described
above.306
It is further ordered, pursuant to
Section 11A(b) of the Act,307 that NOM
LLC shall be exempt from registering as
a securities information processor,
subject to the conditions specified in
this order.
It is further ordered, pursuant to
Section 36 of the Act,308 that Nasdaq
shall be exempt from the rule filing
requirements of Section 19(b) of the
Act 309 with respect to the rules that
Nasdaq proposes to incorporate by
reference into NOM’s Rules, subject to
the conditions specified in this order.
By the Commission.
Nancy M. Morris,
Secretary.
[FR Doc. E8–5320 Filed 3–17–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–57469; File No. SR–
NYSEArca–2008–08)]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Order Approving Proposed
Rule Change Pertaining to the
Imposition of Fines for Minor Rule
Violations
March 11, 2008.
On January 18, 2008, NYSE Arca, Inc.
(‘‘NYSE Arca’’ or ‘‘Exchange’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to amend NYSE Arca Rule 6.24,
‘‘Exercise of Options Contracts,’’ and
NYSE Arca Rule 10.12 ‘‘Minor Rule
Plan.’’ The proposed rule change was
published for comment in the Federal
Register on February 5, 2008.3 The
Commission received no comments
regarding the proposal. This order
approves the proposed rule change.
NYSE Arca Rule 6.24 contains special
procedures that apply to the exercise of
options on the last business day before
expiration. The Exchange proposes to
amend NYSE Arca Rule 6.24 to: (i) Add
a reference to new terminology; (ii)
make minor revisions to the procedures
related to exercising option contracts;
(iii) amend Commentary .08 of NYSE
Arca Rule 6.24 to authorize the
Exchange to sanction an OTP Holder or
OTP Firm that fails to follow NYSE Arca
Rule 6.24, pursuant to the Minor Rule
Plan (‘‘MRP’’); and (iv) add the
recommended sanctions to the MRP
contained in NYSE Arca Rule 10.12.
An option holder desiring to exercise
or not exercise expiring options must
either: (i) take no action and allow
exercise determinations to be made in
accordance with the Options Clearing
Corporation’s (‘‘OCC’’) Ex-by-Ex
procedures, where applicable; or (ii)
submit a Contrary Exercise Advice
(‘‘CEA’’) to the Exchange.4 A CEA is also
referred to within the options industry
as an Expiring Exercise Declaration
(‘‘EED’’). While the form itself may be
called by a different name, the purpose
and procedure for submitting an EED is
identical to that of a CEA. Therefore, the
Exchange proposes adding a
parenthetical reference to EEDs within
NYSE Arca Rule 6.24.
An OTP Holder or OTP Firm that
manually submits a CEA to the
Exchange does so by completing a form
and putting it in the Exchange’s
Contrary Exercise Advice Box. Going
forward, the Exchange will discontinue
the use of the Contrary Exercise Advice
Box; and instead, an OTP Holder or OTP
Firm will submit a CEA directly to a
designated representative of the
Exchange’s Options Surveillance
Department.
Commentary .08 to NYSE Arca Rule
6.24 provides that the failure of any
OTP Holder to follow the provisions
contained in this rule may be referred to
the Ethics and Business Conduct
Committee (‘‘EBCC’’) and result in the
assessment of a fine, which may
include, but is not limited to, the
disgorgement of potential economic gain
obtained or loss avoided by the subject
exercise. Referral to the EBCC involves
a formal disciplinary proceeding. NYSE
Arca proposes to add a provision to
Commentary .08 that would authorize
the Exchange to sanction an OTP Holder
or OTP Firm that fails to follow NYSE
Arca Rule 6.24, pursuant to the MRP.
The Exchange would retain the
authority to refer violators to the EBCC
for formal disciplinary proceedings.
The Exchange also proposes adding
the phrase ‘‘or OTP Firm’’ to
Commentary .08 to NYSE Arca Rule
6.24. The Exchange has always intended
to apply NYSE Arca Rule 6.24 equally
to both OTP Holders and OTP Firms.
The addition of OTP Firms will codify
the original intent of the NYSE Arca
Rule 6.24.
Under this proposal, violators of the
NYSE Arca Rule 6.24 may be subject to
MRP fines based on the number of
violations occurring within a rolling 24month period. An individual OTP
Holder would be subject to a fine of
$500 for the first offense, $1,000 for the
second offense, and $2,500 for the third
offense. An OTP Firm would be subject
to a $1,000 fine for the first offense,
$2,500 for the second offense, and
$5,000 for a third offense.5 A list of the
proposed fines would be added to the
MRP fine schedule in NYSE Arca Rule
10.12. The addition of a sanction under
the MRP adds an additional method for
disciplining violators of NYSE Arca
Rule 6.24.6 The Exchange submits that
mstockstill on PROD1PC66 with NOTICES
1 15
305 As
noted above, the $1 Strike Price Program,
which is part of the Trading Rules Proposal, is
approved on a pilot basis through June 5, 2008.
306 See supra note 15 and accompanying text.
307 15 U.S.C. 78k–1(b).
308 15 U.S.C. 78mm.
309 15 U.S.C. 78s(b).
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17:39 Mar 17, 2008
Jkt 214001
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 See Securities Exchange Act Release No. 57220
(January 29, 2008), 73 FR 6757.
4 A CEA is a communication to either: (i) Not
exercise an option that would be automatically
exercised under OCC’s Ex-by-Ex procedure, or (ii)
exercise an option that would not be automatically
exercised under OCC’s Ex-by-Ex procedure.
14543
2 17
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Fmt 4703
Sfmt 4703
5 The Exchange, in its discretion, processes
subsequent violations, after the third violation,
according to NYSE Arca Rule 10.4. See NYSE Arca
Rule 10.12(h), n.1.
6 In addition, as a member of the Intermarket
Surveillance Group, the Exchange, as well as
certain other self-regulatory organizations (‘‘SROs’’)
E:\FR\FM\18MRN1.SGM
Continued
18MRN1
Agencies
[Federal Register Volume 73, Number 53 (Tuesday, March 18, 2008)]
[Notices]
[Pages 14521-14543]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-5320]
=======================================================================
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-57478; File Nos. SR-NASDAQ-2007-004 and SR-NASDAQ-2007-
080]
Self-Regulatory Organizations; The NASDAQ Stock Market LLC;
Notice of Filing of Amendment No. 2 to a Proposed Rule Change and Order
Granting Accelerated Approval to a Proposed Rule Change, as Amended, To
Establish Rules Governing the Trading of Options on the NASDAQ Options
Market; Order Approving a Proposed Rule Change Relating to the LLC
Agreement Establishing the NASDAQ Options Market LLC and Delegation
Agreement Delegating to NOM LLC the Authority To Operate the NASDAQ
Options Market; Order Granting an Application of The NASDAQ Stock
Market LLC for an Exemption Pursuant to Section 36(a) of the Exchange
Act from the Requirements of Section 19(b) of the Exchange Act; and
Order Granting an Exemption for the NASDAQ Options Market LLC from
Section 11A(b) of the Exchange Act
March 12, 2008.
