Self-Regulatory Organizations; Boston Stock Exchange, Incorporated; Boston Stock Exchange Clearing Corporation; Order Approving Proposed Rule Change, as Modified by Amendment No. 1, Amending the Certificate of Incorporation of Boston Stock Exchange, Incorporated; Notice of Filing of Amendment No. 1 to a Proposed Rule Change Relating to the Acquisition of the Boston Stock Exchange, Incorporated by The NASDAQ OMX Group, Inc., and Order Granting Accelerated Approval of the Proposed Rule Change, as Modified by Amendment No. 1; Notice of Filing of Amendment No. 1 to a Proposed Rule Change Relating to a Proposal To Transfer Boston Stock Exchange, Incorporated's Ownership Interest in Boston Options Exchange Group, LLC and Order Granting Accelerated Approval of the Proposed Rule Change, as Modified by Amendment No. 1; Notice of Filing of Amendment No. 1 to a Proposed Rule Change by the Boston Stock Exchange Clearing Corporation Relating to Amendment of Its Articles of Organization and By-Laws in Connection With the P, 46936-46955 [E8-18577]
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46936
Federal Register / Vol. 73, No. 156 / Tuesday, August 12, 2008 / Notices
OFFICE OF THE UNITED STATES
TRADE REPRESENTATIVE
SECURITIES AND EXCHANGE
COMMISSION
Fiscal Year 2008 Tariff-Rate Quota
Allocations of Raw Cane Sugar,
Refined and Specialty Sugar, and
Sugar-Containing Products; Correction
[Release No. 34–58324; File Nos. SR–BSE–
2008–02; SR–BSE–2008–23; SR–BSE–2008–
25; SR–BSECC–2008–01]
In the Federal Register of August 24,
2007, Volume 72, Page 48695, the Office
of the United States Trade
Representative published a notice
entitled ‘‘Fiscal Year 2008 Tariff-Rate
Quota Allocations of Raw Cane Sugar,
Refined and Specialty Sugar, and SugarContaining Products.’’ A correction is
being made to the information in the
table in the second column, which
contains the country-specific allocations
for raw sugar. The figure for the
allocation for the country of Nicaragua
is incorrect. The correct figure is 22,114
Metric Tons Raw Equivalent (MTRV)
rather than 22,538 MTRV. All other
information remains unchanged and
will not be repeated in this correction.
Self-Regulatory Organizations; Boston
Stock Exchange, Incorporated; Boston
Stock Exchange Clearing Corporation;
Order Approving Proposed Rule
Change, as Modified by Amendment
No. 1, Amending the Certificate of
Incorporation of Boston Stock
Exchange, Incorporated; Notice of
Filing of Amendment No. 1 to a
Proposed Rule Change Relating to the
Acquisition of the Boston Stock
Exchange, Incorporated by The
NASDAQ OMX Group, Inc., and Order
Granting Accelerated Approval of the
Proposed Rule Change, as Modified by
Amendment No. 1; Notice of Filing of
Amendment No. 1 to a Proposed Rule
Change Relating to a Proposal To
Transfer Boston Stock Exchange,
Incorporated’s Ownership Interest in
Boston Options Exchange Group, LLC
and Order Granting Accelerated
Approval of the Proposed Rule
Change, as Modified by Amendment
No. 1; Notice of Filing of Amendment
No. 1 to a Proposed Rule Change by
the Boston Stock Exchange Clearing
Corporation Relating to Amendment of
Its Articles of Organization and ByLaws in Connection With the Planned
Acquisition by The NASDAQ OMX
Group, Inc., and Order Granting
Accelerated Approval of the Proposed
Rule Change, as Modified by
Amendment No. 1
FOR FURTHER INFORMATION CONTACT:
August 7, 2008.
AGENCY:
ACTION:
USTR.
Notice; correction.
SUMMARY: The Office of the United
States Trade Representative published a
document in the Federal Register of
August 24, 2007 concerning Fiscal Year
2008 Tariff-Rate Quota allocations of
raw cane sugar, refined and specialty
sugar, and sugar-containing products.
The document contained incorrect data.
Correction to Previous Notice
Leslie O’Connor, Office of Agricultural
Affairs, telephone: 202–395–6127 or
facsimile: 202–395–4579.
Susan C. Schwab,
United States Trade Representative.
[FR Doc. E8–18520 Filed 8–11–08; 8:45 am]
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BILLING CODE 3190–W8–P
I. Introduction
On April 21, 2008, the Boston Stock
Exchange, Inc. (‘‘BSE’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’ or ‘‘SEC’’) a proposed
rule change, pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder 2 to: (1) Amend and restate
the BSE Certificate in its entirety to
reflect the planned acquisition of BSE
by The NASDAQ OMX Group, Inc.
(‘‘NASDAQ OMX’’), the parent
corporation of The NASDAQ Stock
Market LLC (‘‘Nasdaq’’); (2) replace the
BSE Constitution in its entirety with
proposed new BSE By-Laws; (3) adopt a
written operating agreement for its
subsidiary, Boston Options Exchange
Regulation, LLC (‘‘BOXR’’), and amend
the BOXR By-Laws; (4) obtain approval
for a change of control of BSX Group,
1 15
2 17
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U.S.C. 78s(b)(1).
CFR 240.19b–4.
Frm 00068
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LLC (‘‘BSX’’), which would operate,
upon Commission approval of certain
proposed rule changes, BSE’s equities
trading facility, and make related
amendments to the Operating
Agreement of BSX; (5) adopt two rules;
and (6) obtain Commission approval for
the affiliation between BSE and certain
broker-dealer subsidiaries of NASDAQ
OMX (collectively, the ‘‘BSE
Governance Proposal’’). The BSE
Governance Proposal was published for
comment in the Federal Register on
May 8, 2008.3 The Commission received
no comments on the BSE Governance
Proposal. On July 28, 2008, BSE filed
Amendment No. 1 to the BSE
Governance Proposal.4 This order
provides notice of and requests
comment on Amendment No. 1 to the
BSE Governance Proposal and approves
the BSE Governance Proposal, as
modified by Amendment No. 1, on an
accelerated basis.
On April 23, 2008, BSE filed with the
Commission a proposed rule change
(‘‘BOX Transfer Proposal’’) to transfer its
ownership interest in the Boston
Options Exchange Group, LLC (‘‘BOX’’),
the operator of BSE’s Boston Options
Exchange facility (‘‘BOX Market’’), to
MX U.S. 2, Inc. (‘‘MX US’’), a wholly´
owned U.S. subsidiary of the Montreal
Exchange Inc. (‘‘MX’’), and to amend the
BOX LLC Agreement. The BOX Transfer
Proposal was published for comment in
the Federal Register on May 8, 2008.5
The Commission received no comments
on the BOX Transfer Proposal. On July
28, 2008, BSE filed Amendment No. 1
to the BOX Transfer Proposal.6 This
order provides notice of and requests
comment on Amendment No. 1 to the
BOX Transfer Proposal and approves
the BOX Transfer Proposal, as modified
by Amendment No. 1, on an accelerated
basis.
On April 23, 2008, BSE filed with the
Commission a proposed rule change
(‘‘BSE Interim Certificate Proposal’’) to
amend the BSE Certificate to permit BSE
to make distributions to BSE
membership owners in connection with
the transfer of its ownership interest in
3 See Securities Exchange Act Release No. 57757
(May 1, 2008), 73 FR 26159 (SR–BSE–2008–23)
(‘‘BSE Governance Proposal Notice’’).
4 In Amendment No. 1 to the BSE Governance
Proposal, BSE filed NASDAQ OMX’s Certificate and
By-Laws, as proposed to be amended in connection
with the acquisition of BSE by NASDAQ OMX, and
proposed to make a non-substantive correction in
the purpose section of the original filing. See infra
note 104 and accompanying text.
5 See Securities Exchange Act Release No. 57762
(May 1, 2008), 73 FR 26170 (SR–BSE–2008–25)
(‘‘BOX Transfer Proposal Notice’’).
6 In Amendment No. 1 to the BOX Transfer
Proposal, BSE proposes to clarify Section 8.4(g) of
the BOX LLC Agreement.
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Federal Register / Vol. 73, No. 156 / Tuesday, August 12, 2008 / Notices
BOX. The BSE Interim Certificate
Proposal was published for comment in
the Federal Register on May 7, 2008.7
The Commission received no comment
letters regarding the BSE Interim
Certificate Proposal. On July 28, 2008,
BSE filed Amendment No. 1 to the BSE
Interim Certificate Proposal.8 This order
approves the BSE Interim Certificate
Proposal as modified by Amendment
No. 1.
On April 24, 2008, the Boston Stock
Exchange Clearing Corporation
(‘‘BSECC’’) filed with the Commission a
proposed rule change (‘‘BSECC
Governance Proposal’’). The BSECC
Governance Proposal was published for
comment in the Federal Register on
May 13, 2008.9 The Commission
received no comments on the BSECC
Governance Proposal. On July 28, 2008,
BSECC filed Amendment No. 1 to the
BSECC Governance Proposal.10 This
order provides notice of and requests
comment on Amendment No. 1 to the
BSECC Governance Proposal and
approves the BSECC Governance
Proposal, as modified by Amendment
No. 1, on an accelerated basis.
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II. Discussion and Commission
Findings
After careful review, the Commission
finds that the BSE Interim Certificate
Proposal, the BSE Governance Proposal,
and the BOX Ownership Transfer
Proposal are consistent with the
requirements of the Act and the rules
and regulations thereunder applicable to
a national securities exchange.11
Specifically, the Commission finds that
these proposed rule changes are
consistent with Section 6(b)(5) of the
Act,12 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
7 See Securities Exchange Act Release No. 57760
(May 1, 2008), 73 FR 25809 (SR–BSE–2008–02)
(‘‘BSE Interim Certificate Proposal Notice’’).
8 In Amendment No. 1 to the BSE Interim
Certificate Proposal, BSE proposes to correct
typographical errors in the proposed amendments
to the current BSE Certificate. Because Amendment
No. 1 is technical in nature, the Commission is not
publishing it for comment.
9 See Securities Exchange Act Release No. 57782
(May 6, 2008), 73 FR 27583 (SR–BSECC–2008–01)
(‘‘BSECC Governance Proposal Notice’’).
10 In Amendment No. 1 to the BSECC Governance
Proposal, BSECC filed NASDAQ OMX’s Certificate
and NASDAQ OMX’s By-Laws, as proposed to be
amended in connection with the acquisition of BSE
by NASDAQ OMX. See infra note 258 and
accompanying text.
11 In approving these proposed rule changes, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. 15 U.S.C. 78c(f).
12 15 U.S.C. 78f(b)(5).
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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. The Commission also
finds that these proposed rule changes
are consistent with Section 6(b)(1) of the
Act,13 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
regulations thereunder, and the rules of
the exchange; Section 6(b)(3) of the
Act,14 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; and Section
6(b)(7) of the Act,15 which requires, in
part, that the rules of an exchange
provide a fair procedure for disciplining
members.
The Commission also finds that the
BSECC Governance Proposal is
consistent with Section 17A(b)(3)(C) of
the Act,16 which requires, in part, that
the rules of a registered clearing agency
assure the fair representation of its
shareholders (or members) and
participants in the selection of its board
of directors and administration of its
affairs.
The discussion below does not review
every detail of each of the proposed rule
changes, but focuses on the most
significant rules and policy issues
considered by the Commission in
reviewing the proposals.
NASDAQ OMX, the parent
corporation of Nasdaq, and BSE have
entered into an agreement pursuant to
which NASDAQ OMX would acquire all
of the outstanding membership interests
in BSE (‘‘BSE Acquisition’’).17
Following the BSE Acquisition, BSE
would be a wholly-owned subsidiary of
NASDAQ OMX. The BSE Acquisition
would have the effect of: (1) converting
BSE, a registered national securities
exchange, from a Delaware, non-stock
corporation into a Delaware stock
corporation; and (2) demutualizing BSE
by separating equity ownership in BSE
13 15
U.S.C. 78f(b)(1).
U.S.C. 78f(b)(3).
15 15 U.S.C. 78f(b)(7).
16 15 U.S.C. 78q–1(b)(3)(C).
17 See BSE Governance Proposal Notice, supra
note 3, 73 FR 26159.
14 15
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46937
from trading privileges on BSE. BSE
members would receive cash as
consideration for their ownership
interests in BSE and would not retain
any ownership interest in BSE or its
affiliates. NASDAQ OMX plans that BSE
would operate as a separate selfregulatory organization (‘‘SRO’’) with
rules, memberships, and listings that are
separate and distinct from those of
Nasdaq.18
BSE has four affiliates: BSX, BOX,
BOXR, and BSECC. BSE owns 53.21
percent of BSX, which operated the
Boston Equities Exchange (‘‘BeX’’) until
BeX ceased operations in September
2007.19 The remaining 46.79 percent of
BSX is owned by Citigroup Financial
Strategies Inc., Credit Suisse First
Boston Next Fund Inc., LB 1 Group,
Inc., Fidelity Global Brokerage Group,
Inc., and Merrill Lynch L.P. Holdings
Inc. Following the BSE Acquisition,
NASDAQ OMX indirectly would own,
through its ownership of BSE, the 53.21
percent of BSX that BSE would continue
to own. In addition, NASDAQ OMX
would acquire the 46.79 percent interest
in BSX that is not presently owned by
BSE. Consequently, BSX would become
a wholly-owned subsidiary of NASDAQ
OMX.20
NASDAQ OMX would not acquire
BSE’s interest in BOX, the transfer of
which to a third party is a condition to
the closing of the BSE Acquisition.21
BSE proposes to transfer its 21.87
percent ownership interest in BOX to
MX US, a wholly-owned subsidiary of
MX.22 BSE intends to distribute the
proceeds from the BOX transfer to its
member owners by redeeming a portion
of each BSE member ownership for a
pro rata share of the net proceeds.23
Although BSE no longer would hold an
ownership interest in BOX, as discussed
in greater detail below,24 the BOX
Market would remain a facility of BSE
and, therefore, BSE would continue to
have self-regulatory obligations with
respect to the BOX Market.25
Finally, BOXR and BSECC are whollyowned subsidiaries of BSE and,
18 See Securities Exchange Act Release No. 57761
(May 1, 2008), 73 FR 26182, at 26183 (SR–
NASDAQ–2008–035) (‘‘NASDAQ OMX By-Laws
Proposal Notice’’).
19 See infra note 222.
20 See BSE Governance Proposal Notice, supra
note 3, 73 FR at 26159. See also infra notes 222–
244 and accompanying text.
21 See BSE Interim Certificate Proposal Notice,
supra note 7, 73 FR at 25810.
22 See BOX Transfer Proposal Notice, supra note
5, 73 FR at 26170.
23 See BSE Interim Certificate Proposal Notice,
supra note 7, 73 FR at 25810.
24 See infra notes 124–136 and accompanying
text.
25 15 U.S.C. 78c(a)(2). See also BOX Transfer
Proposal Notice, supra note 5, 73 FR at 26171.
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sroberts on PROD1PC70 with NOTICES
therefore, following the BSE Acquisition
would become wholly-owned, indirect
subsidiaries of NASDAQ OMX.26
Following the BSE Acquisition,
Nasdaq OMX would own five SROs:
Nasdaq, BSE, BSECC, Philadelphia
Stock Exchange, Inc. (‘‘Phlx’’) and Stock
Clearing Corporation of Philadelphia
(‘‘SCCP’’).27 As discussed below, the
Commission believes that the ownership
of BSE and BSECC by the same public
holding company that owns Nasdaq,
Phlx, and SCCP would not impose any
burden on competition not necessary or
appropriate in furtherance of the Act’s
purposes.28 The Commission previously
has approved proposals in which a
holding company owns multiple
SROs.29 However, the BSE Acquisition
is the first instance in which the
Commission is approving the ownership
by one holding company of three
exchanges and two clearing agencies.30
The Commission’s experience to date
with the issues raised by the ownership
26 See BSECC Governance Proposal Notice, supra
note 9, 73 FR at 27583.
27 See Securities Exchange Act Release No. 57703
(April 23, 2008), 73 FR 23293 (April 29, 2008) (SR–
Phlx–2008–31) (notice of proposed rule change
related to NASDAQ OMX’s acquisition of Phlx
(‘‘Phlx Acquisition’’)). See also Securities Exchange
Act Release No. 57818 (May 14, 2008), 73 FR 29171
(May 20, 2008) (SR–SCCP–2008–01) (notice of
proposed rule change to amend and restate the
Articles of Incorporation of the Stock Clearing
Corporation of Philadelphia (‘‘SCCP’’) in
connection with the Phlx Acquisition). See also
Securities Exchange Act Release Nos. 58179 (July
17, 2008), 73 FR 42874 (July 23, 2008) (order
approving SR–Phlx–2008–31) and 58180 (July 17,
2008), 73 FR 42890 (July 23, 2008) (order approving
SR–SCCP–2008–01).
28 15 U.S.C. 78f(b)(8) and 15 U.S.C. 78q–1(b)(3)(I).
29 See, e.g., Securities Exchange Act Release Nos.
53382 (February 27, 2006), 71 FR 11251 (March 6,
2006) (SR–NYSE–2005–77) (approving proposed
rule change relating to the combination of the New
York Stock Exchange, Inc. and Archipelago
Holdings, Inc.); 58179, supra note 27.
30 The Depository Trust and Clearing Corporation
(‘‘DTCC’’) is a holding company that at one point
owned five registered clearing agencies: The
National Securities Clearing Corporation (‘‘NSCC’’),
the Depository Trust Company (‘‘DTC’’), the
Government Securities Clearing Corporation
(‘‘GSCC’’), the MBS Clearing Corporation
(‘‘MBSCC’’), and the Emerging Markets Clearing
Corporation (‘‘EMCC’’). See Securities Exchange Act
Release Nos. 41786 (August 24, 1999), 64 FR 47882
(September 1, 1999) (SR–DTC–99–17); 41800
(August 27, 1999), 64 FR 48694 (September 7, 1999)
(SR–NSCC–99–10); 44987 (October 25, 2001), 66 FR
55218 (November 1, 2001) (SR–EMCC–2001–03);
44988 (October 25, 2001), 66 FR 55222 (November
1, 2001) (SR–MBSCC–2001–01); and 44989 (October
25, 2001), 66 FR 55220 (November 1, 2001) (SR–
GSCC–2001–11). These clearing agencies provided
clearance and settlement services for different
instruments or provided different clearance and
settlement services for the same instruments. The
GSCC and the MBSCC have since merged to form
the Fixed Income Clearing Corporation (‘‘FICC’’).
See Securities Exchange Act Release No. 47015
(December 17, 2002), 67 FR 78531 (December 24,
2002) (SR–GSCC–2002–09 and SR–MBSCC–2002–
01). The EMCC no longer operates as a clearing
agency.
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by a holding company of one or more
SROs has not presented any concerns
that have not been addressed, for
example, by Commission-approved
measures at the holding company level
that are designed to protect the
independence of each SRO.31
The Commission believes that the
current market for cash equity trading
venues is highly competitive. Existing
exchanges face significant competition
from other exchanges and from nonexchange entities such as alternative
trading systems that trade the same or
similar financial instruments.32 New
entrants to the market do not face
significant barriers to entry. In this
regard, the Chicago Board Options
Exchange, Incorporated and the
International Securities Exchange, LLC a
few years ago commenced trading of
cash equity securities.33 In addition,
other entities have recently applied for
exchange registration, which provides
evidence that they have determined
there are benefits in starting a new
exchange to compete in the
marketplace.34 In addition, since BeX
ceased operating in September 2007,
BSE has zero market share in cash
equity trading, and prior to September
2007, BSE had a very small market
share. Therefore, the BSE Acquisition
would not change the number of active
exchanges or the distribution of market
share across exchanges. Accordingly,
the Commission finds that the BSE’s
proposed rule changes are consistent
with Section 6(b)(8), which requires that
the rules of an exchange not impose any
burden on competition not necessary or
31 See infra notes 38–47, 258–261 and
accompanying text for a discussion of proposals by
BSE and BSECC to adopt NASDAQ OMX’s By-Laws
as part of their rules. See also Securities Exchange
Act Release No. 58183 (July 17, 2008), 73 FR 42850
(July 23, 2008) (order approving SR–NASDAQ–
2008–035) (‘‘NASDAQ OMX By-Laws Approval
Order’’).
32 See, e.g., Securities Exchange Act Release No.
58092 (July 3, 2008), 73 FR 40144 (July 11, 2008),
in which the Commission recognized that
‘‘[n]ational securities exchanges registered under
Section 6(a) of the Exchange Act face increased
competitive pressures from entities that trade the
same or similar financial instruments * * *.’’
33 See Securities Exchange Act Release Nos.
55389 (March 2, 2007), 72 FR 10575 (March 8,
2007) (order approving the establishment of CBOE
Stock Exchange, LLC); 55392 (March 2, 2007), 72
FR 10572 (March 8, 2007) (order approving trading
rules for non-option securities trading on CBOE
Stock Exchange, LLC); 54528 (September 28, 2006),
71 FR 58650 (October 4, 2006) (order approving
rules governing ISE’s electronic trading system for
equities).
34 See Securities Exchange Act Release No. 57322
(February 13, 2008), 73 FR 9370 (February 20, 2008)
(File No. 10–182) (notice of application and
Amendment No. 1 thereto by BATS Exchange, Inc.
for registration as a national securities exchange).
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Fmt 4703
Sfmt 4703
appropriate in furtherance of the
purposes of the Act.
With regard to NASDAQ OMX’s
ownership of two registered clearing
agencies following the BSE Acquisition,
the Commission does not believe the
acquisition of BSECC and SCCP by
NASDAQ OMX would reduce
competition with respect to the
clearance and settlement of securities
transactions. The Commission notes that
NSCC currently provides clearance and
settlement services and a central
counterparty guarantee for virtually all
trades on the New York Stock Exchange
LLC, Nasdaq, the American Stock
Exchange LLC and for all regional
exchanges, electronic communications
networks and alternative trading
systems in the U.S.35 In September
2007, BSECC ceased processing trades
and currently provides only limited
account maintenance services to its
participants. SCCP continues to forward
trades to NSCC for clearance and
settlement.36 The Commission will
continue to evaluate the competitive
environment should the operations of
either BSECC or SCCP expand, taking
into account the maintenance of fair
competition among brokers and dealers,
clearing agencies, and transfer agents.37
For these reasons, the Commission finds
that the BSECC’s proposed rule change
is consistent with Section 17A(b)(3)(I),
which requires that the rules of a
clearing agency not impose any burden
on competition not necessary or
appropriate in furtherance of the
purpose of the Act.