I. Introduction
On January 30, 2007, The NASDAQ Stock Market LLC (``Nasdaq'' or
``Exchange'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act''),\1\ and Rule 19b-4 thereunder,\2\ a
proposed rule change (``Trading Rules Proposal'') to adopt rules
governing participation in and trading on The NASDAQ Options Market
(``NOM''), which will be an options exchange facility of Nasdaq
operated by The Nasdaq Options Market LLC (``NOM LLC''). The proposed
rule change, as modified by Amendment No. 1, was published for comment
in the Federal Register on May 1, 2007.\3\ The Commission received five
comment letters regarding the proposed rule change.\4\ Nasdaq responded
to the
[[Page 14522]]
commenters in a letter dated December 13, 2007,\5\ and filed Amendment
No. 2 to the proposal on December 13, 2007. This notice and order
provides notice and solicits comments from interested persons regarding
Amendment No. 2 and approves the Trading Rules Proposal, as amended, on
an accelerated basis.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 55667 (April 25,
2007), 72 FR 23869 (``Trading Rules Proposal Notice'').
\4\ See letters to Nancy M. Morris, Secretary, Commission, from
Stephen Schuler, Managing Member, Global Electronic Trading Company
(``GETCO''), and Daniel Tierney, Managing Member, GETCO, dated July
20, 2007 (``GETCO Letter''); Michael J. Simon, Secretary, The
International Securities Exchange, LLC (``ISE''), dated June 15,
2007 (``ISE Letter''); John C. Nagel, Director and Associate General
Counsel, Citadel Investment Group L.L.C. (``Citadel''), dated June
11, 2007 (``Citadel Letter''); Michael T. Bickford, Senior Vice
President, Options, American Stock Exchange LLC (``Amex''), dated
May 24, 2007 (``Amex Letter''); and Christopher Nagy, Chair,
Securities Industry and Financial Markets Association (``SIFMA'')
Options Committee, dated May 22, 2007 (``SIFMA Letter'').
\5\ See letter from Jeffrey S. Davis, Vice President and Deputy
General Counsel, Nasdaq, to Nancy M. Morris, Secretary, Commission,
dated December 13, 2007 (``Nasdaq Response'').
---------------------------------------------------------------------------
Also, on September 17, 2007, the Exchange filed with the Commission
a proposed rule change, pursuant to Section 19(b)(1) of the Act \6\ and
Rule 19b-4 thereunder,\7\ to establish, through a limited liability
company agreement, NOM LLC, and to delegate to NOM LLC the authority to
operate NOM as a facility of Nasdaq (``Corporate Structure Proposal,''
and, with the Trading Rules Proposal, the ``Proposals''). The proposed
rule change was published for comment in the Federal Register on
October 12, 2007.\8\ The Commission received no comments on the
proposal. This order approves the Corporate Structure Proposal.
---------------------------------------------------------------------------
\6\ 15 U.S.C. 78s(b)(1).
\7\ 17 CFR 240.19b-4.
\8\ See Securities Exchange Act Release No. 56604 (October 3,
2007), 72 FR 58137 (``Corporate Structure Proposal Notice'').
---------------------------------------------------------------------------
On December 13, 2007, Nasdaq requested that the Commission grant
NOM LLC a permanent exemption from the requirement under Section 11A(b)
of the Act and Rule 609 thereunder that a securities information
processor (``SIP'') acting as an exclusive processor register with the
Commission.\9\ Further, on December 13, 2007, Nasdaq asked the
Commission to exempt Nasdaq from the rule filing requirements of
Section 19(b) of the Act for changes to NOM rules that are effected
solely by virtue of a change to a Chicago Board Options Exchange
(``CBOE''), New York Stock Exchange (``NYSE''), or Financial Industry
Regulatory Authority (``FINRA'') rule that NOM has incorporated by
reference. This order grants these exemptions.
---------------------------------------------------------------------------
\9\ 15 U.S.C. 78k-1(b). Rule 609 under the Act, 17 CFR 242.609,
requires that the registration of a securities information processor
be on Form SIP, 17 CFR 249.1001.
---------------------------------------------------------------------------
II. Discussion and Commission Findings
After careful review of the Trading Rule Proposal, as amended, and
consideration of the comment letters and Nasdaq's response to the
commenters, and the Corporate Structure Proposal, the Commission finds
that the Trading Rules Proposal, as amended, and the Corporate
Structure Proposal are consistent with the requirements of the Act and
the rules and regulations thereunder applicable to a national
securities exchange.\10\ Specifically, the Commission finds that the
Proposals are consistent with Section 6(b)(5) of the Act,\11\ which
requires, among other things, that the rules of a national securities
exchange be designed to prevent fraudulent and manipulative acts and
practices; to promote just and equitable principles of trade; to foster
cooperation and coordination with persons engaged in regulating,
clearing, settling, and processing information with respect to, and
facilitating transactions in securities; to remove impediments to and
perfect the mechanism of a free and open market and a national market
system; and, in general, to protect investors and the public interest.
Section 6(b)(5) also requires that the rules of an exchange not be
designed to permit unfair discrimination among customers, issuers,
brokers, or dealers. Further, the Commission finds that the Proposals
are consistent with Sections 6(b)(1) of the Act,\12\ which requires,
among other things, that a national securities exchange be so organized
and have the capacity to carry out the purposes of the Act, and to
comply and enforce compliance by its members and persons associated
with its members, with the provisions of the Act, the rules and
regulation thereunder, and the rules of the exchange, and Section
6(b)(2) of the Act,\13\ which requires, in part, that the rules of an
exchange assure a fair representation of its members in the selection
of its directors and administration of its affairs.
---------------------------------------------------------------------------
\10\ In approving this proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. 15 U.S.C. 78c(f).
\11\ 15 U.S.C. 78f(b)(5).
\12\ 15 U.S.C. 78f(b)(1).
\13\ 15 U.S.C. 78f(b)(2).
---------------------------------------------------------------------------
Overall, the Commission believes that approving Nasdaq's Proposals
could confer important benefits on the public and market participants.
In particular, NOM's entry into the marketplace could provide market
participants with an additional venue for executing orders in
standardized options, enhance innovation, and increase competition
between and among the options exchanges, resulting in better prices and
executions for investors.
This discussion does not review every detail of the proposed rule
changes, but focuses on the comments received and the most significant
rules and policy issues considered in review of the proposals.
A. Corporate Structure
In connection with the establishment of NOM, Nasdaq has entered
into a limited liability company agreement (``NOM LLC Agreement'') to
establish NOM LLC as a Delaware limited liability company that will
operate NOM as a facility of Nasdaq, as that term is defined in Section
3(a)(2) of the Act.\14\ Nasdaq and NOM LLC also will enter into a
delegation agreement (``NOM Delegation Agreement''), pursuant to which
Nasdaq will delegate to NOM LLC certain limited responsibilities and
obligations with respect to the operation of NOM as an options facility
of Nasdaq.\15\
---------------------------------------------------------------------------
\14\ 15 U.S.C. 78c(a)(2). Pursuant to Section 3(a)(2), a
``facility'' ``with respect to an exchange includes its premises,
tangible or intangible property whether on the premises or not, any
right to the use of such premises or property or any service thereof
for the purpose of effecting or reporting a transaction on an
exchange (including, among other things, any system of communication
to or from the exchange, by ticker or otherwise, maintained by or
with the consent of the exchange), and any right of the exchange to
the use of any property or service.''
\15\ The form of each of the NOM LLC Agreement and NOM
Delegation Agreement are available at the Commission's Web site
https://www.sec.gov.