Finally, the Commission will
continue to monitor holding companies’
ownership of multiple SROs for
compliance with the Act, the rules and
regulations thereunder, as well as the
SRO’s own rules.
A. BSE
1. Relationship Between NASDAQ OMX
and BSE; Jurisdiction Over NASDAQ
OMX
After the BSE Acquisition, BSE would
become a subsidiary of NASDAQ OMX.
Although NASDAQ OMX is not itself an
SRO, its activities with respect to the
operation of BSE must be consistent
with, and must not interfere with, the
self-regulatory obligations of BSE.
NASDAQ OMX’s By-Laws make
applicable to all of NASDAQ OMX’s
SRO subsidiaries, including BSE (after
35 See Annual Report for the Depository Trust and
Clearing Corporation for 2007, page 14. NSCC is a
subsidiary of the DTCC, as are the FICC and the
DTC.
36 In recent years, both BSECC and SCCP have
forwarded all trades to NSCC for clearance and
settlement.
37 See 15 U.S.C. 78q–1(a)(2)(A).
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the BSE Acquisition), certain provisions
of NASDAQ OMX’s Certificate and
NASDAQ OMX’s By-Laws that are
designed to maintain the independence
of each of its SRO subsidiaries’ selfregulatory function, enable each SRO
subsidiary to operate in a manner that
complies with the federal securities
laws, and facilitate the ability of each
SRO subsidiary and the Commission to
fulfill their regulatory and oversight
obligations under the Act.38
The By-Laws of NASDAQ OMX
specify that NASDAQ OMX and its
officers, directors, employees, and
agents irrevocably submit to the
jurisdiction of the United States federal
courts, the Commission, and each selfregulatory subsidiary of NASDAQ OMX
for the purposes of any suit, action or
proceeding pursuant to the United
States federal securities laws, and the
rules and regulations thereunder, arising
out of, or relating to, the activities of any
self-regulatory subsidiary.39 Further,
NASDAQ OMX agreed to provide the
Commission with access to its books
and records.40 NASDAQ OMX also
agreed to keep confidential non-public
information relating to the selfregulatory function of BSE and not to
use such information for any nonregulatory purpose.41 In addition, the
NASDAQ OMX Board, as well as its
officers, employees, and agents are
required to give due regard to the
preservation of the independence of
BSE’s self-regulatory function.42
38 Provisions of NASDAQ OMX’s Certificate and
By-Laws are rules of BSE and BSECC because they
are stated policies, practices, or interpretations of
BSE and BSECC, pursuant to Section 19(b) of the
Act and Rule 19b–4 thereunder. Accordingly, BSE
and BSECC filed them with the Commission. See
Amendment No. 1 to the BSE Governance Proposal,
supra note 4, and Amendment No. 1 to the BSECC
Governance Proposal, supra note 10 and infra note
258 and accompanying text.
39 See proposed Section 12.3, NASDAQ OMX ByLaws.
40 See proposed Section 12.1(c), NASDAQ OMX
By-Laws. To the extent that they relate to the
activities of BSE, all books, records, premises,
officers, directors, and employees of NASDAQ
OMX would be deemed to be those of the BSE. See
id.
41 See proposed Section 12.1(b), NASDAQ OMX
By-Laws. This requirement to keep confidential
non-public information relating to the selfregulatory function is designed to prevent attempts
to limit the Commission’s ability to access and
examine such information or limit the ability of
directors, officers, or employees of NASDAQ OMX
from disclosing such information to the
Commission. See id. Other holding companies with
SRO subsidiaries have undertaken similar
commitments. See, e.g., Securities Exchange Act
Release No. 56955 (December 13, 2007), 72 FR
71979, at 71983 (December 19, 2007) (SR–ISE–
2007–101) (order approving the acquisition of
International Securities Exchange, LLC’s parent,
International Securities Exchange Holdings, Inc., by
Eurex Frankfurt AG).
42 See Section 12.1(a), NASDAQ OMX By-Laws.
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Similarly, the NASDAQ OMX Board,
when evaluating any issue, would be
required to take into account the
potential impact on the integrity,
continuity, and stability of its SRO
subsidiaries.43 Finally, the NASDAQ
OMX By-Laws require that any changes
to the NASDAQ OMX Certificate and
By-Laws be submitted to the Board of
Directors of each of its SRO subsidiaries,
including BSE, and, if such amendment
is required to be filed with the
Commission pursuant to Section 19(b)
of the Act, such change shall not be
effective until filed with, or filed with
and approved by, the Commission.
The Commission believes that the
NASDAQ OMX By-Laws, as amended to
accommodate the BSE Acquisition, are
designed to facilitate the BSE’s ability to
fulfill its self-regulatory obligations and
are, therefore, consistent with the Act.
In particular, the Commission believes
these changes are consistent with
Section 6(b)(1) of the Act,44 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 regulations
thereunder, and the rules of the
exchange.
Under Section 20(a) of the Act,45 any
person with a controlling interest in
NASDAQ OMX would be jointly and
severally liable with and to the same
extent that NASDAQ OMX is liable
under any provision of the Act, unless
the controlling person acted in good
faith and did not directly or indirectly
induce the act or acts constituting the
violation or cause of action. In addition,
Section 20(e) of the Act 46 creates aiding
and abetting liability for any person
who knowingly provides substantial
assistance to another person in violation
of any provision of the Act or rule
thereunder. Further, Section 21C of the
Act 47 authorizes the Commission to
enter a cease-and-desist order against
any person who has been ‘‘a cause of’’
a violation of any provision of the Act
through an act or omission that the
person knew or should have known
would contribute to the violation.
2. BSE Certificate
In the BSE Governance Proposal, BSE
proposes to amend and restate the BSE
43 See proposed Section 12.7, NASDAQ OMX ByLaws.
44 15 U.S.C. 78f(b)(1).
45 15 U.S.C. 78t(a).
46 15 U.S.C. 78t(e).
47 15 U.S.C. 78u-3.
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Certificate in its entirety. The restated
BSE Certificate would provide for the
issuance of 1,000 shares of common
stock (‘‘BSE Common Stock’’), all of
which would be held by NASDAQ
OMX.48 The restated BSE Certificate
would further provide that NASDAQ
OMX may not transfer or assign any
shares of BSE Common Stock, in whole
or in part, to any entity, unless such
transfer or assignment is filed with and
approved by the Commission under
Section 19 of the Act and the rules
promulgated thereunder.49 In addition,
the restated BSE Certificate would
contain provisions relating to the BSE
board of directors (‘‘BSE Board’’)
including that the total number of
directors (‘‘BSE Directors’’) constituting
the BSE Board would be fixed from time
to time by NASDAQ OMX, as the sole
stockholder, and would be elected by
NASDAQ OMX to hold office until their
respective successors have been duly
elected and qualified.50 Of particular
importance are the BSE Board
composition requirements in the BSE
By-Laws relating to independence and
fair representation of members.51
Finally, the restated BSE Certificate
would specifically provide that BSE’s
business would include actions that
support its regulatory responsibilities
under the Act.52
The Commission finds that the BSE
Certificate, as proposed to be amended
and restated, is consistent with the Act,
and, in particular, with Sections 6(b)(1)
and 6(b)(3) of the Act. The Commission
believes that the restated BSE Certificate
is designed to allow BSE to exercise
those powers necessary to carry out the
purposes of the Act and ensure
compliance by its members with the Act
and BSE rules. The Commission further
believes that the restriction on the
transfer or assignment of any shares of
BSE Common Stock without
Commission approval would minimize
the potential that a person could
improperly interfere with or restrict the
ability of the Commission, BSE, or
BOXR to carry out their regulatory
responsibilities under the Act.
3. Proposed New BSE By-Laws
In the BSE Governance Proposal, the
BSE proposes to replace its Constitution
with new BSE By-Laws. The new BSE
By-Laws reflect NASDAQ OMX’s
expectation that BSE would be operated
with governance, regulatory, and market
structures similar to those of Nasdaq.
48 See
Article Fourth, restated BSE Certificate.
49 Id.
50 See
Article Fifth, restated BSE Certificate.
infra notes 53–84 and accompanying text.
52 See Article Third, restated BSE Certificate.
51 See
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Key provisions of these new BSE ByLaws are discussed below.
The property, business, and affairs of
BSE would be managed under the
direction of the BSE Board.53 The exact
number of BSE Directors would be
determined by NASDAQ OMX, as the
sole stockholder, but in no event would
the BSE Board have fewer than ten
directors.54
Moreover, the number of NonIndustry Directors,55 including at least
three Public Directors 56 and at least one
BSE Director representative of issuers
and investors,57 would have to equal or
exceed the sum of the number of
Industry Directors 58 and Member
Representative Directors.59 Further, at
53 See
Article IV, BSE By-Laws.
Section 4.2, BSE By-Laws. In addition, no
decrease in the number of BSE Directors would
shorten the term of any incumbent BSE Director.
See Article Fifth, restated BSE Certificate.
55 ‘‘Non-Industry Director’’ is a BSE Director
(excluding Staff Directors) who is: (i) A Public
Director; (ii) an officer or employee of an issuer of
securities listed on BSE; or (iii) any other individual
who would not be an Industry Director. See Article
I(bb), BSE By-Laws.
56 ‘‘Public Director’’ is a BSE Director who has no
material business relationship with a broker or a
dealer, BSE or its affiliates, or FINRA. See Article
I(gg), BSE By-Laws.
57 See Section 4.3(a), BSE By-Laws. The BSE
Director representative of issuers and investors
would be nominated by the Nominating and
Governance Committee and elected by NASDAQ
OMX as the sole stockholder. See Sections 4.4(a)
and 4.14(b), BSE By-Laws.
58 ‘‘Industry Director’’ is a person who: (i) Is or
has served in the prior three years as an officer,
director, or employee of a broker or dealer,
excluding an outside director or a director not
engaged in the day-to-day management of a broker
or dealer; (ii) is an officer, director (excluding an
outside director), or employee of an entity that
owns more than 10% of the equity of a broker or
dealer, and the broker or dealer accounts for more
than 5% of the gross revenues received by the
consolidated entity; (iii) owns more than 5% of the
equity securities of any broker or dealer, whose
investments in brokers or dealers exceed 10% of his
or her net worth, or whose ownership interest
otherwise permits him or her to be engaged in the
day-to-day management of a broker or dealer; (iv)
provides professional services to brokers or dealers,
and such services constitute 20% or more of the
professional revenues received by the Industry
Director or 20% or more of the gross revenues
received by the Industry Director’s firm or
partnership; (v) provides professional services to a
director, officer, or employee of a broker, dealer, or
corporation that owns 50% or more of the voting
stock of a broker or dealer, and such services relate
to the director’s, officer’s, or employee’s
professional capacity and constitute 20% or more
of the professional revenues received by the
Industry Director or 20% or more of the gross
revenues received by the Industry Director’s firm or
partnership; or (vi) has a consulting or employment
relationship with or provides professional services
to BSE or any affiliate thereof or to FINRA or has
had any such relationship or provided any such
services at any time within the prior three years.
See Article I(t), BSE By-Laws.
59 See Section 4.3(a), BSE By-Laws. ‘‘Member
Representative Director’’ is a BSE Director who has
been elected by NASDAQ OMX as the sole
stockholder after having been nominated by the
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54 See
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least 20% of the BSE Directors would
have to be Member Representative
Directors and, as is currently the case,
one Industry Director would have to be
selected as a representative of a firm or
organization that is registered with BSE
for the purposes of participating in
options trading on the BOX Market
(‘‘BOX Participant Director’’).60 A BSE
Director could not be subject to a
statutory disqualification.61 The new
BSE By-Laws also permit up to two
officers of BSE, who would otherwise be
considered Industry Directors, to be
designated as Staff Directors,62 and
thereby be excluded from the definition
of Industry Director.63
The initial BSE Board would be
selected by NASDAQ OMX, as the sole
stockholder, immediately following the
BSE Acquisition. NASDAQ OMX would
hold a special meeting (or sign a consent
in lieu thereof) for the purpose of
electing the BSE Board. The initial BSE
Board would satisfy the compositional
requirements in the BSE By-Laws.64
Specifically, the initial BSE Board
would consist of at least three Public
Directors, one or two Staff Directors, at
least two Member Representative
Directors,65 an Industry Director
representing BOX Participants,66 at least
one Non-Industry Director
representative of issuers and investors,
and such additional Industry and NonIndustry Directors as NASDAQ OMX, as
Member Nominating Committee or voted upon by
BSE members pursuant to the BSE By-Laws (or
elected by the stockholders without such
nomination or voting in the case of the initial
Member Representative Directors elected pursuant
to Section 4.3(b) of the BSE By-Laws). See Article
I(x), BSE By-Laws.
60 See Section 4.4, BSE By-Laws, and Section 14,
BOXR By-Laws.
61 See Section 4.3(a), BSE By-Laws.
62 ‘‘Staff Director’’ is a BSE Director, selected at
the sole discretion of the BSE Board, who is an
officer of BSE. See Article I(g), BSE By-Laws.
63 The exclusion of Staff Directors from the
definition of Industry Director is consistent with
provisions previously approved by the Commission.
See Securities Exchange Act Release No. 53128
(January 13, 2006), 71 FR 3550 (January 23, 2006)
(order approving application of Nasdaq for
registration as a national securities exchange)
(‘‘Nasdaq Exchange Approval Order’’). See also
Securities Exchange Act Release No. 44280 (May 8,
2001), 66 FR 26892 (May 15, 2001) (order approving
amendment to the National Association of
Securities Dealers (‘‘NASD’’) By-Laws to allow for
the treatment of Staff Governors as ‘‘neutral’’ for
purposes of Industry/Non-Industry balancing on the
NASD Board of Governors).
64 See Section 4.3(b), BSE By-Laws.
65 The initial Member Representative Directors
would be officers, directors, or employees of BSE
members. See BSE Governance Proposal Notice,
supra note 3, at 73 FR 26162.
66 ‘‘BOX Participant’’ is a firm or organization that
is registered with BOX for purposes of participating
in options trading on the BOX Market as an order
flow provider or market maker. See Section 1.1, 6th
BOX LLC Agreement. See also BOX Rules, Chapter
II.
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Fmt 4703
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the sole stockholder, deems appropriate,
consistent with the compositional
requirements of the BSE By-Laws.67 As
soon as practicable after election of the
initial BSE Board, BSE would hold its
annual meeting for the purpose of
electing directors in accordance with
the procedures set forth in the BSE ByLaws.68 For subsequent boards, BSE
Directors, other than the Member
Representative Directors and the BOX
Participant Director,69 would be
nominated by a Nominating Committee
appointed by the BSE Board 70 and then
elected by NASDAQ OMX as sole
stockholder.71
The BSE Board also would appoint a
Member Nominating Committee
composed of no fewer than three and no
more than six members.72 All members
of the Member Nominating Committee
would be associated persons of a current
BSE member. The BSE Board would
appoint such individuals after
appropriate consultation with
representatives of BSE members. The
Member Nominating Committee would
nominate candidates for the Member
Representative Director positions to be
filled. The candidates nominated by the
Member Nominating Committee would
be included on a formal list of
candidates (‘‘List of Candidates’’).
BSE members may nominate
additional candidates for inclusion on
the List of Candidates by submitting,
within the prescribed timeframe that is
based on the preceding year’s voting
date (‘‘Voting Date’’),73 a timely written
67 See Section 4.3(b), BSE By-Laws. See also BSE
Governance Proposal Notice, supra note 3, 73 FR
at 26162.
68 Id. Specifically, in accordance with Section
14.4(b) of the BSE By-Laws, the initial BSE Board
selected by NASDAQ OMX would appoint a
Nominating Committee and Member Nominating
Committee, and such committees would nominate
candidates for election pursuant to the procedures
set forth in Section 4.4 of the BSE By-Laws, which
process is described below. Telephone conversation
between John Yetter, Vice President and Deputy
General Counsel, Nasdaq, and Nancy Burke-Sanow,
Assistant Director, and Jennifer Dodd, Special
Counsel, Division of Trading and Markets,
Commission, on June 11, 2008. In Amendment No.
1 to the BSE Governance Proposal, BSE states that
the initial BSE Board will populate the Committees
of the BSE Board and BSE’s standing committees in
accordance with the compositional requirements of
Sections 4.13 and 4.14 of the BSE By-Laws. See
Amendment No. 1 to the BSE Governance Proposal,
supra note 4. The Commission notes that this
would include the initial Nominating Committee
and Member Nominating Committee. See Section
4.14(b), BSE By-Laws.
69 See infra notes 207–216 and accompanying text
for a description of the nomination and election
process for the BOX Participant Director who would
serve on the BSE Board.
70 See Section 4.14(b), BSE By-Laws.
71 See Section 4.4(a), BSE By-Laws.
72 See Section 4.14, BSE By-Laws.
73 The Voting Date is a date selected by the BSE
Board for BSE members to vote with respect to
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petition executed by the authorized
representatives of 10% or more of all
BSE members. If there is only one
candidate for each Member
Representative Director seat by the date
on which a BSE member may no longer
submit a timely nomination, the
Member Representative Directors would
be elected by NASDAQ OMX directly
from the List of Candidates nominated
by the Member Nominating Committee.
If the number of candidates on the List
of Candidates exceeds the number of
Member Representative Director
positions to be filled, there would be a
Contested Vote,74 in which case each
BSE member would have the right to
cast one vote for each Member
Representative Director position to be
filled.75 The persons on the List of
Member Representative Directors in the event there
is more than one candidate for a Member
Representative Director position (‘‘Contested
Vote’’). As described below, the BSE Board would
select a Voting Date each year. However, a vote
would be conducted on the Voting Date only in the
event of Contested Vote. See BSE Governance
Proposal Notice, supra note 3, 73 FR at 26161, n.11.
In Amendment No. 1 to the BSE Governance
Proposal, BSE states that: ‘‘In order to make the
intent of this definition clearer, immediately
following the closing of the [BSE Acquisition],
[BSE] will propose to the newly constituted Board
of the Exchange an amendment to the definition to
read as follows: ‘‘ ‘Voting Date’ means the date
selected by the Board on an annual basis, on which
[BSE members] may vote with respect to Member
Representative Directors in the event of a Contested
Vote.’’ Following approval by the [BSE] Board,
[BSE] will immediately file the amendment as a
proposed rule change for approval by the
Commission. This clarifying change could not be
included in this filing because Article XX of [BSE’s]
current Constitution, which is being replaced by the
proposed [BSE] By-Laws, provides that [BSE’s]
members must approve amendments to the [BSE]
Constitution. The [BSE] members voted, on
December 4, 2007, to approve the [BSE] By-Laws as
submitted in this filing and it would have been
impracticable and unduly expensive to seek a
second member vote for approval of this clarifying
change. Following adoption of the new By-Laws,
the [BSE] Board will have authority to approve ByLaw amendments.’’ See Amendment No. 1 to the
BSE Governance Proposal, supra note 4.
Also, in the case of the first annual meeting held
pursuant to the new BSE By-Laws, a nomination for
the Member Representative Director positions
would be considered timely if delivered not earlier
than the close of business on the later of the 120th
day prior to the first Voting Date and not later than
the close of business on the 90th day prior to the
first Voting Date, or the 10th day following the day
on which public announcement of such Voting Date
is first made. See BSE Governance Proposal Notice,
supra note 3, 73 FR at 26161, n.12. See also Section
4.4(d), BSE By-Laws.
74 See Section 1(k), BSE By-Laws.
75 In Amendment No. 1 to the BSE Governance
Proposal, BSE states that: ‘‘In order to limit the
influence that a single affiliated group of members
might exercise over [BSE], immediately following
the closing of the [BSE Acquisition], [BSE] will
propose to the newly constituted [BSE Board] an
amendment to stipulate that no [BSE member],
either alone or together with its affiliates, may
account for more than 20% of the votes cast for a
candidate, and any votes cast by such [BSE
member], either alone or together with its affiliates,
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Candidates who receive the most votes
would be submitted to NASDAQ OMX
for election,76 and NASDAQ OMX
would elect those candidates.77
The Commission finds that the
proposed changes regarding the
composition of the BSE Board are
consistent with the Act, including
Section 6(b)(1) of the Act,78 which
requires, among other things, that a
national securities exchange be
organized to carry out the purposes of
the Act and comply with the
requirements of the Act. The
Commission previously has stated its
belief that the inclusion of public, nonindustry representatives on exchange
oversight bodies is critical to an
exchange’s ability to protect the public
interest.79 Further, public
representatives help to ensure that no
single group of market participants has
the ability to systematically
disadvantage other market participants
through the exchange governance
process. The Commission believes that
public directors can provide unique,
unbiased perspectives, which should
enhance the ability of the BSE Board to
address issues in a non-discriminatory
fashion and foster the integrity of BSE.
The Commission also finds that the
composition of the BSE Board satisfies
Section 6(b)(3) of the Act,80 which
requires that one or more directors be
representative of issuers and investors
and not be associated with a member of
the exchange or with a broker or dealer.
The fair representation requirement in
Section 6(b)(3) of the Act is intended to
give members a voice in the selection of
in excess of such 20% limitation shall be
disregarded. Following approval by the [BSE]
Board, [BSE] will immediately file the amendment
as a proposed rule change for approval by the
Commission. This clarifying change could not be
included in this filing because Article XX of [BSE’s]
current Constitution, which is being replaced by the
proposed [BSE] By-Laws, provides that [BSE’s]
members must approve amendments to the
Constitution. The members voted, on December 4,
2007, to approve the By-Laws as submitted in this
filing and it would have been impracticable and
unduly expensive to seek a second member vote for
approval of this clarifying change. Following
adoption of the new [BSE] By-Laws, the [BSE]
Board will have authority to approve [BSE] By-Law
amendments.’’ See Amendment No. 1 to the BSE
Governance Proposal, supra note 4.