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Nasdaq, a registered national securities exchange, is the wholly-
owned subsidiary of The NASDAQ Stock Market, Inc. (``Nasdaq Holding
Company''). NOM LLC will be a direct, wholly-owned subsidiary of
Nasdaq, and, pursuant to the NOM LLC Agreement, Nasdaq may not transfer
or assign, in whole or in part, its interest in NOM LLC.\16\ Further,
NOM will be operated as a facility of the Exchange and Nasdaq will
retain self-regulatory responsibility for NOM.
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\16\ See NOM LLC Agreement, Section 19. Also, Nasdaq Holding
Company may not transfer or assign its interest in Nasdaq, other
than to an affiliate of Nasdaq Holding Company. See Limited
Liability Company Agreement of The NASDAQ Stock Market LLC, Section
20. Any change to Nasdaq's status as the sole member of NOM LLC, or
to Nasdaq Holding Company's status as the sole member of Nasdaq,
would have to be filed pursuant to Section 19(b) of the Act. 15
U.S.C. 78s.
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1. Changes in Control of NOM; Ownership and Voting Limitations
The Commission notes that the Nasdaq Holding Company's Restated
Certificate of Incorporation imposes limits on direct and indirect
changes in control, which are designed to prevent any shareholder from
exercising undue control over the operation of the Exchange and to
ensure that the
[[Page 14523]]
Exchange and the Commission are able to carry out their regulatory
obligations under the Act. Specifically, no person who beneficially
owns shares of common stock, preferred stock, or notes in excess of
five percent of the securities generally entitled to vote may vote
shares in excess of five percent.\17\
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\17\ See Nasdaq Holding Company Restated Certificate of
Incorporation, Article Fourth, C. The Nasdaq Holding Company board
of directors may approve an exemption from the five percent voting
limitation for any person that is not a broker-dealer, an affiliate
of a broker-dealer, or a person subject to a statutory
disqualification under Section 3(a)(39) of the Act. See id. Any such
exemption from the five percent voting limitation would not be
effective until approved by the Commission pursuant to Section 19 of
the Act. See Nasdaq Holding Company By-Laws, Article XII, Section
12.5.
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The Exchange's rules also prohibit Exchange members and persons
associated with Exchange members from beneficially owning more than 20
percent of the then-outstanding voting securities of Nasdaq Holding
Company.\18\ Members that trade on an exchange or through the facility
of an exchange traditionally have ownership interests in such exchange
or facility. The Commission has noted in the past, however, that a
member's interest in an exchange could become so large as to cast doubt
on whether the exchange can fairly and objectively exercise its self-
regulatory responsibilities with respect to that member.\19\ A member
that is a controlling shareholder of an exchange might be tempted to
exercise that controlling influence by directing the exchange to
refrain from, or the exchange may hesitate to, diligently monitor and
surveil the member's conduct or diligently enforce its rules and the
federal securities laws with respect to conduct by the member that
violates such provisions.
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\18\ See Exchange Rule 2130.
\19\ See Securities Exchange Act Release No. 53128 (January 13,
2006), 71 FR 3550 (January 23, 2006) (order approving Nasdaq's
application to register as a national securities exchange)
(``Registration Approval Order'') at note 42 and accompanying text.
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The Commission believes that the proposed corporate structure for
NOM is consistent with the Act. The voting restrictions imposed on
shareholders of Nasdaq Holding Company will flow through to NOM LLC by
virtue of the fact that NOM LLC will be a wholly-owned subsidiary of
Nasdaq, which is a wholly-owned subsidiary of Nasdaq Holding Company.
The ownership limitation on members of Nasdaq will apply to NOM
participants by virtue of the fact that all NOM participants must be
members of the Exchange. These ownership and voting restrictions are
designed to minimize the potential that a person could improperly
interfere with or attempt to restrict the ability of the Commission or
the Exchange to effectively carry out their regulatory oversight
responsibilities under the Act.
2. Fair Representation
NOM LLC will not have its own board of directors or committees
separate from the board and committees of the Exchange. The Commission
believes that because NOM LLC does not have a separate board, and
because all NOM participants will be Exchange members, the composition
of and selection process for the Exchange board continues to satisfy
the requirement in Section 6(b)(3) of the Act that the rules of the
Exchange provide for the fair representation of members in the
selection of directors and the administration of the Exchange.\20\
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\20\ See Registration Approval Order, supra note 19, at 3553.
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3. Regulatory Independence
As noted above, NOM LLC will not have its own board or committees
separate from those of the Exchange. Additionally, pursuant to the NOM
LLC Agreement, management of the company is vested in the Exchange, and
the officers of NOM LLC will be the officers of the Exchange.\21\ As a
result, NOM LLC may only act through the Exchange and its officers and
directors.
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\21\ See NOM LLC Agreement, Sections 9 and 10, respectively. See
also Section 9(b) of the NOM LLC Agreement which requires NOM LLC
and the Exchange to comply with federal securities laws and the
rules and regulations thereunder, and to cooperate with the
Commission and NOM pursuant to their regulatory authority.
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The Commission notes that certain provisions of the Exchange's and
Nasdaq Holding Company's corporate documents are designed to maintain
the independence of Nasdaq's self-regulatory function, enable the
Exchange to operate in a manner that complies with federal securities
laws, including the objectives of Sections 6(b) and 19(g) of the Act,
and facilitate the ability of Nasdaq and the Commission to fulfill
their regulatory and oversight obligations under the Act.\22\ As a
facility of Nasdaq, the protections afforded by these provisions in the
corporate documents of the Exchange and Nasdaq Holding Company extend
to the operation of NOM.
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\22\ A discussion of Nasdaq's corporate structure and the
protections afforded by the corporate documents of Nasdaq and Nasdaq
Holding Company, is set forth in the Registration Approval Order,
supra note 19. The corporate documents of Nasdaq and Nasdaq Holding
Company are not being amended by this proposed rule change.
---------------------------------------------------------------------------
Similar provisions also are included in the NOM Delegation
Agreement. For example, NOM agrees: (1) To keep confidential non-public
information relating to Nasdaq and not to use such information for any
commercial purposes; (2) to provide the Commission and Nasdaq access to
NOM's books and records at all times and to maintain such books and
records within the United States; (3) that the books, records,
premises, officers, and employees of NOM shall be deemed to be those of
Nasdaq for purposes of the Act; and (4) to cooperate with, and take
reasonable steps to cause its agents to cooperate with, the Commission
and Nasdaq pursuant to their regulatory authority. In addition, NOM and
its officers and employees submit to the jurisdiction of the Commission
and agree to give due regard to the preservation of the self-regulatory
function of Nasdaq.\23\ Further, the NOM Delegation Agreement may not
be amended unless such amendment is filed with, or filed with and
approved by, the Commission pursuant to Section 19 of the Act.\24\ The
Commission believes that these provisions, which are designed to assist
Nasdaq in fulfilling its self-regulatory obligations and in
administering and complying with the requirements of the Act, are
consistent with the Act, in particular Sections 6(b)(1) and 19(g).
---------------------------------------------------------------------------
\23\ See NOM Delegation Agreement, II.B.
\24\ See NOM Delegation Agreement, III.
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B. Status of NOM as a Facility of Nasdaq and Delegation of Authority to
NOM LLC
As a facility of Nasdaq, NOM will be subject to the Commission's
oversight and examination. Consequently, the Commission will have the
same authority to oversee the premises, personnel, and records of NOM
LLC as it currently has with respect to Nasdaq. In addition, Nasdaq
will be fully responsible for all activity that takes place through
NOM, and NOM participants will be subject to Nasdaq's rules and
oversight.
As described in detail in the Notice, the NOM Delegation Agreement
provides that Nasdaq will delegate to NOM LLC performance of certain
limited responsibilities and obligations of Nasdaq with respect to the
operation of NOM as an options trading facility. Nasdaq, however,
expressly retains ultimate responsibility for the fulfillment of its
statutory and self-regulatory obligations under the Act. Accordingly,
as described more fully below, Nasdaq will retain ultimate
responsibility for such delegated responsibilities and functions, and
any actions taken pursuant to delegated authority will remain subject
to review, approval or rejections by Nasdaq's board
[[Page 14524]]
of directors in accordance with procedures established by Nasdaq's
board of directors. Nasdaq has filed the NOM Delegation Agreement as
part of its rules.
Pursuant to the Delegation Agreement, Nasdaq expressly retains the
authority to (1) delegate authority to NOM LLC to take actions on
behalf of the Exchange, and (2) direct NOM LLC to take action necessary
to effectuate the purposes and functions of Nasdaq, consistent with the
independence of Nasdaq's regulatory functions, exchange rules, policies
and procedures, and the federal securities laws.\25\ NOM LLC will have
delegated authority to, among other things, operate NOM, develop and
adopt governing listing standards applicable to options listed on NOM
in consultation with Nasdaq, and establish and assess listing fees,
transaction fees, market data fees and other fees for the products and
services offered by NOM.\26\ In addition, NOM LLC will have the
authority to act as a SIP for quotations and transaction information
related to securities traded on NOM and any trading facilities operated
by NOM LLC.\27\
---------------------------------------------------------------------------
\25\ See Corporate Structure Proposal Notice, supra note 8, at
58140 and NOM Delegation Agreement, I.
\26\ See Corporate Structure Proposal Notice, supra note 8, at
58140 and NOM Delegation Agreement, II.A.
\27\ See NOM Delegation Agreement, II.A.3.
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NOM LLC also will have authority to develop, adopt, and administer
rules governing participation in NOM,\28\ but the Exchange represents
that it will have ultimate responsibility for the operations, rules and
regulations developed by NOM LLC, as well as their enforcement.
Further, the Exchange represents that actions taken by NOM LLC pursuant
to its delegated authority will remain subject to review, approval or
rejection by the Exchange's board of directors.\29\ In addition, NOM
LLC will be responsible for referring to Nasdaq any complaints of a
regulatory nature involving potential rule violations by member
organizations or employees,\30\ and Nasdaq will retain overall
responsibility for ensuring that the statutory and self-regulatory
functions of the Exchange are fulfilled.\31\
---------------------------------------------------------------------------
\28\ Id.
\29\ See Corporate Structure Proposal Notice, supra note 8, at
58140.
\30\ See NOM Delegation Agreement, II.A.9.
\31\ See NOM Delegation Agreement, I.1.
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The Commission finds that it is consistent with the Act for Nasdaq
to delegate the operation of NOM to NOM LLC, while retaining ultimate
responsibility for statutory and self-regulatory obligations and
ensuring that NOM's business is conducted in a manner consistent with
the requirements of the Act.
C. Access to NOM
Only Options Participants (``Options Participants'' or
``Participants'') may transact business on NOM via the System.\32\
There are two categories of Participants: (1) Options Order Entry Firms
(``OEFs''), which represent customer orders as agent or conduct
proprietary trading; and (2) Options Market Makers (``Options Market
Makers'' or ``Market Makers''). A Participant must be a member of
Nasdaq and of another registered options exchange that is not
registered solely under Section 6(g) of the Act.\33\ As Nasdaq members,
Participants must satisfy the requirements of the Nasdaq Rule 1000
Series (Membership, Registration, and Qualification Requirements), as
well as additional requirements set forth in the NOM rules.\34\
Further, an OEF may transact business with Public Customers only if it
is a member of another registered national securities exchange or
association with which Nasdaq has entered into an agreement under Rule
17d-2 under the Act \35\ pursuant to which the other exchange or
association is the designated options examining authority for the
OEF.\36\ In addition, Options Participants that transact business with
customers must be members of FINRA.\37\
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\32\ See NOM Rules, Chapter II, Section 1(a). An Options
Participant is a firm or organization registered with Nasdaq
pursuant to Chapter II of the NOM Rules for purposes of
participating in options trading on NOM as an Order Entry Firm or
Options Market Maker. See NOM Rules, Chapter I, Section 1(a)(40).
\33\ 15 U.S.C. 78f(g). See NOM Rules, Chapter II, Sections
1(a)(iii) and 2(f). In Amendment No. 2, Nasdaq proposes to eliminate
from Chapter II, Section 1(b)(iii) a provision stating that a Nasdaq
member would automatically become a NOM Participant upon completing
a NOM Application and paying the applicable fees. Nasdaq believes
that this provision did not accurately reflect the intended scope of
review of NOM applicants, and that eliminating the provision will
improve the quality of regulation of NOM. The Commission finds that
this change is consistent with the Act.
\34\ See NOM Rules, Chapter II. Nasdaq's rules apply to
Participants unless a specific NOM rule governs or unless the
context otherwise requires. See NOM Rules, Chapter I, Section 2.
Among others, Participants will be able to provide sponsored access
to NOM to a non-member (``Sponsored Participant'') pursuant to
Nasdaq Rule 4611(d), which Nasdaq adopted in 2007. See Securities
Exchange Act Release Nos. 55061 (January 8, 2007), 72 FR 2052
(January 17, 2007) (notice of filing and immediate effectiveness of
File No. SR-Nasdaq-2006-061) (adopting Nasdaq Rule 4611(d)); and
55550 (March 28, 2007), 72 FR 16389 (April 4, 2007) (notice of
filing and immediate effectiveness of File No. SR-Nasdaq-2007-010)
(revising Nasdaq Rule 4211(d)).
\35\ 17 CFR 240.17d-2.
\36\ See NOM Rules, Chapter XI, Section 1. See also notes 240 to
241, infra, and accompanying text for a discussion of Rule 17d-2.
\37\ See NOM Rules, Chapter II, Section 2(f).
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Among other things, each Participant must be registered as a
broker-dealer and have as the principal purpose of being a Participant
the conduct of a securities business, which shall be deemed to exist if
and so long as: (1) The Participant has qualified and acts in respect
of its business on NOM as either an OEF or an Options Market Maker or
both; and (2) all transactions effected by the Participant are in
compliance with Section 11(a) of the Act \38\ and the rules and
regulations thereunder.\39\ Participants may trade options for their
own proprietary accounts or, if authorized to do so under applicable
law, may conduct business on behalf of customers.\40\
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\38\ 15 U.S.C. 78k(a).
\39\ See NOM Rules, Chapter II, Section 2(e).
\40\ See NOM Rules, Chapter II, Section 1(a).
---------------------------------------------------------------------------
1. OEFs
OEFs are Participants representing customer orders as agent on NOM
or trading as principal on NOM.\41\ OEFs also may register as Market
Makers. A Market Maker that engages in specified Other Business
Activities, or that is affiliated with a broker-dealer that engages in
Other Business Activities, including functioning as an OEF, must have
an Information Barrier between the market making activities and the
Other Business Activities.\42\
---------------------------------------------------------------------------
\41\ See NOM Rules, Chapter VII, Section 1.