76 See Section 4.4(f), BSE By-Laws.
77 See Section 4.4(b), BSE By-Laws.
78 15 U.S.C. 78f(b)(1).
79 See Regulation of Exchanges and Alternative
Trading Systems, Securities Exchange Act Release
No. 40760 (December 8, 1998), 63 FR 70844
(December 22, 1998). See also Securities Exchange
Act Release Nos. 53382, supra note 29, 71 FR at
11261 n.121 and accompanying text; 53128, supra
note 63, 71 FR at 3553, n.54 and accompanying text;
and 44442 (June 18, 2001), 66 FR 33733, n.13 and
accompanying text, (June 25, 2001) (SR–PCX–01–
03).
80 15 U.S.C. 78f(b)(3).
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46941
the exchange’s directors and the
administration of its affairs. The
Commission finds that the requirement
under BSE By-Laws that at least 20% of
the BSE Directors represent members,81
and the process for selecting Member
Representative Directors, are designed
to ensure the fair representation of BSE
members on the BSE Board. The
Commission believes that the method
for selecting Member Representative
Directors on the BSE Board allows
members to have a voice in BSE’s use
of its self-regulatory authority.82 In
particular, the Commission notes that
the Member Nominating Committee is
composed solely of persons associated
with BSE members and is selected after
consultation with representatives of BSE
members. In addition, the BSE By-Laws
include a process by which members
can directly petition and vote for
representation on the BSE Board. The
Commission therefore finds that the
process for selecting Member
Representative Directors to the BSE
Board is consistent with Section 6(b)(3)
of the Act.83 The Commission also notes
that these provisions are consistent with
previous proposals approved by the
Commission.84
4. Committees
The proposed new BSE By-Laws
would include provisions governing the
composition and authority of various
BSE committees established by the BSE
Board.85 The BSE By-Laws would
establish several standing BSE Board
committees that are composed solely of
BSE Directors and would delineate their
general duties and compositional
requirements.86 These committees are
the Executive Committee, the Finance
Committee, the Management
Compensation Committee, the Audit
Committee, and the Regulatory
Oversight Committee (‘‘BSE ROC’’). In
addition to these committees, the BSE
By-Laws provide for the appointment by
the BSE Board of certain standing
committees, not composed solely of BSE
Directors, to administer various
provisions of the rules that BSE expects
to propose with respect to governance,
81 See
Section 4.3(a), BSE By-Laws.
addition, the BSE By-Laws provide that one
BSE Director would represent BOX Participants.
See infra notes 207–216 and accompanying text for
a description of the nomination and election
process for the BOX Participant Director who would
serve on the BSE Board.
83 15 U.S.C. 78f(b)(3).
84 See, e.g., Securities Exchange Act Release Nos.
58179, supra note 27; 53128, supra note 63; and
49098 (January 16, 2004), 69 FR 3974 (January 27,
2004) (order approving the demutualization of
Phlx).
85 See Sections 4.12–4.14, BSE By-Laws.
86 See Section 4.13, BSE By-Laws.
82 In
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listing, equity trading, and member
discipline.87 These committees include
the Member Nominating Committee, the
Nominating Committee, the BSE Listing
and Hearings Review Council, the BSE
Review Council, the Quality of Markets
Committee, the Market Operations
Review Committee, the Arbitration and
Mediation Committee, and the Market
Regulation Committee.
As noted above, all members of the
Member Nominating Committee must be
associated persons of a BSE member. In
addition, at least 20% of the members
of the BSE Listing and Hearings Review
Council, the BSE Review Council, the
Quality of Markets Committee, and the
Market Operations Review Committee
must be composed of Member
Representatives. Moreover, the
Nominating Committee, the BSE Review
Council, the Quality of Markets
Committee, the Arbitration and
Mediation Committee, and the Market
Regulation Committee must be
compositionally balanced between
Industry members 88 and Non-Industry
members.89 These compositional
requirements are designed to ensure that
members are protected from unfair,
unfettered actions by an exchange
pursuant to its rules, and that, in
general, an exchange is administered in
a way that is equitable to all those who
trade on its market or through its
facilities. The Commission believes that
the proposed compositional balance of
these BSE committees is consistent with
the Section 6(b)(3) of the Act because it
provides for the fair representation of
BSE members in the administration of
the affairs of BSE.90
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5. Regulatory Oversight Responsibilities
and Regulatory Funds
The BSE By-Laws would provide that
the BSE Board, when evaluating any
proposal, would, to the fullest extent
permitted by applicable law, take into
account: (i) the potential impact thereof
on the integrity, continuity, and stability
of BSE and the other operations of BSE,
on the ability to prevent fraudulent and
manipulative acts and practices and on
investors and the public, and (ii)
whether such would promote just and
equitable principles of trade, foster
cooperation and coordination with
persons engaged in regulating, clearing,
settling, processing information with
respect to and facilitating transactions
in securities, or assist in the removal of
87 See Section 4.14 and Articles VI–VII, BSE ByLaws.
88 See Article I(u), BSE By-Laws.
89 See Article I(cc), BSE By-Laws.
90 See, e.g., Securities Exchange Act Release Nos.
58179, supra note 27; 53128, supra note 63; and
49098, supra note 84.
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impediments to or perfection of the
mechanisms for a free and open market
and a national market system.91 Taken
together, these provisions reinforce the
notion that BSE, while wholly-owned
by NASDAQ OMX, is not solely a
commercial enterprise, but rather is an
SRO registered pursuant to the Act and
subject to the obligations imposed by
the Act.
The BSE ROC would be composed of
Public Directors, each of whom also
would need to qualify as an
independent director pursuant to
Nasdaq Rule 4200.92 The BSE ROC
would be responsible for monitoring the
adequacy and effectiveness of BSE’s
regulatory program and assisting the
BSE Board in reviewing BSE’s
regulatory plan and the overall
effectiveness of BSE’s regulatory
functions.93 BSE also would have a
Chief Regulatory Officer (‘‘BSE CRO’’)
who would have general supervision of
the BSE’s regulatory operations,
including responsibility for overseeing
BSE’s surveillance, examination, and
enforcement functions and for
administering any regulatory services
agreements with another SRO to which
BSE is a party.94 The BSE CRO would
have to meet with the BSE ROC in
executive session at regularly scheduled
meetings of such committee and at any
time upon request of the BSE CRO or
any member of the BSE ROC. The BSE
CRO could also serve as the General
Counsel of BSE.95
In addition, the BSE By-Laws would
contain a stipulation that dividends
could not be paid to the stockholders
using regulatory funds, which are fees,
fines, or penalties derived from the
regulatory operations of BSE.96 This
restriction on the use of regulatory
funds is intended to preclude BSE from
using its authority to raise regulatory
funds for the purpose of benefiting its
shareholders, or for other non-regulatory
purposes, such as executive
compensation. Regulatory funds,
however, would not be construed to
include revenues derived from listing
fees, market data revenues, transaction
revenues, or any other aspect of the
commercial operations of BSE, even if a
portion of such revenues are used to pay
91 See
92 See
Section 4.9, BSE By-Laws.
Section 4.13(e), BSE By-Laws.
93 Id.
94 See
Section 5.10, BSE By-Laws.
The Commission has previously approved a
similar structure. See Nasdaq Exchange Approval
Order, supra note 63, 71 FR at 3555, n.103 and
accompanying text (order approving application of
Nasdaq for registration as a national securities
exchange, including the ability of the CRO to serve
as General Counsel).
96 See Section 9.8, BSE By-Laws. See also Section
1(ii), BSE By-Laws.
95 Id.
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costs associated with the regulatory
operations of BSE.97
Section 6(b)(1) of the Act 98 requires
an exchange to be so organized and have
the capacity to be able to carry out the
purposes of the Act. The Commission
believes that BSE’s regulatory structure
is designed to insulate its regulatory
functions from its market and other
commercial interests so that it can carry
out its regulatory obligations and,
therefore, BSE’s proposal is consistent
with the Act.
6. Restrictions on Affiliation Between
BSE and Its Members: Proposed BSE
Chapter XXXIX
a. Limitations on BSE Members’
Ownership of NASDAQ OMX
In connection with the transaction, in
the BSE Governance Proposal, BSE
proposes to add a new Chapter XXXIX,
Section 1 to the BSE Rules to prohibit
BSE members and persons associated
with BSE members from beneficially
owning more than 20% of the thenoutstanding voting securities of
NASDAQ OMX. Members that trade on
an exchange traditionally have had
ownership interests in such exchange.
As the Commission has noted in the
past, however, 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.99 A member that is a
controlling shareholder of an exchange
or an exchange’s holding company
might be tempted to exercise that
controlling influence by pressuring or
directing the exchange to refrain from,
or the exchange otherwise 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.
In addition, the NASDAQ OMX
Certificate imposes limits on direct and
97 The Commission further notes that the BSX
Operating Agreement is being amended to adopt a
restriction on distributions of regulatory funds
comparable to the restriction proposed for inclusion
in the BSE By-Laws. See proposed Section 9.2, BSX
Operating Agreement.
98 15 U.S.C. 78f(b)(1).
99 See, e.g., Securities Exchange Act Release Nos.
57478 (March 12, 2008), 73 FR 14521, 14523 (March
18, 2008) (SR–NASDAQ–2007–004 and SR–
NASDAQ–2007–080) (‘‘NOM Approval Order’’);
55389, supra note 33, 72 FR at 10578; 55293
(February 14, 2007), 72 FR 8033, 8037 (February 22,
2007) (SR–NYSE–2006–120); 53382, supra note 29,
71 FR at 11256; 51149 (February 8, 2005), 70 FR
7531, 7538 (February 14, 2005) (SR–CHX–2004–26);
49718 (May 17, 2004), 69 FR 29611, 29624 (May 24,
2004) (SR–PCX–2004–08); 49098, supra note 84, 69
FR at 3986; 49067 (January 13, 2004), 69 FR 2761,
2767 (January 20, 2004) (SR–BSE–2003–19) (‘‘BOX
LLC Agreement Order’’); and Nasdaq Exchange
Approval Order, supra note 63, 71 FR at 3552.
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indirect changes in control, which are
designed to prevent any shareholder
from exercising undue control over the
operation of its SRO subsidiaries and to
ensure that its SRO subsidiaries 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 of NASDAQ OMX in
excess of 5% of the securities generally
entitled to vote may vote shares in
excess of 5%.100 This limitation would
mitigate the potential for any NASDAQ
OMX shareholder to exercise undue
control over the operations of the BSE
and facilitate BSE’s and the
Commission’s ability to carry out their
regulatory obligations under the Act.
The NASDAQ OMX Board may
approve exemptions from the 5% voting
limitation for any person that is not a
broker-dealer, an affiliate of a brokerdealer, or a person subject to a statutory
disqualification under Section 3(a)(39)
of the Act,101 provided that the
NASDAQ OMX Board also determines
that granting such exemption would be
consistent with the self-regulatory
obligations of Nasdaq.102 Further, any
such exemption from the 5% voting
limitation would not be effective until
approved by the Commission pursuant
to Section 19 of the Act.103 The BSE
Governance Proposal reflects an
amendment to the NASDAQ OMX ByLaws to require the NASDAQ OMX
Board, prior to approving any
exemption from the 5% voting
limitation, to determine that granting
such exemptions would also be
consistent with BSE’s self-regulatory
obligations.104
The Commission finds that the
ownership restriction in proposed
Chapter XXXIX, Section 1 of the BSE
Rules, combined with the voting
limitations in Article Fourth.C of
Section 12.5 of the NASDAQ OMX
Certificate and the NASDAQ OMX ByLaws, is consistent with the Act,
including Sections 6(b)(1) and 6(b)(5) of
the Act. These limitations should
reduce the potential for a BSE member
to improperly interfere with or restrict
the ability of the Commission or BSE to
effectively carry out their respective
regulatory oversight responsibilities
under the Act.
100 See Article Fourth.C., NASDAQ OMX
Certificate.
101 15 U.S.C. 78c(a)(39). See Article Fourth.C.6.,
NASDAQ OMX Certificate.
102 Specifically, the NASDAQ OMX Board must
determine that granting such exemption would (1)
not reasonably be expected to diminish the quality
of, or public confidence in, NASDAQ OMX or
Nasdaq or the other operations of NASDAQ OMX
and its subsidiaries, on the ability to prevent
fraudulent and manipulative acts and practices on
investors and the public, and (2) promote just and
equitable principles of trade, foster cooperation and
coordination with persons engaged in regulating,
clearing, settling, processing information with
respect to and facilitating transactions in securities
or assist in the removal of impediments to or
perfection of the mechanisms for a free and open
market and a national market system. See Article
Fourth.C.6, NASDAQ OMX Certificate.
103 See Section 12.5, NASDAQ OMX By-Laws.
104 See Amendment No. 1 to the BSE Governance
Proposal, supra note 4. Specifically, the NASDAQ
OMX Board must determine that granting such
exemption would (1) not reasonably be expected to
diminish the quality of, or public confidence in,
NASDAQ OMX or its SRO Subsidiaries or the other
operations of NASDAQ OMX and its subsidiaries,
on the ability to prevent fraudulent and
manipulative acts and practices on investors and
the public, and (2) promote just and equitable
principles of trade, foster cooperation and
coordination with persons engaged in regulating,
clearing, settling, processing information with
respect to and facilitating transactions in securities
or assist in the removal of impediments to or
perfection of the mechanisms for a free and open
market and a national market system. See proposed
Section 12.5, NASDAQ OMX By-Laws.
105 Proposed BSE Rule, Chapter XXXIX, Section
2. BSE defines ‘‘business venture’’ as an
arrangement under which (1) BSE or an entity with
which it is affiliated and (2) a BSE member or an
affiliate of a BSE member, engage in joint activities
with the expectation of shared profit and a risk of
shared loss from common entrepreneurial efforts.
106 Id. In connection with the Phlx Acquisition,
Phlx proposed, and the Commission approved, a
similar rule. See Phlx Rule 985(b) and Securities
Exchange Act Release No. 58179, supra note 27, 73
FR at 42886–42887.
107 Id. BSE defines ‘‘affiliate’’ as having the
meaning specified in Rule 12b–2 under the Act, 17
CFR 240.12b–2, provided, however, that one entity
would not be deemed to be an affiliate of another
entity solely by reason of having a common
director. Id.
108 15 U.S.C. 78s(b).
109 Proposed BSE Rule, Chapter XXXIX, Section
1.
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b. Limitations on Affiliation Between
BSE and Its Members
BSE also proposes to prohibit BSE or
an entity with which it is affiliated from
acquiring or maintaining an ownership
interest in, or engaging in a business
venture 105 with, a BSE member or an
affiliate of a BSE member in the absence
of an effective filing with the
Commission under Section 19(b) of the
Act.106 Further, the proposed rule
would prohibit a BSE member from
becoming an affiliate 107 of BSE or an
affiliate of an entity affiliated with BSE
in the absence of an effective filing
under Section 19(b) of the Act.108
However, the proposed rule would
exclude from this restriction two types
of affiliations.
First, a BSE member or an affiliate of
a BSE member could acquire or hold an
equity interest in NASDAQ OMX that is
permitted pursuant to proposed BSE
Rules 109 (i.e., less than 20% of the
outstanding voting securities) without
the need for BSE to file such acquisition
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46943
or holding under Section 19(b) of the
Act.110 Second, BSE or an entity
affiliated with BSE could acquire or
maintain an ownership interest in, or
engage in a business venture with, an
affiliate of a BSE member without filing
a proposed rule change relating to such
affiliation under Section 19(b) of the
Act, if there were information barriers
between the BSE member and BSE and
its facilities. These information barriers
would have to prevent the member from
having an ‘‘informational advantage’’
concerning the operation of BSE or its
facilities or ‘‘knowledge in advance of
other [BSE] members’’ of any proposed
changes to the operations of BSE or its
trading systems. Further, BSE may only
notify an affiliated member of any
proposed changes to its operations or
trading systems in the same manner as
it notifies non-affiliated members. BSE
and its affiliated member may not share
employees, office space, or data
bases.111 Finally, the BSE ROC must
certify annually that BSE has taken all
reasonable steps to implement and
comply with the rule.112
Proposed BSE Rules Chapter XXXIX
is consistent with rules of Nasdaq,
which the Commission previously
found consistent with the Act.113 The
Commission similarly finds that
proposed Chapter XXXIX to the BSE
Rules is consistent with the
requirements of Section 6(b)(5) of the
Act,114 which requires that an exchange
have rules designed, among other
things, to promote just and equitable
principles of trade, to remove
impediments and to perfect the
mechanism of a free and open market
and a national market system, and in
general, to protect investors and the
public interest.115
The Commission is concerned about
the potential for unfair competition and
110 Id. As discussed above, the proposed BSE
Rules would provide that ‘‘[n]o member or person
associated with a member shall be the beneficial
owner of greater than twenty percent (20%) of the
then-outstanding voting securities of [NASDAQ
OMX].’’
111 Proposed BSE Rule, Chapter XXXIX, Section
2(b)(2)(A).
112 Proposed BSE Rule, Chapter XXXIX, Section
2(b)(2)(B).
113 See Nasdaq Rules 2130 and 2140. See also
Nasdaq Exchange Approval Order, supra note 63,
71 FR at 3552, n. 41 and accompanying text, and
Securities Exchange Act Release No. 54170 (July 18,
2006), 71 FR 42149 (July 25, 2006) (SR–NASDAQ–
2006–006) (order approving Nasdaq’s proposal to
adopt Nasdaq Rule 2140, restricting affiliations
between Nasdaq and its members). Also, in
connection with the Phlx Acquisition, Phlx
proposed, and the Commission approved, similar
rules. See Phlx Rule 985(a) and (b) and Securities
Exchange Act Release No. 58179, supra note 27, 73
FR at 42886–42887.
114 15 U.S.C. 78f(b)(5).
115 Id.
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conflicts of interest between an
exchange’s self-regulatory obligations
and its commercial interests that could
exist if an exchange were to otherwise
become affiliated with one of its
members, as well as the potential for
unfair competitive advantage that the
affiliated member could have by virtue
of informational or operational
advantages, or the ability to receive
preferential treatment.116 The
Commission believes that the proposed
additions to the BSE Rules are designed
to mitigate these concerns by requiring
that BSE file a proposed rule change in
connection with proposed affiliations
between BSE and its members, unless
such affiliation is due to a member’s
interest in NASDAQ OMX that is
permitted under proposed Chapter
XXXIX, Section 1 of the BSE Rules or
conforms to the specified information
barrier requirements.
If BSE entered into an affiliation with
a BSE member (or any other party) that
resulted in a change to a BSE Rule or the
need to establish new BSE Rules, as
defined under the Act, then such
affiliation would be subject to the rule
filing requirements of Section 19(b) of
the Act and Rule 19b–4 thereunder.
7. Exceptions to Limitations on
Affiliation Between BSE and Its
Members
sroberts on PROD1PC70 with NOTICES
NASDAQ OMX currently owns two
broker-dealers: (1) NASDAQ Execution
Services, LLC (‘‘NES’’), and (2)
NASDAQ Options Services, LLC
(‘‘NOS’’). NES and NOS are members of
BSE. Absent relief, after the closing of
NASDAQ OMX’s acquisition of BSE,
NASDAQ OMX’s ownership of NES and
NOS would cause NES and NOS to
violate the provision in proposed BSE
Rules Chapter XXXIX, Section 2
prohibiting BSE members from being
affiliated with BSE.
BSE has proposed, in the BSE
Governance Proposal, that NES and
NOS be permitted to become affiliates of
BSE, subject to certain conditions and
limitations. First, BSE proposes that
NES and NOS would only route orders
to BSE that first attempt to access
liquidity on Nasdaq.117 Second, NES
116 See Securities Exchange Act Release No.
53382, supra note 29. See also Securities Exchange
Act Release No. 54170, supra note 113.
117 NES currently provides to Nasdaq members
optional routing services to other market centers,
including BSE, as set forth in Nasdaq’s rules. See
Nasdaq Rules 4751, 4755, and 4758. NES does not
currently route to BSE because BSE currently does
not trade equity securities. See infra note 222. NOS
provides to Nasdaq members that are Nasdaq
Options Market (‘‘NOM’’) participants routing
services to other market centers. Pursuant to
Nasdaq’s rules, NOS: (1) routes orders in options
currently trading on NOM, referred to as ‘‘System
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and NOS would remain facilities of
Nasdaq. Under Nasdaq Rules, NES
operates as a facility 118 of Nasdaq and
routes orders to other market centers as
directed by Nasdaq. Similarly, NOS is
operated and regulated as a facility of
Nasdaq with respect to its routing of
System Securities (‘‘NOS facility
function’’), and, consequently, the
operation of NOS in this capacity would
be subject to BSE oversight, as well as
Commission oversight.119 Nasdaq is
responsible for ensuring that NES and
NOS are operated consistent with
Section 6 of the Act and Nasdaq’s Rules.
In addition, Nasdaq must file with the
Commission rule changes and fees
relating to NES and NOS. Third, use of
NES’s and NOS’s routing function by
Nasdaq members would continue to be
optional. Parties that do not desire to
use NES may enter orders into Nasdaq
as immediate-or-cancel orders or any
other order-type available through
Nasdaq that are ineligible for routing.120
Similarly, NOM participants are not
required to use NOS to route orders, and
a NOM participant may route its orders
through any available router it
selects.121 In addition, the Commission
notes that NES and NOS are members of
an SRO unaffiliated with Nasdaq, which
serves as their designated examining
authority under Rule 17d–1.122
In the past, the Commission has
expressed concern that the affiliation of
an exchange with one of its members
raises potential conflicts of interest, and
the potential for unfair competitive
advantage.123 Although the Commission
Securities;’’ and (2) routes orders in options that are
not currently trading on NOM (‘‘Non-System
Securities’’). See NOM Rules, Chapter VI Sections
1(b) and 11. See also NOM Approval Order, supra
note 99. With respect to System Securities, NOM
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. See
NOM Rules, Chapter VI, Section 11. See also NOM
Approval Order, supra note 99, 73 FR at 14532–
14533.