\42\ See NOM Rules, Chapter VII, Section 10.
---------------------------------------------------------------------------
One commenter believes that the ability of OEFs, like Market
Makers, to enter orders on both sides of the market for the same
customer raises questions concerning the rights and responsibilities of
the OEF and the customer. In particular, the commenter asks whether
Market Makers will have exclusive access to certain NOM systems or
other tools, or otherwise have rights that differ from the rights of
these customers. The commenter also asserts that NOM's proposal lacks
clarity regarding its Participants' responsibility for surveillance of
the activities of these market participants.\43\
---------------------------------------------------------------------------
\43\ See SIFMA Letter, supra note 4, at 2.
---------------------------------------------------------------------------
In response, Nasdaq stated its belief that the NOM market model is
similar to Nasdaq's equity market structure and does not raise any
unique or challenging issues for order entry firms and investors.
Nasdaq further believes that most Participants will be familiar with
the regulatory and surveillance requirements associated with access to
NOM from their businesses in equity securities.\44\ Nasdaq represents
that,
[[Page 14525]]
within the System, Market Makers will not have any special priorities
or other privileges.\45\
---------------------------------------------------------------------------
\44\ See Nasdaq Response, supra note 5, at 2.
\45\ 45 Id. at 5. Registered market makers do, however, receive
certain benefits for carrying out their responsibilities. For
example, a lender may extend credit to a broker-dealer without
regard to the restrictions in Regulation T of the Board of Governors
of the Federal Reserve System if the credit is used to finance the
broker-dealer's activities as a specialist or market maker on a
national securities exchange (see 12 CFR 221.5(c)(6)). In addition,
market makers are excepted from the prohibition in Section 11(a) of
the Act.
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The Commission believes that it is consistent with the Act for an
options exchange not to prohibit a user of its market from effectively
operating as a market maker by holding itself out as willing to buy and
sell options contracts on a regular or continuous basis without
registering as a market maker.\46\ The Commission notes that although
an entity that effectively acts as a market maker but is not registered
as such will not be required to comply with any rules applicable to a
Market Maker, it also will not be eligible to receive certain benefits
of being a Market Maker.\47\ The Commission also agrees with Nasdaq's
assertion that NOM does not raise any unique issues related to
surveillance or the responsibilities of OEFs, and notes that all
Options Participants must also be members of Nasdaq. Further, the
Commission notes that an entity that acts as a ``dealer,'' as defined
in Section 3(a)(5) of the Act,\48\ would be required to register with
the Commission under Section 15 of the Act,\49\ and the rules and
regulations thereunder, or qualify for any exception or exemption from
registration.\50\
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\46\ See Securities Exchange Act Release No. 38054 (December 16,
1996), 61 FR 67365 (December 20, 1996) (order approving File No. SR-
CBOE-95-48).
\47\ See infra notes 76 and 84 and accompanying text.
\48\ 15 U.S.C. 78c(a)(5).
\49\ 15 U.S.C. 78o.
\50\ Activity that may cause a person to be deemed a dealer
includes ``'quoting a market in or publishing quotes for securities
(other than quotes on one side of the market on a quotations system
generally available to non-broker-dealers, such as a retail screen
broker for government securities).''' See Definition of Terms in and
Specific Exemptions for Banks, Savings Associations, and Savings
Banks Under Sections 3(a)(4) and 3(a)(5) of the Securities Exchange
Act of 1934, Securities Exchange Act Release No. 47364, 68 FR 8685,
8689, note 26 (February 24, 2003) (quoting OTC Derivatives Dealers,
Securities Exchange Act Release No. 40594, 63 FR 59362, 59370, note
61 (November 3, 1998)).
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2. Market Makers
a. Registration of Market Makers
An Options Market Maker is a Participant registered with Nasdaq as
a Market Maker.\51\ To register as a Market Maker, a Participant must
file a written application with Nasdaq Regulation, which will consider
an applicant's market making ability and other factors it deems
appropriate in determining whether to approve an applicant's
registration.\52\ All Market Makers are designated as specialists on
NOM for all purposes under the Act or rules thereunder.\53\ The NOM
Rules place no limit on the number of qualifying entities that may
become Market Makers.\54\ The good standing of a Market Maker may be
suspended, terminated, or withdrawn if the conditions for approval
cease to be maintained or the Market Maker violates any of its
agreements with Nasdaq or any provisions of the NOM Rules.\55\ A
Participant that has qualified as a Market Maker may register to make
markets in individual series of options.\56\
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\51\ See NOM Rules, Chapter VII, Section 2.
\52\ See NOM Rules, Chapter VII, Section 2(a).
\53\ See NOM Rules, Chapter VII, Section 2.
\54\ See NOM Rules, Chapter VII, Rule 2(c). However, Nasdaq may
limit access to the System based on system constraints, capacity
restrictions, or other factors relevant to protecting the integrity
of the System, pending action required to address the issue of
concern. To the extent that Nasdaq places limitations on access to
the System on any Participant(s), such limits shall be objectively
determined and submitted to the Commission for approval pursuant to
a rule change filed under Section 19(b) of the Act. See NOM Rules,
Chapter VII, Section 2(c).
\55\ See NOM Rules, Chapter VII, Section 4(b).
\56\ See NOM Rules, Chapter VII, Section 3(a).
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The Commission finds that NOM Market Maker qualifications
requirements are consistent with the Act, and notes that they are
similar to those of other options exchanges.\57\ Further, the
Commission believes that allowing NOM Market Makers to register by
series, rather than by class, will permit Market Makers to select the
options series they are most interested in trading. This is designed to
help to reduce the number of quotes submitted by such Market Makers,
and therefore could help to mitigate NOM's quote message traffic and
capacity.\58\
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\57\ See, e.g., BOX Rules, Chapter VI, Section 2 and ISE Rule
804.
\58\ See Securities Exchange Act Release No. See Securities
Exchange Act Release No. 55027 (December 29, 2006), 72 FR 1358
(January 11, 2007) (order approving File No. SR-Phlx-2006-53).
Further, one commenter believes that series-by-series registration
will allow market makers to target the series for which they are
most apt to provide liquidity, which in turn will create greater
liquidity across the entire market. See GETCO Letter, supra note 4,
at 2.
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b. Market Maker Obligations
Pursuant to NOM rules, the transactions of a Market Maker in its
market making capacity must constitute a course of dealings reasonably
calculated to contribute to the maintenance of a fair and orderly
market.\59\ Further, among other things, a Market Maker must: (1) On a
daily basis participate in the pre-opening phase and maintain a two-
sided market on a continuous basis in at least 75% of the options
series in which it is registered;\60\ (2) enter a size of at least ten
contracts for its best bid and its best offer;\61\ and (3) maintain
minimum net capital in accordance with Commission and Nasdaq rules.\62\
In addition, Nasdaq may call upon a Market Maker to submit a single bid
or offer or to maintain continuous bids and offers in one or more of
the series in which the Market Maker is registered if, in Nasdaq's
judgment, it is necessary to do so in the interest of fair and orderly
markets.\63\ If Nasdaq finds any substantial or continued failure by a
Market Maker to engage in a course of dealings as specified in Chapter
VII, Section 5(a) of the NOM Rules, such Market Maker will be subject
to disciplinary action or suspension or revocation of registration in
one or more of the securities in which the Market Maker is
registered.\64\
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\59\ See NOM Rules, Chapter VII, Section 5(a). Amendment No. 2
replaces the provisions in the NOM proposal related to the
Exchange's ability to automatically cancel all bids and offers
posted by a Market Maker under certain circumstances with provisions
allowing any Options Participant to ask NOM staff to simultaneously
cancel all of the Options Participant's bids, offers, and orders in
all series. See NOM Rules, Chapter VII, Section 11. The Commission
believes that the proposed change is reasonably designed to enable
Participants to limit their risk and is consistent with the Act.