118 See Nasdaq Rule 4758(b)(3). See also
Securities Exchange Act Release No. 56708 (October
26, 2007), 72 FR 61925 (November 1, 2007) (SR–
NASDAQ–2007–078) (‘‘NES Routing Release’’). As
a facility of Nasdaq, Nasdaq Rule 4758(b)
acknowledges that Nasdaq is responsible for filing
with the Commission rule changes related to the
operation of, and fees for services provided by, NES
and that NES is subject to exchange nondiscrimination requirements.
119 See NOM Rules, Chapter 11(e). See also NOM
Approval Order, supra note 99, 73 FR at 14533.
120 See Nasdaq Rule 4758(b)(7).
121 See NOM Rules, Chapter VI, Section 11(a)
(allowing Participants to designate orders as
available for routing or not available for routing).
See also NOM Approval Order, supra note 99, 73
FR at 14533, n.91 and accompanying text.
122 See Nasdaq Rule 4758(b)(4), and NOM Rules,
Chapter 11(e). See also NES Routing Release, supra
note 118; and NOM Approval Order, supra note 99,
73 FR at 14533, n.189 and accompanying text.
123 See supra note 116 and accompanying text.
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continues to be concerned about
potential unfair competition and
conflict of interest between an
exchange’s self-regulatory obligations
and its commercial interest when the
exchange is affiliated with one of its
members, the Commission believes that
it is appropriate and consistent with the
Act to permit NES and NOS to become
affiliates of BSE for the limited purpose
of providing routing services for Nasdaq
for orders that first attempt to access
liquidity on Nasdaq’s systems before
routing to BSE, and in light of the
protections afforded by the other
conditions described above.
B. BOX
1. BSE Transfer of BOX Interest
The BOX Market is a facility of
BSE.124 BOXR is BSE’s wholly-owned
subsidiary,125 to which BSE has
delegated, pursuant to a delegation plan
(‘‘Delegation Plan’’),126 certain selfregulatory responsibilities related to the
BOX Market (BSE together with BOXR
with respect to the BOX Market,
‘‘Regulatory Authority’’).127
In the BOX Transfer Proposal, BSE
proposes to transfer its 21.87%
ownership interest in BOX to MX US.
Following this transfer, BSE no longer
would have any ownership interest in
BOX and MX US would have a 53.24%
ownership interest.128 Because BSE
would no longer have an ownership
interest, it no longer would be admitted
and named as a BOX Member.129 The
proposed changes to the BOX LLC
Agreement reflect this change. However,
124 See Securities Exchange Act Release Nos.
49066 (January 13, 2004), 69 FR 2773 (January 20,
2004) (SR–BSE–2003–17); 49065 (January 13, 2004),
69 FR 2768 (January 20, 2004) (SR–BSE–2003–04)
(‘‘BOXR Order’’); 49068 (January 13, 2004), 69 FR
2775 (January 20, 2004) (SR–BSE–2002–15); and
BOX LLC Agreement Order, supra note 99. Section
3(a)(2) of the Act states that ‘‘[t]he term ‘facility’
when used 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
U.S.C. 78c(a)(2).
125 See BOXR Order, supra note 124.
126 See BSE Rules, Chapter XXXVI. See also
BOXR Order, supra note 124.
127 See Section 1.1, 6th BOX LLC Agreement.
128 MX US currently has a 31.37% ownership
interest in BOX. See Securities Exchange Act
Release No. 57260 (February 1, 2008), 73 FR 7617
(February 8, 2008) (SR–BSE–2008–06).
129 ‘‘BOX Member’’ means a person admitted and
named as a member on schedules to the 5th BOX
LLC Agreement and any person admitted to BOX
as an additional or substitute member of BOX, in
such person’s capacity as a member of BOX. See
Section 1.1, 5th BOX LLC Agreement.
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pursuant to the revised BOX LLC
Agreement, the BOX Market would
remain a facility of BSE, and BSE would
remain the SRO for the BOX Market.130
BSE, together with BOXR, would retain
regulatory control over the BOX Market
and BSE, as the SRO, would remain
responsible for ensuring compliance
with the federal securities laws and all
applicable rules and regulations.131
Section 8.4(f) of the current BOX LLC
Agreement requires that any transfer
that results in the acquisition and
holding by any person, alone or together
with any affiliate of such person, of an
aggregate percentage interest which
meets or crosses the threshold of 20%
or any successive 5% be subject to a
rule filing pursuant to Section
19(b)(1).132 Section 8.4(f) also requires
that any transfer that reduces BSE’s
aggregate ownership interest in BOX
below the 20% threshold be subject to
a rule filing.133 BSE has filed the
proposed transfer of its interest in BOX
to MX US in accordance with these
provisions of the BOX LLC Agreement.
The Commission believes that BSE’s
transfer of its 21.87% interest in BOX to
MX US is consistent with the Act. MX
US is currently a BOX Member and
therefore is bound by all the provisions
of the current BOX LLC Agreement 134
and would similarly be bound by the
provisions of the revised BOX LLC
Agreement.135 Further, although BSE no
sroberts on PROD1PC70 with NOTICES
130 See
Section 3.2(a)(i), 6th BOX LLC Agreement
(‘‘BSE will provide SEC-approved SRO status for
the BOX Market, the Regulatory Authority will
provide the regulatory framework for the BOX
Market and the Regulatory Authority, together with
BOX, will have regulatory responsibility for the
activities of the BOX Market.’’). BSE also proposes
that the SRO for the BOX Market may be changed
by a vote of the BOX Board and the approval of the
Commission. See Section 1.1, 6th BOX LLC
Agreement.
131 See infra notes 144–164 and notes 185–199
and accompanying text.
132 See Section 8.4(f), 5th BOX LLC Agreement.
133 Id.
134 MX, a parent corporation of MX US, has
agreed to abide by all of the provisions of the 5th
BOX LLC Agreement, including those provisions
requiring submission to the jurisdiction of the
Commission. See Securities Exchange Act Release
No. 57713 (April 25, 2008), 73 FR 24327 (May 2,
2008) (SR–BSE–2008–28).
135 These provisions of the BOX LLC Agreement
provide that MX US would, among other things,
comply with the federal securities laws and the
rules and regulations thereunder; cooperate with
the Commission and the Regulatory Authority
pursuant to their regulatory authority and the
provisions of the revised BOX LLC Agreement; and
engage in conduct that fosters and does not interfere
with BOX’s ability to prevent fraudulent and
manipulative acts and practices; promote just and
equitable principles of trade; foster cooperation and
coordination with persons engaged in regulating,
clearing, settling, processing information with
respect to, and facilitating transactions in securities;
remove impediments to and perfect the mechanism
of a free and open market and a national market
system; and, in general protect investors and the
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longer would hold ownership interest in
BOX, BSE would remain the SRO for the
BOX Market. As the Commission has
noted in the past, ‘‘the Act does not
require that an SRO have any ownership
interest in the operator of one of its
facilities.’’ 136 Moreover, BOX is
obligated under the BOX LLC
Agreement to continue to operate the
BOX Market in a manner consistent
with the regulatory and oversight
responsibilities of BSE and with the Act
and rules and regulations thereunder.137
As discussed below, BSE will have veto
power over planned or proposed
changes to BOX or the BOX Market, and
if the Regulatory Authority, in its sole
discretion, determines that a planned or
proposed change to BOX or the BOX
Market is not consistent with Regulatory
Authority Rules or SEC Rules governing
the BOX Market or BOX Participants,
the Regulatory Authority could direct
BOX to modify the proposal.138
Moreover, the books, premises, officers,
directors, agents and employees of BOX
are deemed to be the books, premises,
officers, directors, agents and employees
of BSE.139 In addition, the Commission
has authority to inspect BOX’s books
and records because BOX is the operator
of the BOX Market, a facility of an
exchange. Accordingly, the Commission
believes that the transfer of BSE’s
ownership interest in BOX would not
public interest. See Section 5.3, 6th BOX LLC
Agreement. See also BOX LLC Agreement Order,
supra note 99, 69 FR at 2765.
136 In the BOX LLC Agreement Order, the
Commission approved the operating agreement
governing the BOX Market. At the time of the BOX
LLC Agreement Order, BSE did not hold the largest
ownership interest in BOX, but the Commission
noted that the Act does not require that an SRO
have any ownership interest in the operator of its
facility. See BOX LLC Agreement Order, supra note
99, 69 FR at 2764. See also Securities Exchange Act
Release No. 44983 (October 25, 2001), 66 FR 55225
(November 1, 2001) (‘‘ArcaEx Approval Order’’). In
the ArcaEx Approval Order, the Commission
approved the establishment of Archipelago
Exchange (‘‘ArcaEx’’) as a facility of the Pacific
Exchange, Inc. (‘‘PCX,’’ n/k/a NYSE Arca, Inc.).
ArcaEx was operated by the Archipelago Exchange,
L.L.C. (‘‘Arca L.L.C.’’). At the time of the ArcaEx
Approval Order, PCX’s ownership interest in Arca
L.L.C. consisted solely of a 10% interest in
Archipelago Holdings, LLC, the parent company of
Arca L.L.C. See also Securities Exchange Act
Release Nos. 41210 (March 24, 1999), 64 FR 15857
(April 1, 1999) (SR–Phlx–96–14) (order approving
electronic system offering VWAP that was operated
as a facility of Phlx, where Phlx had no ownership
interest in the operation of the system) and 54538
(September 29, 2006), 71 FR 59184 (October 6,
2006) (SR–Phlx–2006–43) (order approving Phlx’s
New Equity Trading system and operation of
optional outbound router as a facility of Phlx,
where Phlx had no ownership interest in the third
party operator).
137 See infra notes 144–164 and notes 185–199
and accompanying text.
138 See infra notes 147–164 and accompanying
text.
139 See infra note 187 and accompanying text.
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impair BSE’s or the Commission’s
ability to discharge their respective
regulatory and oversight
responsibilities, and is consistent with
the Act.
2. BSE Interim Certificate
BSE plans to distribute the net
proceeds from the transfer of its interest
in BOX to BSE member owners.140 To
effectuate this distribution, in the BSE
Interim Certificate Proposal, BSE
proposes to amend the BSE Certificate
to remove a provision that prevents BSE
from making distributions and to add a
provision that would allow BSE to
redeem a portion of each membership in
exchange for a pro rata share of the net
proceeds from its transfer of BSE’s
interest in BOX.141
The BSE Certificate as proposed to be
amended as just described is referred to
as the Interim Certificate and would be
effective immediately prior to the
transfer of BSE’s interest in BOX to MX
US.142 Immediately thereafter, this
Interim Certificate would be amended
and restated in its entirety in connection
with the BSE Acquisition.143
The Commission believes that the
Interim Certificate is consistent with the
Act. The sole purpose of the Interim
Certificate is to enable BSE to distribute
to BSE member owners the proceeds
from the transfer of BSE’s interest in
BOX to MX US. The Interim Certificate
would be in effect only until the BSE
Certificate is amended and restated in
its entirety, as discussed above, in
connection with the BSE Acquisition.
The Commission believes that allowing
such a distribution would not have any
adverse effect on the ability of BSE to
fulfill its regulatory obligations in
relation to the BOX Market, because
funding for the regulation of the BOX
Market would be established through a
regulatory services agreement between
BSE and BOX and not with the proceeds
from the transfer of BSE’s interest in
BOX to MX US.
3. BOX LLC Agreement
In conjunction with BSE’s divestiture
of BOX, BSE also proposes, in the BOX
Transfer Proposal, to amend the BOX
LLC Agreement to reflect BSE’s
140 All BSE members, including lessors but not
lessees, and excluding electronic access members,
would be entitled to receive their pro rata share of
equity interest in BOX based on the outstanding
number of such BSE memberships.
141 See Article Fourth, Interim Certificate. The
Interim Certificate also would delete obsolete text
regarding BSE incorporators.
142 See BSE Interim Certificate Proposal Notice,
supra note 7, 73 FR at 25810.
143 See BSE Governance Proposal Notice, supra
note 3, 73 FR 26159.
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continuing role as the SRO of its facility,
the BOX Market.
a. BSE as the SRO for the BOX Market
The BOX LLC Agreement provides
that as long as BSE maintains 8% or
greater interest in BOX, BSE would have
the right to designate and retain two
directors on the BOX board of directors
(‘‘BOX Board’’).144 BSE no longer would
be entitled to maintain two directors on
the BOX Board following its transfer of
interest to MX US. BSE, therefore,
proposes to amend the BOX LLC
Agreement to provide that as long as the
BOX Market remains a facility of BSE,
BSE would have the right to designate
and retain one non-voting director
(‘‘Regulatory Director’’) on the BOX
Board.145 The Regulatory Director
would have the right to attend all
meetings of the BOX Board and
committees thereof and receive notice of
meetings and copies of the meeting
materials provided to other BOX
directors.146
Under the current BOX LLC
Agreement, BSE holds veto power over
certain ‘‘Major Actions,’’ which relate to
both commercial and regulatory actions.
After the transfer of its ownership
interest to MX US, BSE, as the SRO for
the facility, would continue to have a
regulatory interest in the BOX Market.
In connection with the sale of BSE’s
ownership interest, the BOX LLC
Agreement is being amended to
eliminate BSE’s veto power over Major
Actions of BOX, but BSE would
continue to hold veto power over all
regulatory actions.
Specifically, BSE proposes to amend
the BOX LLC Agreement to provide that
BSE, with certain exceptions discussed
below,147 would have veto power over
planned or proposed changes to BOX or
the BOX Market.148 These amendments
to the BOX LLC Agreement would
provide that the Regulatory
Authority 149 would receive notice of
planned or proposed changes to BOX, or
the BOX Market pursuant to request for
change procedures established by the
mutual agreement of the Regulatory
144 See
Section 4.1(b), 5th BOX LLC Agreement.
Section 4.1(a)(i), 6th BOX LLC Agreement.
A Regulatory Director is a member of the senior
management of the regulation staff of the Regulatory
Authority, who is separated from the business
operations of BSE via effective information barriers
and is not an employee, officer, or director of
NASDAQ OMX or its affiliates, other than BSE and
BSE’s subsidiaries. See Section 1.1, 6th BOX LLC
Agreement.
146 See Section 4.2(d), 6th BOX LLC Agreement.
147 See infra note 159 and accompanying text.
148 See Section 3.2, 6th BOX LLC Agreement.
149 See supra text accompanying note 127.
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145 See
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Authority and BOX.150 Moreover, if
BSE, in its sole discretion, determines
that a Regulatory Deficiency exists, BSE
may direct BOX to undertake such
modifications as are necessary or
appropriate to eliminate the Regulatory
Deficiency.151 Prior to implementation,
the Regulatory Authority would be
required to affirmatively approve such
planned or proposed changes.152 If the
Regulatory Authority, in its sole
discretion, determines that a proposed
or planned change to BOX or the BOX
Market is not consistent with Regulatory
Authority Rules 153 or SEC Rules 154
governing the BOX Market or BOX
Participants, or impedes the Regulatory
Authority’s ability to regulate the BOX
Market or BOX Participants or to fulfill
its obligations under the Act,155 the
Regulatory Authority, again in its sole
discretion, could direct BOX to modify
the proposal such that it does not cause
a Regulatory Deficiency.156 BOX would
not implement the proposed change
until such change, and any required
modifications, are approved by the
BOXR board of directors (‘‘BOXR
Board’’).157 Further, in the event that the
Regulatory Authority, in its sole
discretion, determines that a Regulatory
Deficiency could exist or would result
from the change as planned, the
Regulatory Authority could direct BOX
to undertake such modifications to BOX
or the BOX Market as are necessary or
150 See Section 3.2(a)(ii), 6th BOX LLC
Agreement.
151 See Section 3.2(a)(iv), 6th BOX LLC
Agreement.
152 See Section 3.2(a)(ii), 6th BOX LLC
Agreement. The Regulatory Authority would also
receive notice of any planned or proposed change,
pursuant to which the BOX Market would cease to
be a facility of BSE. BOX would not be required,
however, to obtain consent from the Regulatory
Authority for any such planned or proposed
change, provided that the Commission has
approved such action. The BOX LLC Agreement
does not affect BSE’s obligations under Section 19
of the Act to file all proposed rule changes with the
Commission. Accordingly, if any proposed change
would be required to be filed as a proposed rule
change under the Act, BOX could not implement
such change until such change became effective
under the Act.
153 ‘‘Regulatory Authority Rules’’ means the rules
of the Regulatory Authority, including the BOX
Rules that constitute ‘‘rules of an exchange’’ within
the meaning of Section 3 of the Act and that pertain
to the BOX Market. See Section 1.1, 6th BOX LLC
Agreement.
154 ‘‘SEC Rules’’ mean the Act and such statutes,
rules, regulations, interpretations, releases, orders,
determinations, reports, or statements as are
administered, enforced, adopted or promulgated by
the Commission. See Section 1.1, 6th BOX LLC
Agreement.
155 The operation of BOX or the BOX Market in
such manner would be referred to as a ‘‘Regulatory
Deficiency.’’ See Section 1.1, 6th BOX LLC
Agreement.
156 See Section 3.2(a)(iii), 6th BOX LLC
Agreement.
157 Id.
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appropriate to eliminate or prevent the
Regulatory Deficiency and allow the
Regulatory Authority to perform and
fulfill its regulatory responsibilities
under the Act.158
Notice would not be required to be
provided to the Regulatory Authority if
a proposed change were a ‘‘Non-Market
Matter.’’ 159 Any planned or proposed
change to BOX that has a regulatory
component would not fall within the
definition of Non-Market Matters.160
The presence of a Regulatory
Director 161 on the BOX Board is
designed to help ensure that no matter
with a regulatory component is
considered a Non-Market Matter by
BOX.
These proposed changes to the BOX
LLC Agreement, which give the
Regulatory Authority notice of changes
and the authority to require
modification prior to implementation if
such changes would cause Regulatory
Deficiencies, are designed to replace the
current BOX LLC Agreement’s
provisions that state that, at all times
when BSE is a BOX Member, Major
Actions of BOX would not be effective
unless BSE-designated directors
affirmatively vote for such Major
Actions.162 Major Actions of BOX
include, among others, merger or
consolidation of BOX with any other
entity or the sale by BOX of any material
portion of its assets, entry by BOX into
any line of business other than the
business contemplated in the BOX LLC
Agreement, and making any
fundamental change in the market
structure of BOX.163 Following BSE’s
divestiture of BOX, however, BSE
would no longer have voting directors
on the BOX Board. BSE, therefore,
would be unable to affirmatively vote on
Major Actions of BOX.
The Commission believes that these
proposed changes are consistent with
the Act. The revised BOX LLC
Agreement reflects BSE’s continuing
status as the SRO for its facility, the
BOX Market, by providing that the
158 The cost of any such modifications must be
paid by BOX. See Section 3.2(a)(iv), 6th BOX LLC
Agreement.
159 Non-Market Matters include changes relating
solely to one or more of the following: marketing,
administrative matters, personnel matters, social or
team-building events, meetings of BOX Members,
communication with BOX Members, finance,
location, and timing of BOX Board meetings, market
research, real property, equipment, furnishings,
personal property, intellectual property, insurance,
contracts unrelated to the operation of the BOX
Market, and de minimis items. See Section
3.2(a)(ii), 6th BOX LLC Agreement.
160 See Section 3.2(a)(ii), 6th BOX LLC
Agreement.
161 See Section 4.1(a)(i), 6th BOX LLC Agreement.
162 See Section 4.4(b), 5th BOX LLC Agreement.
163 Id.
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Regulatory Authority would receive
notice of any planned or proposed
changes to BOX or the BOX Market,
which would include a wider range of
matters than those matters considered
Major Actions. Further, BOX would not
be able to implement a planned or
proposed change if the Regulatory
Authority, in its sole discretion,
determines that such change could
cause a Regulatory Deficiency. In
addition, if the Regulatory Authority
determines that a Regulatory Deficiency
exists or is planned, it may direct BOX
to undertake such modifications to BOX
or the BOX Market as are necessary or
appropriate to eliminate or prevent the
Regulatory Deficiency. As noted above,
the Commission has stated that the Act
does not require that an SRO have any
ownership interest in the operator of
one of its facilities.164 Although BSE
would not have an ownership interest in
BOX, the Commission believes that the
foregoing changes would not limit BSE’s
role as the SRO for the BOX Market. The
Commission, therefore, finds that these
proposed changes would allow BSE to
carry out its regulatory and oversight
responsibilities under the Act.
b. The BOX Committee
In the BOX Transfer Proposal, BSE
proposes to adopt resolutions
(‘‘Resolutions’’) to establish a committee
of the BSE Board, the BOX
Committee.165 The proposed
Resolutions are rules of an exchange
because they are stated policies,
practices, or interpretations (as defined
in Rule 19b–4 under the Act) of BSE,
and must therefore be filed with the
Commission pursuant to Section 19(b)
of the Act and Rule 19b–4 thereunder.
Accordingly, BSE filed the proposed
Resolutions with the Commission.166
Pursuant to the proposed Resolutions,
the BSE Board would delegate to the
BOX Committee all actions and
decisions relating to BSE rules that
govern the BOX Market, appeals from
regulatory decisions of the BOXR Board,
and, except to the extent otherwise
delegated to the BSE ROC, regulation of
the BOX Market.167 The proposed
Resolutions also would provide that the
BOX Committee include a director
164 See
supra note 136 and accompanying text.
Section 4.1(f), 6th BOX LLC Agreement.
166 See Exhibit 3B to the BOX Transfer Proposal
Notice.
167 The BSE ROC would be responsible for
monitoring the adequacy and effectiveness of BSE’s
regulatory program and assisting the BSE Board in
reviewing BSE’s regulatory plan and the overall
effectiveness of BSE’s regulatory function.
Regulatory actions and decisions delegated to the
BSE ROC are not subject to the power and authority
of the BOX Committee. See supra note 93 and
accompanying text.
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165 See
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representing the BOX Participants and
four other BSE Directors who do not
have a material direct or indirect
relationship with NASDAQ OMX, its
affiliates (other than service as directors
of BSE or BOXR), or any provider of
BOX-related regulatory functions
outsourced by BSE.168 Furthermore, the
proposed Resolutions would provide
that at least 50% of members of the BOX
Committee must be Public Directors.169
The proposed Resolutions also would
provide that any resolution or other
action that would have the effect of
dissolving the BOX Committee or
altering, amending, removing, or
abridging the Resolutions or the powers
of the BOX Committee established
thereby must be submitted to the BSE
Board, and if the same must be filed
with, or filed with and approved by, the
Commission under Section 19 of the
Act, then it would not be effective until
filed with, or filed with and approved
by, the Commission.170
Section 6(b)(3) of the Act provides
that the rules of an exchange must
assure that its members are fairly
represented in the selection of the
exchange’s directors and in the
administration of its affairs.171 This
requirement allows members to have a
voice in an exchange’s use of its selfregulatory authority. Moreover, the
Section 6(b)(3) requirement helps to
ensure that members are protected from
unfair, unfettered actions by an
exchange and that, in general, an
exchange is administered in a way that
is equitable to all those who trade on its
market or through its facilities. Because
under the proposed Resolutions, the
BSE Board would delegate to the BOX
Committee its actions and decisions
over the BOX Market, other than matters
delegated to the BSE ROC, the
Commission believes that the
composition of the BOX Committee
must be consistent with the fair
representation requirement under
Section 6(b)(3) of the Act.172 In this
regard, the proposed Resolutions would
require that one director of the five BSE
Directors on the BOX Committee
168 See proposed Resolutions. Material direct or
indirect relationship include, without limitation,
any of the following: being an affiliate; serving as
a board member, employee, officer, consultant,
advisor, or any provider of BOX-related regulatory
functions outsourced by BSE; being a party to any
contractual or other relationship pursuant to which
more than $50,000 is paid; reporting to, controlling,
being controlled by or holding an investment
greater than 5% in any such person; and being a
parent, child, sibling, spouse or in-law of such
person. See Section 4.1(f), 6th BOX LLC Agreement.
169 See proposed Resolutions. See also infra note
207 and accompanying text.
170 See proposed Resolutions.
171 15 U.S.C. 78f(b)(3).
172 15 U.S.C. 78f(b)(3).
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46947
represent BOX Participants. Because
20% of the BOX Committee would be
composed of directors who represent
BOX Participants, the Commission
believes that the proposed BOX
Committee composition satisfies the
Section 6(b)(3) requirement. The
Commission previously has found 20%
representation to satisfy the Section
6(b)(3) requirement.173
c. BSE and BOXR Boards
The BOXR By-Laws require that at
least 20% of the BOXR Board (but no
fewer than two directors) be composed
of directors representing BOX
Participants.174 In addition, the BOXR
By-Laws require that at least 50% of the
directors on the BOXR Board be public
directors (‘‘BOXR Public Directors’’).175
In the BSE Governance Proposal, BSE
proposes to revise this definition such
that a BOXR Public Director could not
also have any material business
relationship with an affiliate of BSE,
BOX, or BOXR.176 The Commission
finds this proposed change to be
consistent with the Act. This change
would make BOXR’s definition of
Public Director substantially similar to
the use of such term in BSE’s ByLaws,177 which the Commission is
approving as part of this Order, and in
Nasdaq’s By-Laws,178 which the
Commission previously found
consistent with the Act.179 The
Commission has previously stated its
belief that the inclusion of public, nonindustry representatives on exchange
oversight bodies is critical to an
exchange’s ability to protect the public
interest.180 The Commission believes
that public representatives help to
ensure that no single group of market
participants has the ability to
systematically disadvantage other
market participants through the
exchange governance process. Further,
the Commission believes that public
directors can provide unique, unbiased
perspectives, which should enhance the
ability of BOXR to address issues in a
173 See, e.g., Securities Exchange Act Release Nos.
54494 (September 25, 2006), 71 FR 58023 (October
2, 2006) (SR–CHX–2006–23) (order approving
amendments to exchange by-laws and other
governance changes) and 53382, supra note 29.
174 See Section 4, BOXR By-Laws.
175 Currently, a BOXR Public Director is a director
who has no material relationship with a broker or
dealer, BSE, BOX, or BOXR. See Section 1(p), BOXR
By-Laws.
176 See proposed Section 1(q), BOXR By-Laws.
177 See BSE By-Laws, Article I(gg) and supra
notes 56 and 78–80 and accompanying text.
178 See Nasdaq By-Laws, Article I(y).
179 See Nasdaq Exchange Approval Order, supra
note 63, 71 FR at 3553, n.47.
180 Id. at 3553. See also Securities Exchange Act
Release No. 40760, supra note 79.
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nondiscriminatory fashion and foster
the integrity of BOXR.
In addition, in the BOX Transfer
Proposal, BSE proposes to change the
BOX LLC Agreement to require BSE, for
so long as the BOX Market remains a
facility of BSE, to allow BOX to
designate one non-voting participant to
the BSE Board and to recommend at
least 10%, but no fewer than one, of the
BOXR directors to the BOXR Board.181
BSE also would be required to include
on the BOXR Board at least two
directors representing BOX Participants,
but no fewer than 20% of all
directors,182 and at least four directors
who do not have a material direct or
indirect relationship with NASDAQ
OMX, its affiliates, or any provider of
BOX-related regulatory functions
outsourced by BSE, other than service as
directors of BSE or BOXR.183 The
proposed changes to the BOX LLC
Agreement would further require that
the directors on the BOXR Board, any
committees thereof, or the BOX
Committee, or the directors otherwise
engaged in BOX-related meetings not
have a material direct or indirect
relationship with NASDAQ OMX or its
affiliates or any provider of BOX-related
regulatory functions outsourced by BSE,
other than service as directors of BSE or
BOXR.184 The Commission finds that,
with respect to the composition of the
BOXR Board, the proposed changes
satisfy the requirements of Section
6(b)(3) of the Act because at least 20%
of BOXR Board directors must represent
BOX Participants. The Commission
further finds that the prohibition on
BOXR Board directors, committee
members, and others from having a
material direct or indirect relationship
with NASDAQ OMX or its affiliates or
any provider of BOX-related regulatory
functions outsourced by BSE are
181 The non-voting participant would have the
right to attend all meetings of the BOX Committee
and all BOX-related deliberations of the BSE Board
and committees thereof and receive equivalent
notice and meeting materials as BSE directors. See
Section 4.1(f), 6th BOX LLC Agreement.
182 See Section 4.1(f), 6th BOX LLC Agreement.
See also infra note 208 and accompanying text.
183 Id. See also supra note 168.
184 Id. Moreover, all other persons permitted to
attend meetings of the BOXR Board or any
committees thereof or the BOX Committee or
otherwise engaged in BOX-related meetings could
not have a material direct or indirect relationship
with NASDAQ OMX or its affiliates or any provider
of BOX-related regulatory functions outsourced by
BSE unless they are Permitted Recipients (as
defined below), BOXR directors, officers, or
employees, other parties making presentations to
directors of the BSE Board engaged in BOX-related
meetings, the BOXR Board, the BOX Committee or
the BSE ROC if such parties’ participation is only
to the extent necessary to make such presentations,
or consented to by BOX. See Section 4.1(f), 6th BOX
LLC Agreement.
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designed to preserve the independence
of the self-regulatory functions of BSE
that have been delegated to BOXR,
BSE’s wholly-owned subsidiary, and to
enable BSE, together with BOXR, to
carry out its SRO functions.
d. Oversight of BOX Market
Although BOX does not carry out any
regulatory functions, all of its activities
must be consistent with the Act. The
BOX Market is a facility of BSE and is
not solely a commercial enterprise, and
is subject to the Act.185 Accordingly, the
current BOX LLC Agreement 186 has
provisions designed to enable BOX to
operate in a manner that complies with
the federal securities laws, including the
objectives and requirements of the Act.
Because BOX’s obligations endure as
long as the BOX Market is a facility of
BSE, regardless of the BSE’s transfer of
its ownership interest in BOX to MX
US, BSE does not propose to amend the
aforementioned provisions, except as
provided below.
In accordance with BSE’s obligations
as the SRO for the BOX Market, the
books, records, premises, officers,
directors, agents, and employees of BOX
are currently deemed to be the books,
premises, officers, directors, agents, and
employees of BSE for the purpose of,
and subject to, oversight pursuant to the
Act.187 Furthermore, the books and
records of BOX are subject at all times
to inspection and copying by BSE and
the Commission.188 To this provision,
BSE proposes to add in the BOX
Transfer Proposal that inspection,
copying, and review of the books and
records of BOX by the Regulatory
Authority at the premises of BOX, and
access to any copied books and records
removed from the premises of BOX or
produced to the Regulatory Authority at
its request, would in all cases be
conducted by, or limited to, certain
individuals (such individuals referred to
as, ‘‘Permitted Recipients’’) 189 and
185 See BOX LLC Agreement Order, supra note 99,
69 FR at 2765.
186 See Sections 4.2, 12.1, 15, 16.5, and 19.6, 5th
BOX LLC Agreement.
187 See Section 12.1, 5th BOX LLC Agreement.
188 Id.
189 See Section 12.1, 6th BOX LLC Agreement.
Permitted Recipients are (i) the BSE CRO and those
regulatory staff members responsible for regulatory
technology and budget, counsel to BSE CRO, or staff
of BSE’s internal audit department, (ii) any member
of the BSE Board serving on the BOX Committee
or BSE ROC, (iii) NASDAQ OMX CRO and staff in
the Office of General Counsel, (iv) any member of
the NASDAQ OMX Board of Directors serving on
the NASDAQ OMX ROC, and (v) any Professional
Services provider. ‘‘Professional Services’’ means
services performed by outside counsel, consultants,
any provider of BOX-related regulatory functions
outsourced by BSE, or subcontractors for the benefit
of BOX or the BOX Market. See Section 1.1, 6th
BOX LLC Agreement.
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directors or employees of BOXR.190 BSE
also proposes that the Regulatory
Authority would inspect, copy, and
review the books and records of BOX,
and would use any information
obtained thereby, only for purposes of
fulfilling its regulatory obligations and
for no other purpose.191 Further, BSE
proposes to add language stating that
although BOX would not be entitled to
refuse the inspection, review, and/or
copying its books and records by the
Regulatory Authority, it would be
entitled to damages in the event that
such inspection, review, and/or copying
was conducted for any purpose other
than to fulfill the Regulatory Authority’s
regulatory responsibilities.192
The Commission finds that these
provisions are consistent with the Act.
The Commission notes that BSE
proposes to delegate to BOXR, together
with the BOX Committee, much of its
regulatory responsibilities over the BOX
Market. Therefore, although BSE
proposes that access to books and
records would be limited to Permitted
Recipients and BOXR directors and
employees, within BSE’s proposed
regulatory framework, this limitation
would not exclude any individuals who
may need access to BOX books and
records. Moreover, the Commission has
authority under the Act to inspect
BOX’s books and records because BOX
is the operator of the BOX Market, a
facility of an exchange. In addition, the
Commission finds it consistent with the
Act that BSE proposes to specify that
inspection, copying, and review of
books and records and the use of any
information obtained thereby be for
purposes of fulfilling BSE’s regulatory
obligations. The Commission notes that,
because BOX would not be entitled to
preclude BSE from inspecting,
reviewing, or copying of its books and
records, BOX could not rely on the
books and records provisions of the
revised BOX LLC Agreement to
improperly hinder BSE from carrying
out its regulatory and oversight
responsibilities under the Act.193
In the BOX Transfer Proposal, BSE
also proposes to add certain other
provisions to the BOX LLC Agreement.
Specifically, BSE proposes to provide
that all confidential information
190 See
Section 12.1, 6th BOX LLC Agreement.
191 Id.
192 Id.
193 See Section 12.1, 6th BOX LLC Agreement.
Instead, BSE proposes that BOX would be entitled
to damages in the event any inspection, copying, or
review of BOX books and records by the Regulatory
Authority is, in whole or in part, used by the
Regulatory Authority or any of its affiliates for any
purpose other than to fulfill the Regulatory
Authority’s regulatory obligations. See Section 12.1,
6th BOX LLC Agreement.
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pertaining to regulatory matters of BOX
and the BOX Market (including, but not
limited to, disciplinary matters, trading
data, trading practices, and audit
information) contained in the books and
records of BOX would not be made
available to any persons other than to
those officers, directors, employees, and
agents of BOX that have a reasonable
need to know the contents thereof and
that such confidential information be
retained in confidence by BOX and the
officers, directors, employees, and
agents of BOX and not be used for any
commercial purposes.194 BSE also
proposes to add a provision in the BOX
LLC Agreement requiring BOX to
provide prompt notice to the Regulatory
Authority and the Regulatory Director of
any amendments, modifications,
waivers, or supplements to the BOX
LLC Agreement presented to the BOX
Board for approval.195 Any proposed
change to the BOX LLC Agreement
would be submitted to the BOX
Committee and if such change is
required under Section 19 of the Act
and rules thereunder to be filed with, or
filed with and approved by, the
Commission before such change may be
effective, then such change would not
be effective until filed with, or filed
with and approved by, the Commission,
as the case may be.196
The current BOX LLC Agreement
provides that each BOX Member and its
officers, directors, agents, and
employees must submit to the
jurisdiction of the federal courts, the
Commission, and BSE for the purposes
of any suit, action, or proceeding
pursuant to federal securities laws,
rules, or regulations thereunder, arising
out of, or relating to, BOX activities.197
BSE proposes to extend this provision
such that BOX and its officers, directors,
agents, and employees also would
submit to the jurisdiction of the U.S.
federal courts, the Commission, and the
Regulatory Authority.198
194 See Section 16.6, 6th BOX LLC Agreement.
BSE also proposes that the provision would not be
interpreted to limit or impede the rights of the
Commission or the Regulatory Authority to access
and examine such confidential information or to
limit or impede the ability of any officers, directors,
employees, or agents of BOX to disclose such
confidential information to the Commission or the
Regulatory Authority. Id.
195 See Section 19.1, 6th BOX LLC Agreement.
196 Id. BOX would not be required to obtain the
approval of the Regulatory Authority for any
amendment to the revised BOX LLC Agreement
pursuant to which the BOX Market would cease to
be a facility of BSE, provided that such amendment
would be filed with, or filed with and approved by,
the Commission, as the case may be, before such
amendment may be effective.
197 As a BOX Member, MX US would be subject
to this provision.
198 See Section 19.6(b), 6th BOX LLC Agreement.
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Finally, the current BOX LLC
Agreement provides that BSE, as a party
to the agreement, and BOX Members
would take such action as is necessary
to ensure that their officers, directors,
and employees consent to the
applicability of certain provisions in the
BOX LLC Agreement, including the
requirement to submit to the
jurisdiction of the U.S. federal courts,
the Commission, and BSE. BSE
proposes to amend this provision such
that BOX’s officers, directors, and
employees would also consent to the
same provisions.199
The Commission believes that the
revised provisions to the BOX LLC
Agreement are intended to enhance
BSE’s ability to fulfill its self-regulatory
obligations and assist in administering
and complying with the requirements of
the Act. Therefore, the Commission
finds that these provisions are
consistent with the Act.
C. BOXR
As noted above, after the BSE
Acquisition, BOXR would continue to
be wholly-owned by BSE and would
become the indirect, wholly-owned
subsidiary of NASDAQ OMX. BOXR is
currently governed by a Delegation
Plan,200 the BOXR By-Laws, and the
applicable BSE Rules, including the BSE
Constitution (to be replaced by the BSE
By-Laws), and would continue to be so
governed after the BSE Acquisition and
the transfer of BSE’s interest in BOX to
MX US.
In addition, BSE now proposes to
adopt a written operating agreement for
BOXR (‘‘BOXR LLC Agreement’’) in
which BSE would be the sole member.
BSE also proposes to amend the BOXR
By-Laws to reflect the BSE Acquisition.
As discussed above, BSE would
continue to delegate certain selfregulatory responsibilities relating to the
BOX Market to BOXR, although BSE
would retain ultimate responsibility.201
199 See Section 19.6(c), 6th BOX LLC Agreement.
BSE proposes to expand the provisions to which
individuals must consent. In addition, MX and the
Regulatory Authority would take such action as is
necessary to insure that with respect to their BOX
related activities, MX’s officers, directors and
employees consent to the communication of their
‘‘personal information’’ as defined under Canada’s
Act Respecting the Protection of Personal
Information in the Private Sector, R.S.Q.c.P–39.1
(‘‘Private Sector Privacy Act’’), by MX to the
Commission and the Regulatory Authority and
agree to waive the protection of such ‘‘personal
information’’ that is provided by the Private Sector
Privacy Act.
200 See supra note 126 and accompanying text.
See also BOXR Order, supra note 124. No changes
to the Delegation Plan are proposed.
201 See supra notes 125–127 and accompanying
text.
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1. BOXR LLC Agreement; Changes in
Control of BOXR
BSE proposes to adopt the BOXR LLC
Agreement.202 The BOXR LLC
Agreement would include provisions
that reflect BOXR’s status as a whollyowned subsidiary of an SRO and that
are designed to preserve the
independence of the self-regulatory
functions of BSE that have been
delegated to BOXR.203 Also, the BOXR
LLC Agreement would preclude BOXR
from making distributions to BSE using
regulatory funds.204
In addition, BSE could not transfer or
assign its ownership of BOXR, unless
such transfer or assignment is filed with
and approved by the Commission
pursuant to Section 19 of the Act.205
Moreover, because BOX Participants are
BSE members, they are subject to
Chapter XXXIX of the BSE Rules, which
requires that no member or person
associated with a member may own
more than 20% of the outstanding
voting securities of NASDAQ OMX.206
Together, 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
BSE to effectively carry out their
regulatory oversight responsibilities
under the Act. The Commission believes
that the proposed BOXR LLC Agreement
is consistent with the Act.
2. Amendments to the BOXR By-Laws;
BOXR Board; Fair Representation
The BOXR Board would continue to
be composed of at least 50% BOXR
Public Directors 207 and at least 20%
(but no fewer than two directors) would
continue to be officers or directors of a
firm approved as a BOX Participant
(‘‘BOXR BOX Participant Directors’’).208
The BOXR BOX Participant Directors
would be selected pursuant to BOXR’s
current procedures for the nomination
and election of BOXR BOX Participant
Directors by BOX Participants, as would
be the BOX Participant Director
202 See BSE Governance Proposal Notice, supra
note 3, 73 FR at 26159.
203 See Section 7, BOXR LLC Agreement.
204 See Section 15, BOXR LLC Agreement.
Pursuant to Schedule A of the proposed BOXR LLC
Agreement, BOXR regulatory funds means fees,
fines, or penalties derived from the regulatory
operations of BOXR, but would not include
revenues derived from listing fees, market data
revenues, transaction revenues, or any other aspect
of the commercial operations of BOXR, even if a
portion of such revenues are used to pay costs
associated with the regulatory operations of BOXR.
205 See Section 20, BOXR LLC Agreement.
206 See supra note 99 and accompanying text.
207 See supra notes 175–176 and accompanying
text.
208 See proposed Section 4, BOXR By-Laws.
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candidate for the BSE Board.209 The
successful candidates for BOXR
Participant Director positions would be
submitted to BSE, as the sole member of
BOXR, for election.210 The successful
candidate for the BOX Participant
Director position on the BSE Board
would be submitted to NASDAQ OMX,
as the sole shareholder of BSE, for
election.211 In connection with this
process, BSE proposes, in the BSE
Governance Proposal, that the BSE ByLaws include a provision that requires
BSE’s Nominating Committee to give
due consideration to the
recommendation of the BOXR
Nominating Committee in nominating
the BOX Participant Director to the BSE
Board.212
Although the BSE By-Laws require
only due consideration of the
recommendation made by the BSE
Nominating Committee, BSE states in its
proposed rule change that, in
nominating the BOX Participant
Director to the BSE Board, the BSE
Nominating Committee would adopt the
recommendation of the BOXR
Nominating Committee, and NASDAQ
OMX, as the sole stockholder of BSE,
would elect such candidate.213 To
reconcile the BSE By-Laws and this
representation, BSE states that
immediately following the closing of the
BSE Acquisition, BSE would propose to
209 See current Section 14(e), BOXR By-Laws, and
proposed Section 14(e), proposed BOXR By-Laws.
See also BOXR Order, supra note 124, 69 FR 2768,
at notes 21–26 and 52–57, and accompanying text,
and discussion supra at note 60 accompanying text.
The BOXR Nominating Committee would continue
to be responsible for nominating the BOXR BOX
Participant Director candidates for the two
positions on the BOXR Board and the BOX
Participant Director candidate for the one position
on the BSE Board. See supra note 59 and
accompanying text. In addition, BOX Participants
would continue to be able to submit additional
nominees for each of these positions and vote on
and elect from the slate of nominees the candidates
to be elected to those positions. See Section 14(e),
BOXR By-Laws.
210 See proposed Section 14(e)(iii), BOXR ByLaws.
Pursuant to proposed Section 14(e)(iii)(E) of the
BOXR By-Laws, the two nominees for the BOXR
Participant Director positions receiving the highest
number of votes would be declared elected thereto,
and the one nominee for the BOX Participant
Director position on the BSE Board would be
recommended by the BOXR Nominating Committee
for election thereto.
Proposed Section 22 of the BOXR LLC
Agreement, which otherwise generally provides
that the provisions of the BOXR LLC Agreement
would not be deemed to create any right in any
person not a party to the BOXR LLC Agreement,
would make clear that the limitations of Section 22
would not apply to BOX Participants to the extent
provided in Section 14 of the BOXR By-Laws.
211 Id.
212 See proposed Section 4.14, BSE By-Laws.
213 See BSE Governance Proposal Notice, supra
note 3, 73 FR at 26159, n.16, and accompanying
text.