\60\ See NOM Rules, Chapter VII, Section 6(d)(i).
\61\ See NOM Rules, Chapter VII, Section 6(a).
\62\ See NOM Rules, Chapter VII, Section 4(a)(i).
\63\ See NOM Rules, Chapter VII, Section 6(d)(ii).
\64\ See NOM Rules, Chapter VII, Section 5(c).
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One commenter notes that NOM's rules do not appear to assure that
there will be continuous quotes in a particular series because a Market
Maker could cease disseminating quotes for a series at any time during
the trading day, and requests that Nasdaq clarify a market maker's
continuous quoting obligations.\65\ In response, Nasdaq notes that
other options markets face the possibility that a registered market
maker will withdraw its quotes during the trading day, and that NOM's
rules permit Nasdaq to require a market maker to quote continuously in
a series in which it is registered.\66\ Nasdaq further notes that it
intends to provide functionality that will allow its Market Makers to
instruct the NOM System to automatically input a quotation on the side
of the market that has been depleted. In addition, Nasdaq represents
that it will bring an appropriate disciplinary action against a Market
[[Page 14526]]
Maker that fails to meet its quoting obligations.\67\
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\65\ See SIFMA Letter, supra note 4, at 1.
\66\ See Nasdaq Response, supra note 5, at 3, and NOM Rules,
Chapter VII, Section 6(d)(ii).
\67\ See Nasdaq Response, supra note 5, at 3.
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This commenter also requests clarification of NOM's treatment of
options series without a Market Maker. In particular, the commenter
questions the actions NOM will take if a Market Maker withdraws from
making markets in a series, including whether NOM will continue to
match orders in the series.\68\ To the extent that the commenter is
questioning what will happen if a Market Maker registered in a series
does not have a quote in that series (as opposed to the Market Maker
withdrawing from registration in the series),\69\ Nasdaq states that
NOM will continue to route and execute orders in that series. In
addition, Nasdaq states that, if an order is received by NOM when its
quote is not at the NBBO, NOM will route the order automatically to a
market at the NBBO. An order displayed on NOM that becomes marketable
will be accessible through the Linkage.\70\
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\68\ See SIFMA Letter, supra note 4, at 2.
\69\ See discussion infra notes 77 to 79 and accompanying text.
\70\ See Nasdaq Response, supra note 5, at 3.
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The definition of a ``market maker'' includes a dealer who holds
itself out as being willing to buy and sell a security for his account
on a regular or continuous basis.\71\ Therefore, although under NOM's
proposal certain series may not have continuous quotes disseminated by
NOM, the Commission believes that the obligations imposed by the NOM
Rules on Market Makers fall within the definition of market maker
because they will require a NOM Market Maker to hold itself out as
being willing to buy and sell a security for its account on a regular
basis. The Commission therefore believes that the obligations imposed
by the NOM Rules on Market Makers are consistent with the Act.\72\
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\71\ See 15 U.S.C. 78c(a)(38) (definition of ``market maker'').
\72\ The Commission notes that in approving the rules of the
Boston Options Exchange (``BOX''), the Commission acknowledged that
certain options series might not have continuous quotes disseminated
by BOX, but concluded that the obligations imposed on market makers
under the BOX Rules were consistent with the Act. The Commission
also noted that the CBOE's Hybrid trading system had market maker
obligations comparable to those proposed for BOX and also did not
require market makers to quote all series. See Securities Exchange
Act Release No. 49068 (January 13, 2004), 69 FR 2775 (January 20,
2004) (order approving File No. SR-BSE-2002-15) (``BOX Approval
Order'').
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The commenter also asserts that other options exchanges generally
require market makers to provide two-sided quotations for 80% of the
classes in which a market maker is registered, and that uniform
quotation requirements among the options markets would be
desirable.\73\ In its response letter, Nasdaq states that NOM's Market
Maker participation standard, which will allow Market Makers to
register in particular options series rather than an entire class,
should result in active participation in all series for which a Market
Maker registers voluntarily.\74\ In addition, Nasdaq maintains that its
approach is numerically superior to other options exchanges, noting
that the BOX Rules effectively require market makers to maintain
continuous two-sided quotes in only 72% of the series in which they are
registered, or at times in only 60% of the series in which they are
registered.\75\
---------------------------------------------------------------------------
\73\ See SIFMA Letter, supra note 4, at 2.
\74\ See Nasdaq Response, supra note 5, at 5.
\75\ See id. and BOX Rules, Chapter VI, Section 6(d)(i).
---------------------------------------------------------------------------
Market makers receive certain benefits for carrying out their
responsibilities. For example, a lender may extend credit to a broker-
dealer without regard to the restrictions in Regulation T of the Board
of Governors of the Federal Reserve System if the credit is used to
finance the broker-dealer's activities as a specialist or market maker
on a national securities exchange.\76\ In addition, market makers are
excepted from the prohibition in Section 11(a) of the Act. The
Commission believes that a market maker must have sufficient
affirmative obligations, including the obligation to hold itself out as
willing to buy and sell options for its own account on a regular or
continuous basis, to justify this favorable treatment. The Commission
further believes that the rules of all U.S. options markets need not
provide the same standards for market maker participation, so long as
they impose affirmative obligations that are consistent with the Act.
The Commission believes that NOM's market maker participation
requirements impose sufficient affirmative obligations on NOM Market
Makers and, accordingly, that NOM's requirements are consistent with
the Act.
---------------------------------------------------------------------------
\76\ 12 CFR 221.5(c)(6).
---------------------------------------------------------------------------
Nasdaq will open trading in an options series only if there is at
least one Market Maker registered for trading in that series.\77\ One
commenter requests clarification of NOM's treatment of options series
without a Market Maker. In particular, the commenter questions the
actions NOM will take if a Market Maker withdraws from making markets
in a series, including whether NOM will continue to match orders in the
series.\78\ In response, Nasdaq states that it is amending proposed
Chapter IV, Section 5 to provide that, in the event a sole Market Maker
for a series withdraws its registration and ceases making markets, NOM
will place the series in a non-regulatory suspension and halt trading
until such time as a member registers to make markets in that
series.\79\
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\77\ See NOM Rules, Chapter IV, Section 5.
\78\ See SIFMA Letter, supra note 4, at 2.
\79\ See Nasdaq Response, supra note 5, at 3. Nasdaq further
notes that, in Amendment No. 2, it proposes to clarify that in such
circumstances, NOM will not execute orders on its book and will have
no rights and privileges under the Linkage Plan to accept inbound
orders from away markets. Nasdaq will continue to accept and route
Participant orders that are designated for routing and execution at
the best price in away markets. Id.