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the BSE Board an amendment to the
BSE By-Laws to make it clear that the
candidate nominated by the BOXR
Nominating Committee to serve as the
BOX Participant Director on the BSE
Board would also be nominated by the
BSE Nominating Committee and elected
by NASDAQ OMX, unless such
nominee is not otherwise eligible for
service pursuant to BSE By-Laws
Section 4.3.214 The Commission
believes that the proposed petition
process, coupled with the right to vote
for their representatives, should help to
ensure that BOX Participants have the
opportunity to be involved in the
selection of their representatives for the
BOXR Board and the BSE Board. The
Commission notes that this proposed
process is consistent with the current
process for electing BOX Participant
Directors previously approved by the
Commission.215
The Commission finds that the
proposed changes are consistent with
Sections 6(b)(3) of the Act,216 which
requires BSE to assure a fair
representation of its members in the
selection of its directors and
administration of its affairs because the
proposal is designed to ensure that BOX
Participants continue to participate in
the selection of their representatives to
the BOXR and BSE Boards.
3. Disciplining of Affiliated Members
In the BSE Governance Proposal, BSE
proposes to amend the BOXR By-Laws
to provide that neither the BSE Board
nor the BOXR Board would consider
appeals of disciplinary actions
involving BOX Participants that are
affiliates of NASDAQ OMX.217
Currently, any BOX Participant
‘‘adjudged guilty in any disciplinary
proceeding’’ by the BOXR Hearing
Committee 218 or any panel thereof may
214 In Amendment No. 1 to the BSE Governance
Proposal, BSE states that, after such proposal to the
BSE Board: ‘‘[BSE] shall promptly file the
amendment as a proposed rule change for approval
by the Commission. This clarifying change could
not be included in this filing because Article XX of
[BSE’s] current Constitution, which is being
replaced by the proposed [BSE] By-Laws, provides
that [BSE’s] members must approve amendments to
the [BSE] Constitution. The [BSE] members voted
to approve the [BSE] By-Laws as submitted in this
filing on December 4, 2007, prior to the submission
of this filing to the Commission, and it would have
been impracticable and unduly expensive to seek a
second member vote for approval of this clarifying
change. Following adoption of the new [BSE] ByLaws, the [BSE] Board will have authority to
approve [BSE] By-Law amendments.’’ See
Amendment No. 1 to the BSE Governance Proposal,
supra note 4.
215 See BOXR Order, supra note 124, 69 FR at
2771.
216 15 U.S.C. 78f(b)(3).
217 See proposed Section 14(f)(i), BOXR By-laws.
218 See BOXR By-Laws, Section 14(f).The ‘‘BOXR
Hearing Committee’’ is appointed by the Chairman
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appeal such decision to the BOXR Board
and subsequently to the BSE Board. Any
initial decision that is rendered by the
BOXR Hearing Committee regarding the
affiliated BOX Participant would
instead constitute final disciplinary
action of BSE under Rule 19d–1(c)(1)
under the Act.219 This proposed change
is consistent with the process for
appeals by affiliated members of Nasdaq
under Nasdaq’s rules, which previously
was approved by the Commission.220
The Commission believes that this
proposed change is consistent with the
Act, including Section 6(b)(7)
thereunder,221 which requires that the
rules of an exchange must provide a fair
procedure for disciplining members.
Specifically, this proposal, which
specifies that the BSE Board and the
BOXR Board may not be involved in
review of disciplinary actions involving
affiliated BOX Participants, would
mitigate a conflict of interest that could
occur as a result of Nasdaq OMX’s
ownership of BSE.
D. BSX
1. NASDAQ OMX Ownership of BSX
In addition to the BSE Acquisition,
NASDAQ OMX would acquire all of the
outstanding limited liability company
interests in BSX held by investors other
than BSE.222 As a result, NASDAQ OMX
would own 46.79% of BSX directly and
would own indirectly through BSE the
remaining 53.21% of BSX. Following
the BSE Acquisition, BSE would remain
the SRO and would provide the
regulatory framework for BSX,223 and
BSE expects to operate in the future a
facility for the trading of cash equity
securities through BSX. BSE would not
resume trading of cash equity securities
until it has filed a proposed rule change
under Section 19(b) of the Act
proposing amendments to BSE Rules,
of the BOXR Board and must include one BOX
Participant, but may not include members of the
BOXR Board or BSE Board. The BOXR Hearing
Committee has exclusive jurisdiction to conduct
disciplinary proceedings brought by BOXR against
any BOX Participant for violation of the Act, the
rules and regulations thereunder, the BSE By-Laws,
BOX Rules, the BOXR LLC Agreement or By-Laws,
or the interpretations and stated policies of either
the BSE or BOXR Boards. Id. The BOX Committee
would hear appeals from regulatory decisions of the
BOXR Board. See supra note 167 and
accompanying text.
219 17 CFR 240.19d–1(c)(1).
220 See Securities Exchange Act Release No.
54170, supra note 113, 71 FR at 42151.
221 15 U.S.C. 78f(b)(7).
222 BSX was formed in 2004 as a joint venture
between BSE and several investors to operate an
electronic trading facility, BeX, for the trading of
cash equity securities. BeX ceased its operations in
September 2007. See BSE Governance Proposal
Notice, supra note 3, 73 FR at 26166.
223 See proposed Section 3.2, BSX Operating
Agreement.
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and the Commission has approved the
new BSE Rules.224
The current BSX Operating
Agreement requires that any transfer
that results in the acquisition and
holding by any person, alone or together
with any affiliate of such person, of an
aggregate percentage interest level that
meets or crosses the threshold of 20%
be subject to a rule filing pursuant to
Section 19(b)(1) of the Act.225 In
accordance with this requirement, BSE
proposes in the BSE Governance
Proposal that the Commission approve
the transfer of ownership interests in
BSX to NASDAQ OMX.
The Commission notes that following
the transfer of ownership interests in
BSX to NASDAQ OMX, BSE and
NASDAQ OMX would be the sole
members of BSX. In accordance with
proposed Section 18.1 of the BSX
Operating Agreement, any amendment
to the BSX Operating Agreement,
including to permit the admission of
additional or substitute members, would
have to be submitted to the BSE Board
for review, and, if any such amendment
would be required under Section 19 of
the Act and the rules promulgated
thereunder, to be filed with, or filed
with and approved by, the Commission
before such amendment may be
effective, then such amendment would
not be effective until filed with, or filed
with and approved by the
Commission.226 As the operator of a
facility of BSE, BSX must continue to be
operated in a manner consistent with
the regulatory and oversight
responsibilities of BSE and with the Act
and rules and regulations thereunder.
The Commission believes that, because
BSE would remain the SRO and would
provide the regulatory framework for
BSX, the transfer of ownership interests
in BSX to NASDAQ OMX would not
impair the continued ability of BSE or
the Commission to discharge their
respective regulatory and oversight
responsibilities. The Commission
therefore finds that the transfer of
ownership interests in BSX to NASDAQ
OMX is consistent with the Act.
2. BSX Operating Agreement
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In conjunction with the BSE
Acquisition, BSE also proposes in the
BSE Governance Proposal to amend the
BSX Operating Agreement to reflect the
sole ownership of BSX by BSE and
NASDAQ OMX.
224 See BSE Governance Proposal Notice, supra
note 3, 73 FR at 26167.
225 See current Section 18.1, BSX Operating
Agreement.
226 See proposed Section 8.2(e), BSX Operating
Agreement.
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a. Transfer, Ownership and Voting
Restrictions
The amended BSX Operating
Agreement would continue to state that
BSX must provide the Commission with
written notice ten days prior to the
closing date of any acquisition that
results in a BSX Member’s percentage
ownership interest in BSX, alone or
with any affiliate, meeting or crossing
the 5%, 10%, or 15% thresholds.227 In
addition, the amended BSX Operating
Agreement would continue to provide
that any transfer of BSX units that
results in the acquisition and holding by
any person, alone or together with an
affiliate, of an interest that meets or
crosses the 20% threshold or any
successive 5% threshold (i.e., 25%,
30%, etc.) would trigger the requirement
to file an amendment to the BSX
Operating Agreement with the
Commission under Section 19(b) of the
Act.228
Further, the amended BSX Operating
Agreement would continue to provide
that any person that acquires a
controlling interest (i.e., an interest of
25% or greater) in a BSX Member that
holds 20% or more of BSX units would
be required to become a party to the
BSX Operating Agreement and abide by
its terms.229 The addition of any such
indirect controlling party would also
require a filing with the Commission
pursuant to Section 19(b) of the Act.230
In the BSE Governance Proposal, BSE
proposes to amend the BSX Operating
Agreement to remove provisions that
allow BSX Members to exercise rights of
first refusal in the event that one
member proposes to transfer its
ownership interests in BSX to another
member or BSX proposes to issue
additional units of ownership.231
Because BSX would be 100% owned,
227 See proposed Section 8.2(d), BSX Operating
Agreement.
228 See supra note 225. In addition, the amended
BSX Operating Agreement would provide that any
transfer of BSX units that would reduce BSE’s
ownership in BSX below the 20% threshold would
require a proposed rule change under Section 19(b)
of the Act. Moreover, Commission approval would
be required to permit any person, alone or together
with any affiliate, to control 20% of the Total Votes.
See current Section 8.4(e), BSX Operating
Agreement, and proposed Section 8.2(e), BSX
Operating Agreement. The Commission notes that
proposed Section 18.1 of the BSX Operating
Agreement requires the submission of any proposed
amendment thereto to the BSE Board for review. If
such amendment is required under Section 19 of
the Act to be filed with, or filed with and approved
by, the Commission, it could not take effect until
filed with, or filed with and approved by the
Commission.
229 See proposed Section 8.2(f), BSX Operating
Agreement.
230 Id.
231 See current Sections 8.2 and 8.3, BSX
Operating Agreement.
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46951
directly and indirectly, by NASDAQ
OMX, this provision is no longer
relevant. In addition, BSE proposes to
expand those provisions of the BSX
Operating Agreement that currently
prohibit BSX Participants and their
affiliates from owning or voting more
than 20% of BSX to include all BSE
members and their affiliates. To make
the BSX Operating Agreement
consistent with the exception from BSE
Rules to permit NES and NOS to
become affiliates of BSE,232 the
proposed amendment to the BSX
Operating Agreement would state that
these ownership and voting restrictions
do not limit NASDAQ OMX’s or BSE’s
ownership interests in BSX.233
The Commission believes that the
proposed changes to provisions in the
BSX Operating Agreement on transfer,
ownership, and voting restrictions
would not affect the ability of BSE to
carry out its self-regulatory
responsibilities or the ability of the
Commission to fulfill its responsibilities
under the Act. In particular, the
proposal would not change the current
percentage thresholds in the transfer,
ownership, and voting provisions. The
Commission finds that the proposed
revisions to the BSX Operating
Agreement discussed above are
consistent with the Act.
b. BSE’s Authority Over BSX
Although NASDAQ OMX would own
directly 46.79% of BSX, BSE would be
entitled to designate all of the directors
of the BSX board of directors (‘‘BSX
Board’’).234 In addition, in the BSE
Governance Proposal, BSE proposes to
delete a provision in the BSX Operating
Agreement that currently requires a
super-majority of BSX directors’ votes,
including the affirmative votes of all
directors designated by BSE, before BSX
could take certain significant actions,
such as entering into a new line of
business or replacing BSE as BSX’s
regulatory service provider.235 Instead,
BSE would have the authority to veto or
mandate actions that relate to regulatory
requirements.236 Specifically, the
proposal sets forth that BSE’s
affirmative vote would be required with
respect to any action, transaction, or
aspect of an action or transaction that
232 See
supra notes 117–123 and accompanying
text.
233 See
proposed Sections 8.3 and 8.4, BSX
Operating Agreement.
234 See proposed Section 4.1(b), BSX Operating
Agreement. In addition, BSE proposes to reduce the
number of BSX directors from six to five. See
proposed Section 4.1(a), BSX Operating Agreement.
235 See current Section 4.4, BSX Operating
Agreement.
236 See proposed Section 4.4, BSX Operating
Agreement.
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BSE, in its sole discretion, determines is
necessary or appropriate for, or
interferes with, the performance or
fulfillment of BSE’s regulatory
functions, its responsibilities under the
Act or as specifically required by the
Commission.237 In addition, BSE would
have the sole and exclusive right to
direct that any required, necessary, or
appropriate act be undertaken without
regard to the vote, act, or failure to vote
or act by any other party in any
capacity.238
Further, the amended BSX Operating
Agreement would state that any
amendment thereto must be submitted
to the BSE Board for review and, if such
amendment is required under Section
19(b) of the Act and the rules
thereunder to be filed with, or filed with
and approved by the Commission, then
such amendment would not be effective
until filed with, or filed with and
approved by the Commission, as the
case may be.239
The Commission believes that these
proposals are designed to preserve
BSE’s regulatory authority over BSX,
and any proposed facility for the trading
of cash equity securities that BSX may
operate, and are consistent with the Act
because they would grant BSE the
ability to direct BSX to perform any
required, necessary, or appropriate act
and would allow BSE to veto or
mandate actions that relate to regulatory
requirements. The Commission notes
that BSE could not operate a facility for
the trading of cash equity securities
until it has filed under Section 19(b) of
the Act, and the Commission has
approved, the new BSE Rules. In
particular, the Commission believes
these changes are consistent with
Section 6(b)(1) of the Act,240 which
requires, among other things, that the
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 regulations
thereunder, and the rules of the
exchange.
c. Confidentiality Provisions
In the BSE Governance Proposal, BSE
proposes to amend the BSX Operating
Agreement to provide that all
confidential information pertaining to
the self-regulatory function of BSE or
the business of BSE relating to the
237 Id.
238 Id.
239 See proposed Section 18.1, BSX Operating
Agreement.
240 15 U.S.C. 78f(b)(1).
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trading of cash equity securities
(including disciplinary matters, trading
data, trading practices and audit
information) in the books and records of
BSX would not be made available to any
persons. The proposal would allow such
information to be made available to
officers, directors, employees and agents
of BSX who have a reasonable need to
know the contents thereof. However,
such confidential information would be
required to be retained in confidence by
BSX and its officers, directors,
employees and agents and not be used
for any commercial purposes.241 The
Commission believes that the revised
confidentiality provisions would not
impair BSE’s self-regulatory obligations
with respect to BSX and finds that this
provision is consistent with the Act.
d. Jurisdiction
The current BSX Operating
Agreement provides that BSX and each
BSX Member as well as the officers,
directors, agents, and employees of BSX
and each BSX Member must submit to
the jurisdiction of the federal courts, the
Commission, and BSE for the purposes
of any suit, action, or proceeding
pursuant to the U.S. federal securities
laws or the rules or regulations
thereunder, arising out of, or relating to
BSX’s activities.
In the BSE Governance Proposal, BSE
proposes to amend Section 18.6(b) of
the BSX Operating Agreement to: (1)
clarify that the jurisdiction of the U.S.
federal courts, the Commission, and
BSE over BSX, its members, and their
respective officers, directors, agents, and
employees is exclusive; (2) require BSX
and its members and their respective
officers, directors, agents, and
employees to agree not to assert lack of
personal jurisdiction by the U.S. federal
courts or BSE; 242 and (3) include a
provision regarding the waiver of the
defense or application of any foreign
secrecy or blocking statutes by BSX and
its members and their respective
officers, directors, agents, and
employees, with respect to BSX’s
activities or their participation therein.
The Commission believes that these
changes, in conjunction with other
provisions of the BSX Operating
Agreement that would remain
unchanged, would enhance BSE’s
241 See proposed Section 16.7, BSX Operating
Agreement. BSE also proposes that the provision
would not be interpreted to limit or impede the
ability of any officers, directors, employees or
agents of the Company to disclose confidential
information to the Commission or the BSE.
242 Section 18.6(b) of the BSX Operating
Agreement currently requires BSX and its members
and their respective officers, directors, agents, and
employees, to agree not to assert lack of personal
jurisdiction by the Commission.
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ability to fulfill its self-regulatory
obligations and assist in administering
and complying with the requirements of
the Act. Moreover, BSE is required to
enforce compliance with these
provisions because they are ‘‘rules of the
exchange’’ within the meaning of
Section 3(a)(27) of the Act.243 A failure
on the part of BSE to enforce its rules
could result in a Commission
enforcement action pursuant to Section
19(h)(1) of the Act.244
E. BSECC
As a result of the BSE Acquisition,
BSECC, BSE’s wholly-owned subsidiary
and a registered clearing agency, would
become a wholly-owned indirect
subsidiary of NASDAQ OMX. As noted
above, BSECC ceased processing trades
in 2007. In connection with the
transaction, BSECC proposes, in the
BSECC Governance Proposal, to amend
its Articles of Organization (‘‘BSECC
Articles of Organization’’). BSECC also
proposes to update the BSECC Articles
of Organization and By-Laws (‘‘BSECC
By-Laws’’) in certain other respects,
including, according to BSE, to reflect
modern corporate practice for
Massachusetts corporations. In addition,
BSECC has filed the NASDAQ OMX
Certificate and By-Laws as proposed
rules.245
In connection with the BSE
Acquisition, BSECC proposes to amend
the BSECC Articles of Organization such
that the total number of shares of each
class of stock that BSECC would be
authorized to issue is 150 shares of
common stock. This amendment would
reflect a reduction in the total
authorized share capital of BSECC from
1000 shares of common stock to the 150
shares of common stock currently held
by BSE. Thus, following the
amendment, all of the authorized shares
of common stock of BSECC would be
outstanding and would be owned by
BSE.246
BSECC also proposes to amend the
BSECC Articles of Organization to
provide that BSE may not transfer or
assign any shares of stock of BSECC
unless such transfer or assignment has
been filed with and approved by the
Commission under Section 19 of the
Act.247 These proposed changes are
designed to ensure that, absent
Commission approval, BSECC would
remain a wholly-owned subsidiary of
BSE. Further, BSECC proposes to amend
243 15
U.S.C. 78c(a)(27).
U.S.C. 78s(h)(1).
245 See supra note 10 and accompanying text.
246 See proposed BSECC Articles of Organization,
Article III.
247 See proposed BSECC Articles of Organization,
Article V.
244 15
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the BSECC By-Laws to expressly state
that the BSECC By-Laws may be
amended only upon approval by the
Commission and in accordance with the
rules of BSECC.248
BSECC also proposes several other
changes to the BSECC Articles of
Organization and BSECC By-Laws,
which BSECC states are primarily for
the purpose of updating those
documents in accordance with modern
corporate practice for Massachusetts
corporations.249 Specifically, BSECC
proposes to adopt what it terms
‘‘modern provisions’’ stipulating the
conditions under which BSECC may
indemnify its officers and directors and
the scope of that indemnification. Such
provisions provide that directors of
BSECC are not personally liable to it for
breaches of fiduciary duty, except for
breaches involving (1) A breach of the
duty of loyalty, (2) acts or omissions not
in good faith or that involve intentional
misconduct or knowing violation of law,
(3) distributions of assets that would
render BSECC insolvent, or (4) any
transaction from which the director
derived an improper personal benefit.250
BSECC also proposes to amend the
BSECC By-Laws to clarify the time
periods allowed or required for notice to
stockholders of meetings, the
permissible duration of stockholder
proxies, and the setting of a record date,
which BSECC states are consistent with
Massachusetts law.251 BSECC further
proposes to remove a provision from its
By-Laws allowing close of the transfer
books of BSECC, which BSECC states is
no longer consistent with Massachusetts
law.252
In addition, BSECC states that its
proposed changes would allow
stockholders, as well as directors, to fill
vacancies on the BSECC Board of
Directors (‘‘BSECC Board’’) in
accordance with Massachusetts law 253
and to clarify that directors of BSECC,
if such directors also serve on the BSE
Board, must tender resignations from
the BSECC Board if they cease to be BSE
Directors.254 The proposed changes also
would clarify the requirements for
248 See proposed BSECC By-Laws Article VI.7.
BSECC Rule XII requires notice to clearing members
of amendments to the BSECC By-Laws.
249 See BSECC Governance Proposal Notice, supra
note 9, 73 FR at 27584.
250 See proposed BSECC By-Laws Article VI.
251 See proposed BSECC By-Laws Article I.4,
Article I.6, and Article V.3.
252 See BSECC By-Laws Article V.3. BSECC
represents that this change would not limit the
effectiveness of the change to the Articles of
Organization requiring Commission approval of
transfers of BSECC’s stock. See BSECC Governance
Proposal Notice, supra note 9, 73 FR 27583, n.5.
253 See proposed BSECC By-Laws Article II.4.
254 See proposed BSECC By-Laws Article II.7.
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action by the BSECC Board and the
stockholders to be taken without a
meeting.255
The Commission finds that the
proposed changes to the BSECC Articles
of Organization and BSECC By-Laws are
consistent with the requirements of the
Act and the rules and regulations
thereunder and particularly with the
requirements of Section 17A(b)(3)(C) of
the Act.256 The Commission notes that
the proposed rule change does not
amend BSECC’s rules or procedures
with respect to the clearance and
settlement of securities transactions or
the safeguarding of securities and funds
which are in BSECC’s control or for
which it is responsible. Section
17A(b)(3)(C) of the Act requires that a
clearing agency’s rules assure the fair
representation of its shareholders (or
members) and participants in the
selection of its directors and
administration of its affairs. BSECC
would remain a wholly-owned
subsidiary of BSE following the
acquisition by NASDAQ OMX and the
BSECC By-Laws relating to the
selection, composition, powers, and
duties of the BSECC Board, committees,
and officers, except as discussed above,
would remain unchanged. Accordingly,
the Commission finds that BSECC’s
rules would continue to assure the fair
representation of its shareholders and
participants in the selection of BSECC’s
directors and the administration of
BSECC’s affairs as required by Section
17A(b)(3)(C).
Furthermore, as discussed above with
respect to BSE, BSECC also has filed the
Certificate and By-Laws of NASDAQ
OMX as proposed rules.257 As noted
above, although NASDAQ OMX is not
itself an SRO, its activities with respect
to the operation of BSECC must be
consistent with, and must not interfere
with, the self-regulatory obligations of
BSECC. NASDAQ OMX’s By-Laws
would make applicable to all of
NASDAQ OMX’s SRO subsidiaries,
including BSECC (after the BSE
Acquisition), certain provisions of
NASDAQ OMX’s Certificate and
NASDAQ OMX’s By-Laws that are
designed to maintain the independence
of each of its SRO subsidiaries’ selfregulatory functions, enable each SRO
subsidiary to operate in a manner that
complies with the federal securities
255 BSECC also proposes changes to eliminate the
offices of ‘‘clerk’’ and ‘‘vice-chairman’’ from BSECC
and to delete references to those offices from the
By-Laws and to establish that the officers of BSECC
are all appointed by and subject to removal by the
BSECC Board. See proposed BSECC By-Laws
Article III.1 and III.4.
256 15 U.S.C. 78q–1(b)(3)(C).
257 See supra note 38.
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46953
laws, and facilitate the ability of each
SRO subsidiary and the Commission to
fulfill their regulatory and oversight
obligations under the Act.258
Additionally, the Commission notes
that the NASDAQ OMX By-Laws would
provide that the NASDAQ OMX Board,
as well as its officers, employees, and
agents, may not take any action that
would interfere with the decisions of
the board of directors of any SRO
subsidiary relating to its regulatory
functions or the market structures or the
clearing systems which it regulates or
that would interfere with the ability of
any SRO subsidiary to carry out its
responsibilities under the Act.259 Also,
the NASDAQ OMX By-Laws would
specifically require the NASDAQ OMX
Board to consider BSECC’s regulatory
obligations as a clearing agency when
evaluating any issue,260 including
granting any exemption from the
NASDAQ OMX voting limitations
discussed above.261 The Commission
believes that the NASDAQ OMX ByLaws, as amended to accommodate the
BSE Acquisition, are designed to
facilitate BSECC’s ability to fulfill its
self-regulatory obligations and,
accordingly, are consistent with Section
17A of the Act.
258 See Amendment No. 1 to the BSECC
Governance Proposal, supra note 10.
259 See proposed Section 12.1(a), NASDAQ OMX
By-Laws.
260 The NASDAQ OMX Board would be required
to consider, to the extent deemed relevant, when
evaluating any issue, whether such would promote
the prompt and accurate clearance and settlement
of securities transactions (and to the extent
applicable, derivative agreements, contracts and
transactions), would assure the safeguarding of
securities and funds in the custody or control of the
SRO subsidiaries that are clearing agencies or
securities and funds for which they are responsible,
would foster cooperation and coordination with
persons engaged in the clearance and settlement of
securities transactions, and would remove
impediments to and perfect the mechanism of a
national system for the prompt and accurate
clearance and settlement of securities transactions.
See proposed Section 12.7, NASDAQ OMX ByLaws.
261 Specifically, the NASDAQ OMX Board would
be required to determine that granting any such
exemption would promote the prompt and accurate
clearance and settlement of securities transactions
(and to the extent applicable, derivative agreements,
contracts and transactions), would assure the
safeguarding of securities and funds in the custody
or control of the SRO subsidiaries that are clearing
agencies or securities and funds for which they are
responsible, would foster cooperation and
coordination with persons engaged in the clearance
and settlement of securities transactions, and would
remove impediments to and perfect the mechanism
of a national system for the prompt and accurate
clearance and settlement of securities transactions.
See proposed Section 12.5, NASDAQ OMX ByLaws; and Article Fourth.C.6, NASDAQ OMX
Certificate. See also notes 100–104 and
accompanying text.
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Federal Register / Vol. 73, No. 156 / Tuesday, August 12, 2008 / Notices
III. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning: (1) Amendment
No. 1 to File No. SR–BSE–2008–23 (the
BSE Governance Proposal), including
whether Amendment No. 1 is consistent
with the Act; (2) Amendment No. 1 to
File No. SR–BSECC–2008–01 (the
BSECC Governance Proposal), including
whether Amendment No. 1 is consistent
with the Act; and (3) Amendment No.
1 to File No. SR–BSE–2008–25 (the BOX
Transfer Proposal), including whether
Amendment No. 1 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–BSE–2008–23, SR–BSECC–
2008–01, or SR–BSE–2008–25 as
applicable, on the subject line.
sroberts on PROD1PC70 with NOTICES
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street, NE.,
Washington, DC 20549–1090.
All submissions should refer to
Amendment No. 1 to File No. SR–BSE–
2008–23, Amendment No. 1 to File No.
SR–BSECC–2008–01, or Amendment
No. 1 to File No. SR–BSE–2008–25, as
applicable. 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
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 BSE or BSECC, as
applicable. All comments received will
be posted without change; the
Commission does not edit personal
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16:24 Aug 11, 2008
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identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to Amendment No. 1 to File
No. SR–BSE–2008–23, Amendment No.
1 to File No. SR–BSECC–2008–01, or
Amendment No. 1 to File No. SR–BSE–
2008–25, as applicable, and should be
submitted on or before September 2,
2008.
changes to the NASDAQ OMX By-Laws
in either instance.267
As discussed more fully above in
Sections II.A.1. and II.A.6., and in the
NASDAQ OMX By-Law Proposal
Notice, certain provisions of NASDAQ
OMX’s Certificate and By-Laws are
designed to facilitate the ability of
NASDAQ OMX’s SRO subsidiaries,
including BSE and BSECC, to maintain
the independence of each of the SRO
subsidiaries’ self-regulatory function,
IV. Accelerated Approval of the BSE
enable each SRO subsidiary to operate
Governance Proposal, as Modified by
in a manner that complies with the
Amendment No. 1, the BSECC
federal securities laws, and facilitate the
Governance Proposal, as Modified by
ability of each SRO subsidiary and the
Amendment No. 1, and the BOX
Commission to fulfill their regulatory
Transfer Proposal, as Modified by
and oversight obligations under the
Amendment No. 1
Act.268 As stated above, the Commission
finds that such provisions are consistent
The Commission finds good cause for
with the Act.269 Notably, the NASDAQ
approving: (1) The BSE Governance
OMX Certificate and By-Laws are rules
Proposal, as modified by Amendment
of Nasdaq that have been approved
No. 1, (2) the BSECC Governance
previously by the Commission, as noted
Proposal, as modified by Amendment
above, and the changes to the NASDAQ
No. 1, and (3) the BOX Transfer
OMX By-Laws were published for
Proposal, as modified by Amendment
notice and comment, as noted above,
No. 1, prior to the thirtieth day after the
and the Commission did not receive any
date of publication of notice of filing of
comments thereon.
such amendments in the Federal
Additionally, in Amendment No. 1 to
Register.262
the BSE Governance Proposal, BSE
In Amendment No. 1 to the BSE
proposes to amend Section 8.2(f) of the
Governance Proposal and Amendment
BSX Operating Agreement. Section
No. 1 to the BSECC Governance
8.2(f) currently requires that any person
Proposal, BSE and BSECC each propose who, alone or together with any affiliate
to adopt as rules the NASDAQ OMX
of such person, has 25 percent or greater
Certificate and NASDAQ OMX By-Laws. interest in a BSX Member who, alone or
together with any affiliate of such BSX
The NASDAQ OMX Certificate, as filed
Member, holds 20 percent or greater
by BSE and BSECC, was previously
approved by the Commission as rules of interest in BSX become party to, and
Nasdaq.263 The NASDAQ OMX By-Laws abide by all the provisions of, the BSX
Operating Agreement. In Amendment
were similarly approved previously by
the Commission.264 As filed by BSE and No. 1, BSE proposes to clarify that for
the Section 8.2(f) requirement to apply,
BSECC, the NASDAQ OMX By-Laws
a person, alone or together with any
include certain new terminology to
affiliate of such person, must have
reflect the acquisition of BSE and
direct or indirect ownership of 25
BSECC by NASDAQ OMX. These
percent or more of the total voting
changes were filed by Nasdaq as a
power of all equity securities of a BSX
proposed rule change, were published
for comment, and were approved by the Member, other than voting rights solely
with respect to matters affecting the
Commission.265 The changes were also
filed by Phlx, and were approved by the rights, preferences, or privileges of a
particular class of equity securities.
Commission, in connection with the
Notwithstanding the foregoing, BSE
Phlx Acquisition.266 The Commission
proposes to clarify that a person with
received no comments on the proposed
zero percent direct or indirect interest in
262 15 U.S.C. 78s(b)(2). Pursuant to Section
a BSX Member would not be required to
19(b)(2) of the Act, the Commission may not
approve any proposed rule change, or amendment
thereto, prior to the thirtieth day after the date of
publication of the notice thereof, unless the
Commission finds good cause for so doing.
263 See Nasdaq Exchange Approval Order, supra
note 63, 73 FR at 3552–3553.
264 See NASDAQ OMX By-Laws Proposal Notice,
supra note 18, 73 FR 26182, and NASDAQ OMX
By-Laws Approval Order, supra note 31, 73 FR
42850.
265 Id.
266 See Securities Exchange Act Release No.
58179, supra note 27.
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267 In addition, Amendment No. 1 to the BSE
Governance Proposal and Amendment No. 1 to the
BSECC Governance Proposal incorporate a change
to the Nasdaq OMX By-Laws to clarify the
definition of Non-Industry Director with respect to
issuer representation on the Nasdaq OMX Board of
Directors that recently was approved by the
Commission. See Securities Exchange Act Release
No. 58201 (July 21, 2008), 73 FR 43812 (July 28,
2008) (SR–NASDAQ–2008–043).
268 See supra notes 38–47, 100–104 and
accompanying text.
269 See id.
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become party to the BSX Operating
Agreement pursuant to the revised
Section 8.2(f).
The Commission finds these changes
to the BSX Operating Agreement
consistent with the Act. Section 8.2(f) of
the BSX Operating Agreement is
designed to minimize the potential that
a person could improperly interfere
with or restrict the ability of the
Commission and BSE to effectively
carry out their regulatory oversight
responsibilities under the Act. The
clarifications proposed by BSE do not
hinder the intent of Section 8.2(f),
because the Commission believes that a
person without voting power in the
equity securities of a BSX Member, or a
person with no direct or indirect
interest in a BSX Member, could not
interfere with or restrict the
Commission’s or the BSE’s ability to
carry out its regulatory responsibilities.
In Amendment No. 1 to the BOX
Transfer Proposal, BSE proposes to
amend Section 8.4(g) of the BOX LLC
Agreement. Section 8.4(g) currently
requires that any person who, alone or
together with any affiliate of such
person, has 25 percent or greater interest
in a BOX Member who, alone or
together with any affiliate of such BOX
Member, holds 20 percent or greater
interest in BOX become party to, and
abide by all the provisions of, the BOX
LLC Agreement. In Amendment No. 1,
BSE proposes to clarify that for the
Section 8.4(g) requirement to apply, a
person, alone or together with any
affiliate of such person, must have
direct or indirect ownership of 25
percent or more of the total voting
power of all equity securities of a BOX
Member, other than voting rights solely
with respect to matters affecting the
rights, preferences, or privileges of a
particular class of equity securities.
Notwithstanding the foregoing, BSE
proposes to clarify that a person with
zero percent direct or indirect interest in
a BOX Member would not be required
to become party to the BOX LLC
Agreement pursuant to the revised
Section 8.4(g).
The Commission finds these changes
to the BOX LLC Agreement consistent
with the Act. Section 8.4(g) of the BOX
LLC Agreement is designed to minimize
the potential that a person could
improperly interfere with or restrict the
ability of the Commission and BSE to
effectively carry out their regulatory
oversight responsibilities under the Act.
The clarifications proposed by BSE do
not hinder the intent of Section 8.4(g)
because the Commission believes that a
person without voting power in the
equity securities of a BOX Member, or
a person with no direct or indirect
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interest in a BOX Member, could not
interfere with or restrict the
Commission’s or the BSE’s ability to
carry out its regulatory responsibilities.
For the reasons described above, the
Commission finds good cause for
approving each of the following on an
accelerated basis, pursuant to Section
19(b)(2) of the Act: (1) The BSE
Governance Proposal, as modified by
Amendment No. 1; (2) the BSECC
Governance Proposal, as modified by
Amendment No. 1; and (3) the BOX
transfer Proposal, as modified by
Amendment No. 1.
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,270 that the
BSE Interim Certificate Proposal (SR–
BSE–2008–02), as modified by
Amendment No. 1, be, and hereby is,
approved; that the BSE Governance
Proposal (SR–BSE–2008–23), as
modified by Amendment No.1, be, and
hereby is, approved on an accelerated
basis; that the BOX Transfer Proposal
(SR–BSE–2008–25), as modified by
Amendment No. 1, be, and hereby is,
approved on an accelerated basis; and
that the BSECC Governance Proposal
(SR–BSECC–2008–01), as modified by
Amendment No.1 be, and hereby is
approved on an accelerated basis.
By the Commission.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–18577 Filed 8–11–08; 8:45 am]
BILLING CODE 8010–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–58321; File No. SR–CBOE–
2008–78]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Relating to Market-Maker
Transaction Fees
August 6, 2008.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 1,
notice is hereby given that on July 25,
2008, the Chicago Board Options
Exchange, Incorporated (‘‘CBOE’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I, II and III
below, which Items have been prepared
by CBOE. The Commission is
270 15
1 15
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U.S.C. 78s(b)(1).
Frm 00087
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Sfmt 4703
46955
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of the Substance
of the Proposed Rule Change
CBOE proposes to amend its Fees
Schedule relating to market-maker
transaction fees. The text of the
proposed rule change is available on the
Exchange’s Web site (https://
www.cboe.org/legal), at the Exchange’s
Office of the Secretary and at the
Commission.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
CBOE included statements concerning
the purpose of and basis for the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of these statements
may be examined at the places specified
in Item IV below. CBOE has prepared
summaries, set forth in sections (A), (B),
and (C) below, of the most significant
aspects of such statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
Under the Exchange’s ‘‘Liquidity
Provider Sliding Scale’’ program, the
Exchange reduces Liquidity Provider
(CBOE Market-Maker, DPM, e-DPM and
LMM) per contract transaction fees
based on the number of contracts a
Liquidity Provider trades in a month.
The sliding scale applies to Liquidity
Provider transaction fees in all
products.2
A Liquidity Provider’s standard $.20
per contract transaction fee is reduced if
the Liquidity Provider reaches the
volume thresholds set forth in the
sliding scale in a month. As a Liquidity
Provider’s monthly volume increases,
its per contract transaction fee
decreases. The first 75,000 contracts
traded in a month (first tier) are assessed
at $.20 per contract. The next 1,125,000
contracts traded (up to 1.2 million total
contracts traded—second tier) are
assessed at $.18 per contract. The next
1.8 million contracts traded (up to 3
million total contracts traded—third
tier) are assessed at $.15 per contract
2 Contract volume resulting from dividend,
merger and short stock interest strategies as defined
in Footnote 13 of the Fees Schedule does not apply
towards reaching the sliding scale volume
thresholds.
E:\FR\FM\12AUN1.SGM
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Agencies
[Federal Register Volume 73, Number 156 (Tuesday, August 12, 2008)]
[Notices]
[Pages 46936-46955]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-18577]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-58324; File Nos. SR-BSE-2008-02; SR-BSE-2008-23; SR-
BSE-2008-25; SR-BSECC-2008-01]
Self-Regulatory Organizations; Boston Stock Exchange,
Incorporated; Boston Stock Exchange Clearing Corporation; Order
Approving Proposed Rule Change, as Modified by Amendment No. 1,
Amending the Certificate of Incorporation of Boston Stock Exchange,
Incorporated; Notice of Filing of Amendment No. 1 to a Proposed Rule
Change Relating to the Acquisition of the Boston Stock Exchange,
Incorporated by The NASDAQ OMX Group, Inc., and Order Granting
Accelerated Approval of the Proposed Rule Change, as Modified by
Amendment No. 1; Notice of Filing of Amendment No. 1 to a Proposed Rule
Change Relating to a Proposal To Transfer Boston Stock Exchange,
Incorporated's Ownership Interest in Boston Options Exchange Group, LLC
and Order Granting Accelerated Approval of the Proposed Rule Change, as
Modified by Amendment No. 1; Notice of Filing of Amendment No. 1 to a
Proposed Rule Change by the Boston Stock Exchange Clearing Corporation
Relating to Amendment of Its Articles of Organization and By-Laws in
Connection With the Planned Acquisition by The NASDAQ OMX Group, Inc.,
and Order Granting Accelerated Approval of the Proposed Rule Change, as
Modified by Amendment No. 1
August 7, 2008.
I. Introduction
On April 21, 2008, the Boston Stock Exchange, Inc. (``BSE'') filed
with the Securities and Exchange Commission (``Commission'' or ``SEC'')
a proposed rule change, pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4 thereunder \2\ to:
(1) Amend and restate the BSE Certificate in its entirety to reflect
the planned acquisition of BSE by The NASDAQ OMX Group, Inc. (``NASDAQ
OMX''), the parent corporation of The NASDAQ Stock Market LLC
(``Nasdaq''); (2) replace the BSE Constitution in its entirety with
proposed new BSE By-Laws; (3) adopt a written operating agreement for
its subsidiary, Boston Options Exchange Regulation, LLC (``BOXR''), and
amend the BOXR By-Laws; (4) obtain approval for a change of control of
BSX Group, LLC (``BSX''), which would operate, upon Commission approval
of certain proposed rule changes, BSE's equities trading facility, and
make related amendments to the Operating Agreement of BSX; (5) adopt
two rules; and (6) obtain Commission approval for the affiliation
between BSE and certain broker-dealer subsidiaries of NASDAQ OMX
(collectively, the ``BSE Governance Proposal''). The BSE Governance
Proposal was published for comment in the Federal Register on May 8,
2008.\3\ The Commission received no comments on the BSE Governance
Proposal. On July 28, 2008, BSE filed Amendment No. 1 to the BSE
Governance Proposal.\4\ This order provides notice of and requests
comment on Amendment No. 1 to the BSE Governance Proposal and approves
the BSE Governance Proposal, as modified by Amendment No. 1, on an
accelerated basis.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 57757 (May 1, 2008),
73 FR 26159 (SR-BSE-2008-23) (``BSE Governance Proposal Notice'').
\4\ In Amendment No. 1 to the BSE Governance Proposal, BSE filed
NASDAQ OMX's Certificate and By-Laws, as proposed to be amended in
connection with the acquisition of BSE by NASDAQ OMX, and proposed
to make a non-substantive correction in the purpose section of the
original filing. See infra note 104 and accompanying text.
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On April 23, 2008, BSE filed with the Commission a proposed rule
change (``BOX Transfer Proposal'') to transfer its ownership interest
in the Boston Options Exchange Group, LLC (``BOX''), the operator of
BSE's Boston Options Exchange facility (``BOX Market''), to MX U.S. 2,
Inc. (``MX US''), a wholly-owned U.S. subsidiary of the Montr[eacute]al
Exchange Inc. (``MX''), and to amend the BOX LLC Agreement. The BOX
Transfer Proposal was published for comment in the Federal Register on
May 8, 2008.\5\ The Commission received no comments on the BOX Transfer
Proposal. On July 28, 2008, BSE filed Amendment No. 1 to the BOX
Transfer Proposal.\6\ This order provides notice of and requests
comment on Amendment No. 1 to the BOX Transfer Proposal and approves
the BOX Transfer Proposal, as modified by Amendment No. 1, on an
accelerated basis.
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\5\ See Securities Exchange Act Release No. 57762 (May 1, 2008),
73 FR 26170 (SR-BSE-2008-25) (``BOX Transfer Proposal Notice'').
\6\ In Amendment No. 1 to the BOX Transfer Proposal, BSE
proposes to clarify Section 8.4(g) of the BOX LLC Agreement.
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On April 23, 2008, BSE filed with the Commission a proposed rule
change (``BSE Interim Certificate Proposal'') to amend the BSE
Certificate to permit BSE to make distributions to BSE membership
owners in connection with the transfer of its ownership interest in
[[Page 46937]]
BOX. The BSE Interim Certificate Proposal was published for comment in
the Federal Register on May 7, 2008.\7\ The Commission received no
comment letters regarding the BSE Interim Certificate Proposal. On July
28, 2008, BSE filed Amendment No. 1 to the BSE Interim Certificate
Proposal.\8\ This order approves the BSE Interim Certificate Proposal
as modified by Amendment No. 1.
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\7\ See Securities Exchange Act Release No. 57760 (May 1, 2008),
73 FR 25809 (SR-BSE-2008-02) (``BSE Interim Certificate Proposal
Notice'').
\8\ In Amendment No. 1 to the BSE Interim Certificate Proposal,
BSE proposes to correct typographical errors in the proposed
amendments to the current BSE Certificate. Because Amendment No. 1
is technical in nature, the Commission is not publishing it for
comment.
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On April 24, 2008, the Boston Stock Exchange Clearing Corporation
(``BSECC'') filed with the Commission a proposed rule change (``BSECC
Governance Proposal''). The BSECC Governance Proposal was published for
comment in the Federal Register on May 13, 2008.\9\ The Commission
received no comments on the BSECC Governance Proposal. On July 28,
2008, BSECC filed Amendment No. 1 to the BSECC Governance Proposal.\10\
This order provides notice of and requests comment on Amendment No. 1
to the BSECC Governance Proposal and approves the BSECC Governance
Proposal, as modified by Amendment No. 1, on an accelerated basis.
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\9\ See Securities Exchange Act Release No. 57782 (May 6, 2008),
73 FR 27583 (SR-BSECC-2008-01) (``BSECC Governance Proposal
Notice'').
\10\ In Amendment No. 1 to the BSECC Governance Proposal, BSECC
filed NASDAQ OMX's Certificate and NASDAQ OMX's By-Laws, as proposed
to be amended in connection with the acquisition of BSE by NASDAQ
OMX. See infra note 258 and accompanying text.
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II. Discussion and Commission Findings
After careful review, the Commission finds that the BSE Interim
Certificate Proposal, the BSE Governance Proposal, and the BOX
Ownership Transfer Proposal are consistent with the requirements of the
Act and the rules and regulations thereunder applicable to a national
securities exchange.\11\ Specifically, the Commission finds that these
proposed rule changes are consistent with Section 6(b)(5) of the
Act,\12\ 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. The Commission also finds
that these proposed rule changes are consistent with Section 6(b)(1) of
the Act,\13\ 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 regulations thereunder, and the rules of the
exchange; Section 6(b)(3) of the Act,\14\ 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; and
Section 6(b)(7) of the Act,\15\ which requires, in part, that the rules
of an exchange provide a fair procedure for disciplining members.