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In addition, the commenter notes that the proposal does not address
a Market Maker's use of the matching system for new customer orders
after it has withdrawn as a Market Maker.\80\ To the extent that the
commenter is asking whether a Market Maker can enter a customer order
when it is not quoting in a series in which it is registered, Nasdaq
notes that the NOM Rules require that, if a Market Maker enters a bid
in a series in which he is registered, he must also enter an offer,\81\
and that therefore a Market Maker will not be able to enter customer
orders without submitting a quote on the other side of the market from
the customer order.\82\ Further, Nasdaq notes that the NOM Rules
prohibit a Market Maker from acting as an OEF without instituting
appropriate information barriers.\83\ To the extent that the commenter
is asking whether an entity that withdraws as a Market Maker in a
series can then act as an OEF in that series, Nasdaq notes that a
Participant that has withdrawn as a Market Maker and is participating
in NOM as an OEF would not receive favorable margin treatment under
Regulation T.\84\
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\80\ See SIFMA Letter, supra note 4, at 2.
\81\ See NOM Rules, Chapter VII, Section 6(b), which states that
a Market Maker that enters a bid (offer) in a series in which he is
registered on NOM must enter an offer (bid).
\82\ See Nasdaq Response, supra note 5, at 4.
\83\ See NOM Rules, Chapter VII, Section 10.
\84\ See Nasdaq Response, supra note 5, at 4.
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The Commission believes that Nasdaq has adequately clarified NOM's
treatment of options series when either: (1) A registered Market Maker
is not quoting in that series or (2) a registered Market Maker
withdraws from registration in the series.
c. Single Market Maker Requirement
One commenter believes that Nasdaq should require at least two
market makers for an options series to be listed and traded on NOM so
that adequate depth and liquidity will be available to market
participants.\85\ The commenter
[[Page 14527]]
also believes that, in the context of the order exposure requirements
established in Chapter VII, Section 14 of the NOM Rules,\86\ there will
not be meaningful order exposure with a ``trading crowd'' of fewer than
two market makers.\87\ In addition, the commenter believes that the
term ``trading crowd'' may be a misnomer if the trading crowd consists
of only one market maker.\88\
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\85\ See Amex Letter, supra note 4, at 2.
\86\ Amendment No. 2 renumbers this provision as Chapter VII,
Section 12 of the NOM Rules.
\87\ See Amex Letter, supra note 4, at 1.
\88\ Id. at 2. Amex also questions the meaning of the term
``trading crowd'' in Chapter III, Section 4(f) of the NOM Rules.
Nasdaq notes that it has deleted the term ``trading crowd'' from
this rule to make clear that the electronic crowd will be composed
of all NOM Participants, as is the case for other electronic
markets. See Nasdaq Response, supra note 5, at note 9.
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In response, Nasdaq asserts that neither the Act nor Commission
rules require a market to provide for more than one market maker, and,
in fact, the specialist system is an example of a one market maker
market model.\89\ Nasdaq believes that the NOM structure fulfills the
objectives of Section 11A of the Act by providing a trading platform
that will allow customer orders to meet without the intervention of a
dealer.\90\ Nasdaq further maintains that lower barriers to
participation will attract liquidity and market depth from order entry
firms and other market participants. Nasdaq also notes that it intends
to provide an environment whereby robust competition between multiple
market makers will provide depth and liquidity, but that it does not
believe market participants should be prevented from trading directly
with one another due to the absence of multiple dealers.\91\
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\89\ See Nasdaq Response, supra note 5, at 8 to 9.
\90\ Id. at 8.
\91\ Id. at 9.
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The Commission agrees that the Act does not mandate a particular
market model for national securities exchanges, and believes that many
different types of market models could satisfy the requirements of the
Act. The Commission does not believe that the Act requires an exchange
to have market makers.\92\ Although Market Makers could be an important
source of liquidity on NOM, they likely will not be the only source. In
particular, the NOM System is designed to match buying and selling
interest of all Participants on NOM. The Commission therefore believes
that the NOM structure is consistent with the Act.
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\92\ In its release adopting Regulation ATS, the Commission
rejected the suggestion that a guaranteed source of liquidity was a
necessary component of an exchange. See Securities Exchange Act
Release No. 40760 (December 8, 1998), 63 FR 70844 (December 22,
1998) (``Regulation ATS Release''). See also Securities Exchange Act
Release No. 44983 (October 25, 2001), 66 FR 55225 (November 1, 2001)
(File No. SR-PCX-00-25) (order approving Archipelago Exchange as the
equities trading facility of the Pacific Exchange), at Section IV.B.
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D. NOM Trading System
1. Overview
NOM will be a fully automated electronic system (``System'') for
trading standardized options, and will be a facility of Nasdaq, as
defined in Section 3(a)(2) of the Act.\93\ Participants will be able to
enter Displayed Orders on NOM at single and multiple price levels for
the following order types: \94\ Market Orders; Limit Orders; Reserve
Orders; \95\ Minimum Quantity Orders; \96\ Discretionary Orders; \97\
and Price Improving Orders.\98\ Participants may designate orders to be
routed to other market centers when trading interest is not present on
NOM or to be executed only on NOM.\99\ Nasdaq also had originally
proposed to allow Participants to enter Non-Displayed Orders.\100\
Commenters expressed concerns about the use of Non-Displayed Orders in
the options markets.\101\ Nasdaq in Amendment No. 2 has proposed to
eliminate Non-Displayed Orders.\102\ Because Nasdaq has proposed to
eliminate this order type, this order does not make any findings with
respect to Non-Displayed Orders.
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\93\ 15 U.S.C. 78c(a)(2). The System includes: (1) An order
execution service that allows Participants to automatically execute
transactions in securities listed and traded on NOM; (2) a trade
reporting service that submits locked-in trades to a registered
clearing agency for clearance and settlement, transmits last sale
reports to the Options Price Reporting Authority, if required, for
dissemination to the public and industry, and provides Participants
with monitoring and risk management capabilities; and (3) a data
feed(s) that can be used to display without attribution to
Participants' MPIDs Displayed Orders on both the bid and offer side
of the market for price levels within NOM using the minimum price
variation applicable to the security. See NOM Rules, Chapter VI,
Section 1(a). See Trading Rules Proposal Notice, supra note 3, for a
more complete description of NOM operation and rules. The Commission
notes that the Plan for Reporting of Consolidated Options Last Sale
Reports and Quotation Information (``OPRA Plan'') requires each
party to the plan to collect and promptly transmit to OPRA all last
sale reports relating to its market. See OPRA Plan, Section V(a).
\94\ NOM does not propose to trade complex orders at this time.
Participants may enter orders with the following time-in-force
designations: Expire Time; Immediate or Cancel (``IOC''); DAY; and
Good Til Cancelled. See NOM Rules, Chapter VI, Section 1(g).
\95\ A Reserve Order is a limit order with displayed size and an
additional non-displayed amount, both of which are available for
execution against incoming orders. If the displayed portion of a
Reserve Order is executed fully, the System will replenish the
display portion from reserve up to the size of the original display
amount. The System creates a new time stamp for the replenished
portion of an order each time it is replenished from reserve, while
the reserve portion retains the time stamp of its original entry.
See NOM Rules, Chapter VI, Section 1(e)(1).
\96\ A Minimum Quantity Order must be designated as IOC and
requires that a specified minimum number of contracts be traded. A
Minimum Quantity Order received prior to the Opening Cross or after
the market close will be cancelled. See NOM Rules, Chapter VI,
Section 1(e)(3).
\97\ A Discretionary Order has both a displayed price and size
and a non-displayed discretionary price range at which the entering
party is willing to buy or sell. The non-displayed interest is not
entered into the System book but is converted, along with the
displayed size, into an IOC buy (sell) order at the highest (lowest)
price in the discretionary price range when displayed contracts
become available on the opposite side of the market or an execution
takes place at any price within the discretionary price range. If
more than one Discretionary Order is available for conversion into
an IOC order, the System will convert and process all such orders in
the same order as they were entered. If an IOC order is not executed
in full, the unexecuted portion of the order is reposted
automatically and displayed in the System book with a new time stamp
at its original displayed price and with its non-displayed
discretionary price range. See NOM Rules, Chapter VI, Section
1(e)(4).
\98\ A Price Improving Order is an order to buy or sell an
option at a specified price smaller than the minimum price variation
(``MPV'') in the security. Price Improving Orders may be entered in
increments as small as one cent. A Price Improving Order will be
displayed at the MPV in that security and rounded up for sell orders
and down for buy orders. See NOM Rules, Chapter VI, Section 1(e)(6).
\99\ See NOM Rules, Chapter VI, Section 11(a). See also
Amendment No. 2 and the Trading Rules Proposal Notice, supra note 3,
at 23871.
\100\ A Non-Displayed Order was defined as a limit order that is
not displayed in the System but is available for execution against
all incoming orders until executed in full or cancelled.
\101\ See Citadel Letter, supra note 4, at 3, and Amex Letter,
supra note 4, at 2.
\102\ Nasdaq has made corresponding changes throughout the NOM
Rules to reflect the deletion of this order type.
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All trading interest on NOM will be automatically executable. The
NOM System and rules provide for the ranking, display, and execution of
all orders in price/time priority without regard to the status of the
entity entering an order.\103\ Displayed Orders will have priority over
non-displayed interest at the same price.\104\ Any price improvement
resulting from an execution in the System will accrue to the party
taking liquidity.\105\
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\103\ See NOM Rules, Chapter VI, Section 10. In Amendment No. 2,
Nasdaq made a technical change to Chapter VI, Section 10 to clarify
that the System will execute trading interest at the best price in
the System before executing trading interest at the next best price.
This change does not alter the execution algorithm as it was
proposed. See Amendment No. 2.
\104\ See NOM Rules, Chapter VI, Section 10(1). At each price,
trading interest will be executed in the following order: (A)
Displayed Orders; (B) the Non-Displayed portion of Reserve Orders,
in time priority among such interest; and (C) the discretionary
portion of Discretionary Orders, in time priority among such
interest.
\105\ See NOM Rules, Chapter VI, Section 10. One commenter
maintains that the original proposal did not define ``taker of
liquidity'' and failed to specify how price improvement would accrue
to the taker of liquidity. See Amex Letter, supra note 4, at 3. In
response, Amendment No. 2 modifies NOM's rules to indicate that any
price improvement will accrue to the party removing liquidity
previously posted to the Book. See NOM Rules, Chapter VI, Section
10(3). The Commission believes that this change clarifies NOM's
rules and is consistent with the Act.
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[[Page 14528]]
The Commission believes that NOM's proposed execution priority
rules are consistent with the Act. The Commission notes that one
commenter specifically supported NOM's price/time priority algorithm,
noting its belief that ``flat and open'' systems encourage better
executions and provide increased liquidity to the market.\106\ The
Commission also believes that NOM's proposed order types are consistent
with the Act, and discusses several particular order types below.
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\106\ See GETCO Letter, supra note 4, at 1.
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2. Attributable Orders
A Displayed Order may be entered with attribution to a
Participant's MPID (an Attributable Order) or on an anonymous basis (a
Non-Attributable Order).\107\ One commenter expresses concern that
Attributable Orders could result in discrimination against particular
members.\108\ The commenter believes, for example, that it is
beneficial for a firm to identify itself when facilitating customer
order flow since an exchange and its members may want to allow
particular members to trade against more than the minimum guaranteed
amount of the order to encourage the member to send more order flow to
that exchange.\109\
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\107\ See NOM Rules, Chapter VI, Section 1(d).
\108\ See ISE Letter, supra note 4, at 2.
\109\ Id. at note 3.
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The commenter also expressed concern that identifying the entering
firm could encourage internalization. The commenter also asserts that
Attributable Orders would defeat the anti-internalization function of
the information barriers between a firm's market making and customer
order entry activities.\110\ The commenter believes that the
internalization concern is particularly significant in the context of
Nasdaq's ``first-in-first-out'' market model, where orders at a given
price will be executed in sequence, with no priority for customer
orders at the best price or pro rata distribution among participants
quoting at that price. With no customer priority or pro rata allocation
among Participants quoting at the best price, the commenter believes
that a Participant that sees its firm's order at the top of the book
would be able to execute against, and internalize, all of the displayed
order.\111\
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\110\ Id. at 2-3.
\111\ Id. at 3.
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In its response letter, Nasdaq notes that Attributable Orders are a
voluntary feature of the System, and that no firm will be required to
reveal its identity.\112\ Nasdaq also argues that there is no selective
disclosure; Nasdaq will publish the identity of the NOM Participant
only when the order is posted on the NOM book, and that disclosure will
be made simultaneously to all market participants in a proprietary data
feed.\113\ Further, Nasdaq notes that information barriers are designed
to prevent a Market Maker from obtaining and using information about
customer orders prior to execution, and that OEFs must route customer
orders to the best available market, even if that is the market
displaying the firm's Attributable Order.\114\ Nasdaq also believes
that its price/time algorithm allows less internalization than ISE's
pro rata allocation, which guarantees 40% of the order to a market
maker under certain conditions. Nasdaq further notes that there is
always the possibility that an incoming order trades with a Price
Improving Order, rather than a displayed Attributable Order.
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\112\ See Nasdaq Response, supra note 5, at 7.
\113\ Id.
\114\ Id.
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To the extent that a market participant is concerned that its order
would be discriminated against, as Nasdaq notes, the market participant
can choose to enter a Non-Attributable Order. In addition, the
Commission does not believe that it is likely that participants in a
fully electronic market, such as NOM, will refrain from trading with a
particular Participant's Attributable Orders in order to allow that
Participant to do so, particularly in light of their best execution
obligations.
Moreover, the Commission does not believe that a member's use of
Attributable Orders, by itself, will cause a Market Maker to violate
NOM's information barrier rule. The purpose of requiring information
barriers is to prohibit the flow of material non-public information
between the market making activities and other business activities of a
firm. With respect to Attributable Orders, a Market Maker will learn
the identity of an Attributable Order at the same time as all other
Participants--that is, once it is displayed on NOM and disseminated
over NOM's proprietary data feed. The Market Maker will not have any
knowledge of the order prior to that time. The Commission does not
believe that allowing Market Makers to see this information once it is
posted on the book undermines the policy of having information
barriers. The Commission might reach a different conclusion, however,
if order attribution information were disclosed preferentially to
certain Participants or if Market Makers had a systemic or other
advantage that allowed them to r