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\11\ In approving these proposed rule changes, the Commission
has considered the proposed rule's impact on efficiency,
competition, and capital formation. 15 U.S.C. 78c(f).
\12\ 15 U.S.C. 78f(b)(5).
\13\ 15 U.S.C. 78f(b)(1).
\14\ 15 U.S.C. 78f(b)(3).
\15\ 15 U.S.C. 78f(b)(7).
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The Commission also finds that the BSECC Governance Proposal is
consistent with Section 17A(b)(3)(C) of the Act,\16\ which requires, in
part, that the rules of a registered clearing agency assure the fair
representation of its shareholders (or members) and participants in the
selection of its board of directors and administration of its affairs.
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\16\ 15 U.S.C. 78q-1(b)(3)(C).
---------------------------------------------------------------------------
The discussion below does not review every detail of each of the
proposed rule changes, but focuses on the most significant rules and
policy issues considered by the Commission in reviewing the proposals.
NASDAQ OMX, the parent corporation of Nasdaq, and BSE have entered
into an agreement pursuant to which NASDAQ OMX would acquire all of the
outstanding membership interests in BSE (``BSE Acquisition'').\17\
Following the BSE Acquisition, BSE would be a wholly-owned subsidiary
of NASDAQ OMX. The BSE Acquisition would have the effect of: (1)
converting BSE, a registered national securities exchange, from a
Delaware, non-stock corporation into a Delaware stock corporation; and
(2) demutualizing BSE by separating equity ownership in BSE from
trading privileges on BSE. BSE members would receive cash as
consideration for their ownership interests in BSE and would not retain
any ownership interest in BSE or its affiliates. NASDAQ OMX plans that
BSE would operate as a separate self-regulatory organization (``SRO'')
with rules, memberships, and listings that are separate and distinct
from those of Nasdaq.\18\
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\17\ See BSE Governance Proposal Notice, supra note 3, 73 FR
26159.
\18\ See Securities Exchange Act Release No. 57761 (May 1,
2008), 73 FR 26182, at 26183 (SR-NASDAQ-2008-035) (``NASDAQ OMX By-
Laws Proposal Notice'').
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BSE has four affiliates: BSX, BOX, BOXR, and BSECC. BSE owns 53.21
percent of BSX, which operated the Boston Equities Exchange (``BeX'')
until BeX ceased operations in September 2007.\19\ The remaining 46.79
percent of BSX is owned by Citigroup Financial Strategies Inc., Credit
Suisse First Boston Next Fund Inc., LB 1 Group, Inc., Fidelity Global
Brokerage Group, Inc., and Merrill Lynch L.P. Holdings Inc. Following
the BSE Acquisition, NASDAQ OMX indirectly would own, through its
ownership of BSE, the 53.21 percent of BSX that BSE would continue to
own. In addition, NASDAQ OMX would acquire the 46.79 percent interest
in BSX that is not presently owned by BSE. Consequently, BSX would
become a wholly-owned subsidiary of NASDAQ OMX.\20\
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\19\ See infra note 222.
\20\ See BSE Governance Proposal Notice, supra note 3, 73 FR at
26159. See also infra notes 222-244 and accompanying text.
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NASDAQ OMX would not acquire BSE's interest in BOX, the transfer of
which to a third party is a condition to the closing of the BSE
Acquisition.\21\ BSE proposes to transfer its 21.87 percent ownership
interest in BOX to MX US, a wholly-owned subsidiary of MX.\22\ BSE
intends to distribute the proceeds from the BOX transfer to its member
owners by redeeming a portion of each BSE member ownership for a pro
rata share of the net proceeds.\23\ Although BSE no longer would hold
an ownership interest in BOX, as discussed in greater detail below,\24\
the BOX Market would remain a facility of BSE and, therefore, BSE would
continue to have self-regulatory obligations with respect to the BOX
Market.\25\
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\21\ See BSE Interim Certificate Proposal Notice, supra note 7,
73 FR at 25810.
\22\ See BOX Transfer Proposal Notice, supra note 5, 73 FR at
26170.
\23\ See BSE Interim Certificate Proposal Notice, supra note 7,
73 FR at 25810.
\24\ See infra notes 124-136 and accompanying text.
\25\ 15 U.S.C. 78c(a)(2). See also BOX Transfer Proposal Notice,
supra note 5, 73 FR at 26171.
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Finally, BOXR and BSECC are wholly-owned subsidiaries of BSE and,
[[Page 46938]]
therefore, following the BSE Acquisition would become wholly-owned,
indirect subsidiaries of NASDAQ OMX.\26\
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\26\ See BSECC Governance Proposal Notice, supra note 9, 73 FR
at 27583.
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Following the BSE Acquisition, Nasdaq OMX would own five SROs:
Nasdaq, BSE, BSECC, Philadelphia Stock Exchange, Inc. (``Phlx'') and
Stock Clearing Corporation of Philadelphia (``SCCP'').\27\ As discussed
below, the Commission believes that the ownership of BSE and BSECC by
the same public holding company that owns Nasdaq, Phlx, and SCCP would
not impose any burden on competition not necessary or appropriate in
furtherance of the Act's purposes.\28\ The Commission previously has
approved proposals in which a holding company owns multiple SROs.\29\
However, the BSE Acquisition is the first instance in which the
Commission is approving the ownership by one holding company of three
exchanges and two clearing agencies.\30\ The Commission's experience to
date with the issues raised by the ownership by a holding company of
one or more SROs has not presented any concerns that have not been
addressed, for example, by Commission-approved measures at the holding
company level that are designed to protect the independence of each
SRO.\31\
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\27\ See Securities Exchange Act Release No. 57703 (April 23,
2008), 73 FR 23293 (April 29, 2008) (SR-Phlx-2008-31) (notice of
proposed rule change related to NASDAQ OMX's acquisition of Phlx
(``Phlx Acquisition'')). See also Securities Exchange Act Release
No. 57818 (May 14, 2008), 73 FR 29171 (May 20, 2008) (SR-SCCP-2008-
01) (notice of proposed rule change to amend and restate the
Articles of Incorporation of the Stock Clearing Corporation of
Philadelphia (``SCCP'') in connection with the Phlx Acquisition).
See also Securities Exchange Act Release Nos. 58179 (July 17, 2008),
73 FR 42874 (July 23, 2008) (order approving SR-Phlx-2008-31) and
58180 (July 17, 2008), 73 FR 42890 (July 23, 2008) (order approving
SR-SCCP-2008-01).
\28\ 15 U.S.C. 78f(b)(8) and 15 U.S.C. 78q-1(b)(3)(I).
\29\ See, e.g., Securities Exchange Act Release Nos. 53382
(February 27, 2006), 71 FR 11251 (March 6, 2006) (SR-NYSE-2005-77)
(approving proposed rule change relating to the combination of the
New York Stock Exchange, Inc. and Archipelago Holdings, Inc.);
58179, supra note 27.
\30\ The Depository Trust and Clearing Corporation (``DTCC'') is
a holding company that at one point owned five registered clearing
agencies: The National Securities Clearing Corporation (``NSCC''),
the Depository Trust Company (``DTC''), the Government Securities
Clearing Corporation (``GSCC''), the MBS Clearing Corporation
(``MBSCC''), and the Emerging Markets Clearing Corporation
(``EMCC''). See Securities Exchange Act Release Nos. 41786 (August
24, 1999), 64 FR 47882 (September 1, 1999) (SR-DTC-99-17); 41800
(August 27, 1999), 64 FR 48694 (September 7, 1999) (SR-NSCC-99-10);
44987 (October 25, 2001), 66 FR 55218 (November 1, 2001) (SR-EMCC-
2001-03); 44988 (October 25, 2001), 66 FR 55222 (November 1, 2001)
(SR-MBSCC-2001-01); and 44989 (October 25, 2001), 66 FR 55220
(November 1, 2001) (SR-GSCC-2001-11). These clearing agencies
provided clearance and settlement services for different instruments
or provided different clearance and settlement services for the same
instruments. The GSCC and the MBSCC have since merged to form the
Fixed Income Clearing Corporation (``FICC''). See Securities
Exchange Act Release No. 47015 (December 17, 2002), 67 FR 78531
(December 24, 2002) (SR-GSCC-2002-09 and SR-MBSCC-2002-01). The EMCC
no longer operates as a clearing agency.
\31\ See infra notes 38-47, 258-261 and accompanying text for a
discussion of proposals by BSE and BSECC to adopt NASDAQ OMX's By-
Laws as part of their rules. See also Securities Exchange Act
Release No. 58183 (July 17, 2008), 73 FR 42850 (July 23, 2008)
(order approving SR-NASDAQ-2008-035) (``NASDAQ OMX By-Laws Approval
Order'').
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The Commission believes that the current market for cash equity
trading venues is highly competitive. Existing exchanges face
significant competition from other exchanges and from non-exchange
entities such as alternative trading systems that trade the same or
similar financial instruments.\32\ New entrants to the market do not
face significant barriers to entry. In this regard, the Chicago Board
Options Exchange, Incorporated and the International Securities
Exchange, LLC a few years ago commenced trading of cash equity
securities.\33\ In addition, other entities have recently applied for
exchange registration, which provides evidence that they have
determined there are benefits in starting a new exchange to compete in
the marketplace.\34\ In addition, since BeX ceased operating in
September 2007, BSE has zero market share in cash equity trading, and
prior to September 2007, BSE had a very small market share. Therefore,
the BSE Acquisition would not change the number of active exchanges or
the distribution of market share across exchanges. Accordingly, the
Commission finds that the BSE's proposed rule changes are consistent
with Section 6(b)(8), which requires that the rules of an exchange not
impose any burden on competition not necessary or appropriate in
furtherance of the purposes of the Act.
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\32\ See, e.g., Securities Exchange Act Release No. 58092 (July
3, 2008), 73 FR 40144 (July 11, 2008), in which the Commission
recognized that ``[n]ational securities exchanges registered under
Section 6(a) of the Exchange Act face increased competitive
pressures from entities that trade the same or similar financial
instruments * * *.''
\33\ See Securities Exchange Act Release Nos. 55389 (March 2,
2007), 72 FR 10575 (March 8, 2007) (order approving the
establishment of CBOE Stock Exchange, LLC); 55392 (March 2, 2007),
72 FR 10572 (March 8, 2007) (order approving trading rules for non-
option securities trading on CBOE Stock Exchange, LLC); 54528
(September 28, 2006), 71 FR 58650 (October 4, 2006) (order approving
rules governing ISE's electronic trading system for equities).
\34\ See Securities Exchange Act Release No. 57322 (February 13,
2008), 73 FR 9370 (February 20, 2008) (File No. 10-182) (notice of
application and Amendment No. 1 thereto by BATS Exchange, Inc. for
registration as a national securities exchange).
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With regard to NASDAQ OMX's ownership of two registered clearing
agencies following the BSE Acquisition, the Commission does not believe
the acquisition of BSECC and SCCP by NASDAQ OMX would reduce
competition with respect to the clearance and settlement of securities
transactions. The Commission notes that NSCC currently provides
clearance and settlement services and a central counterparty guarantee
for virtually all trades on the New York Stock Exchange LLC, Nasdaq,
the American Stock Exchange LLC and for all regional exchanges,
electronic communications networks and alternative trading systems in
the U.S.\35\ In September 2007, BSECC ceased processing trades and
currently provides only limited account maintenance services to its
participants. SCCP continues to forward trades to NSCC for clearance
and settlement.\36\ The Commission will continue to evaluate the
competitive environment should the operations of either BSECC or SCCP
expand, taking into account the maintenance of fair competition among
brokers and dealers, clearing agencies, and transfer agents.\37\ For
these reasons, the Commission finds that the BSECC's proposed rule
change is consistent with Section 17A(b)(3)(I), which requires that the
rules of a clearing agency not impose any burden on competition not
necessary or appropriate in furtherance of the purpose of the Act.
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\35\ See Annual Report for the Depository Trust and Clearing
Corporation for 2007, page 14. NSCC is a subsidiary of the DTCC, as
are the FICC and the DTC.
\36\ In recent years, both BSECC and SCCP have forwarded all
trades to NSCC for clearance and settlement.
\37\ See 15 U.S.C. 78q-1(a)(2)(A).
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Finally, the Commission will continue to monitor holding companies'
ownership of multiple SROs for compliance with the Act, the rules and
regulations thereunder, as well as the SRO's own rules.
A. BSE
1. Relationship Between NASDAQ OMX and BSE; Jurisdiction Over NASDAQ
OMX
After the BSE Acquisition, BSE would become a subsidiary of NASDAQ
OMX. Although NASDAQ OMX is not itself an SRO, its activities with
respect to the operation of BSE must be consistent with, and must not
interfere with, the self-regulatory obligations of BSE. NASDAQ OMX's
By-Laws make applicable to all of NASDAQ OMX's SRO subsidiaries,
including BSE (after
[[Page 46939]]
the BSE Acquisition), certain provisions of NASDAQ OMX's Certificate
and NASDAQ OMX's By-Laws that are designed to maintain the independence
of each of its SRO subsidiaries' self-regulatory function, enable each
SRO subsidiary to operate in a manner that complies with the federal
securities laws, and facilitate the ability of each SRO subsidiary and
the Commission to fulfill their regulatory and oversight obligations
under the Act.\38\
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\38\ Provisions of NASDAQ OMX's Certificate and By-Laws are
rules of BSE and BSECC because they are stated policies, practices,
or interpretations of BSE and BSECC, pursuant to Section 19(b) of
the Act and Rule 19b-4 thereunder. Accordingly, BSE and BSECC filed
them with the Commission. See Amendment No. 1 to the BSE Governance
Proposal, supra note 4, and Amendment No. 1 to the BSECC Governance
Proposal, supra note 10 and infra note 258 and accompanying text.
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The By-Laws of NASDAQ OMX specify that NASDAQ OMX and its officers,
directors, employees, and agents irrevocably submit to the jurisdiction
of the United States federal courts, the Commission, and each self-
regulatory subsidiary of NASDAQ OMX for the purposes of any suit,
action or proceeding pursuant to the United States federal securities
laws, and the rules and regulations thereunder, arising out of, or
relating to, the activities of any self-regulatory subsidiary.\39\
Further, NASDAQ OMX agreed to provide the Commission with access to its
books and records.\40\ NASDAQ OMX also agreed to keep confidential non-
public information relating to the self-regulatory function of BSE and
not to use such information for any non-regulatory purpose.\41\ In
addition, the NASDAQ OMX Board, as well as its officers, employees, and
agents are required to give due regard to the preservation of the
independence of BSE's self-regulatory function.\42\ Similarly, the
NASDAQ OMX Board, when evaluating any issue, would be required to take
into account the potential impact on the integrity, continuity, and
stability of its SRO subsidiaries.\43\ Finally, the NASDAQ OMX By-Laws
require that any changes to the NASDAQ OMX Certificate and By-Laws be
submitted to the Board of Directors of each of its SRO subsidiaries,
including BSE, and, if such amendment is required to be filed with the
Commission pursuant to Section 19(b) of the Act, such change shall not
be effective until filed with, or filed with and approved by, the
Commission.
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\39\ See proposed Section 12.3, NASDAQ OMX By-Laws.
\40\ See proposed Section 12.1(c), NASDAQ OMX By-Laws. To the
extent that they relate to the activities of BSE, all books,
records, premises, officers, directors, and employees of NASDAQ OMX
would be deemed to be those of the BSE. See id.
\41\ See proposed Section 12.1(b), NASDAQ OMX By-Laws. This
requirement to keep confidential non-public information relating to
the self-regulatory function is designed to prevent attempts to
limit the Commission's ability to access and examine such
information or limit the ability of directors, officers, or
employees of NASDAQ OMX from disclosing such information to the
Commission. See id. Other holding companies with SRO subsidiaries
have undertaken similar commitments. See, e.g., Securities Exchange
Act Release No. 56955 (December 13, 2007), 72 FR 71979, at 71983
(December 19, 2007) (SR-ISE-2007-101) (order approving the
acquisition of International Securities Exchange, LLC's parent,
International Securities Exchange Holdings, Inc., by Eurex Frankfurt
AG).
\42\ See Section 12.1(a), NASDAQ OMX By-Laws.
\43\ See proposed Section 12.7, NASDAQ OMX By-Laws.
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The Commission believes that the NASDAQ OMX By-Laws, as amended to
accommodate the BSE Acquisition, are designed to facilitate the BSE's
ability to fulfill its self-regulatory obligations and are, therefore,
consistent with the Act. In particular, the Commission believes these
changes are consistent with Section 6(b)(1) of the Act,\44\ 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 regulations thereunder, and the rules of the exchange.
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\44\ 15 U.S.C. 78f(b)(1).
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Under Section 20(a) of the Act,\45\ any person with a controlling
interest in NASDAQ OMX would be jointly and severally liable with and
to the same extent that NASDAQ OMX is liable under any provision of the
Act, unless the controlling person acted in good faith and did not
directly or indirectly induce the act or acts constituting the
violation or cause of action. In addition, Section 20(e) of the Act
\46\ creates aiding and abetting liability for any person who knowingly
provides substantial assistance to another person in violation of any
provision of the Act or rule thereunder. Further, Section 21C of the
Act \47\ authorizes the Commission to enter a cease-and-desist order
against any person who has been ``a cause of'' a violation of any
provision of the Act through an act or omission that the person knew or
should have known would contribute to the violation.
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\45\ 15 U.S.C. 78t(a).
\46\ 15 U.S.C. 78t(e).
\47\ 15 U.S.C. 78u-3.
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2. BSE Certificate
In the BSE Governance Proposal, BSE proposes to amend and restate
the BSE Certificate in its entirety. The restated BSE Certificate would
provide for the issuance of 1,000 shares of common stock (``BSE Common
Stock''), all of which would be held by NASDAQ OMX.\48\ The restated
BSE Certificate would further provide that NASDAQ OMX may not transfer
or assign any shares of BSE Common Stock, in whole or in part, to any
entity, unless such transfer or assignment is filed with and approved
by the Commission under Section 19 of the Act and the rules promulgated
thereunder.\49\ In addition, the restated BSE Certificate would contain
provisions relating to the BSE board of directors (``BSE Board'')
including that the total number of directors (``BSE Directors'')
constituting the BSE Board would be fixed from time to time by NASDAQ
OMX, as the sole stockholder, and would be elected by NASDAQ OMX to
hold office until their respective successors have been duly elected
and qualified.\50\ Of particular importance are the BSE Board
composition requirements in the BSE By-Laws relating to independence
and fair representation of members.\51\ Finally, the restated BSE
Certificate would specifically provide that BSE's business would
include actions that support its regulatory responsibilities under the
Act.\52\
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\48\ See Article Fourth, restated BSE Certificate.
\49\ Id.
\50\ See Article Fifth, restated BSE Certificate.
\51\ See infra notes 53-84 and accompanying text.
\52\ See Article Third, restated BSE Certificate.
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The Commission finds that the BSE Certificate, as proposed to be
amended and restated, is consistent with the Act, and, in particular,
with Sections 6(b)(1) and 6(b)(3) of the Act. The Commission believes
that the restated BSE Certificate is designed to allow BSE to exercise
those powers necessary to carry out the purposes of the Act and ensure
compliance by its members with the Act and BSE rules. The Commission
further believes that the restriction on the transfer or assignment of
any shares of BSE Common Stock without Commission approval would
minimize the potential that a person could improperly interfere with or
restrict the ability of the Commission, BSE, or BOXR to carry out their
regulatory responsibilities under the Act.
3. Proposed New BSE By-Laws
In the BSE Governance Proposal, the BSE proposes to replace its
Constitution with new BSE By-Laws. The new BSE By-Laws reflect NASDAQ
OMX's expectation that BSE would be operated with governance,
regulatory, and market structures similar to those of Nasdaq.
[[Page 46940]]
Key provisions of these new BSE By-Laws are discussed below.
The property, business, and affairs of BSE would be managed under
the direction of the BSE Board.\53\ The exact number of BSE Directors
would be determined by NASDAQ OMX, as the sole stockholder, but in no
event would the BSE Board have fewer than ten directors.\54\
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\53\ See Article IV, BSE By-Laws.
\54\ See Section 4.2, BSE By-Laws. In addition, no decrease in
the number of BSE Directors would shorten the term of any incumbent
BSE Director. See Article Fifth, restated BSE Certificate.
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Moreover, the number of Non-Industry Directors,\55\ including at
least three Public Directors \56\ and at least one BSE Director
representative of issuers and investors,\57\ would have to equal or
exceed the sum of the number of Industry Directors \58\ and Member
Representative Directors.\59\ Further, at least 20% of the BSE
Directors would have to be Member Representative Directors and, as is
currently the case, one Industry Director would have to be selected as
a representative of a firm or organization that is registered with BSE
for the purposes of participating in options trading on the BOX Market
(``BOX Participant Director'').\60\ A BSE Director could not be subject
to a statutory disqualification.\61\ The new BSE By-Laws also permit up
to two officers of BSE, who would otherwise be considered Industry
Directors, to be designated as Staff Directors,\62\ and thereby be
excluded from the definition of Industry Director.\63\
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\55\ ``Non-Industry Director'' is a BSE Director (excluding
Staff Directors) who is: (i) A Public Director; (ii) an officer or
employee of an issuer of securities listed on BSE; or (iii) any
other individual who would not be an Industry Director. See Article
I(bb), BSE By-Laws.
\56\ ``Public Director'' is a BSE Director who has no material
business relationship with a broker or a dealer, BSE or its
affiliates, or FINRA. See Article I(gg), BSE By-Laws.
\57\ See Section 4.3(a), BSE By-Laws. The BSE Director
representative of issuers and investors would be nominated by the
Nominating and Governance Committee and elected by NASDAQ OMX as the
sole stockholder. See Sections 4.4(a) and 4.14(b), BSE By-Laws.
\58\ ``Industry Director'' is a person who: (i) Is or has served
in the prior three years as an officer, director, or employee of a
broker or dealer, excluding an outside director or a director not
engaged in the day-to-day management of a broker or dealer; (ii) is
an officer, director (excluding an outside director), or employee of
an entity that owns more than 10% of the equity of a broker or
dealer, and the broker or dealer accounts for more than 5% of the
gross revenues received by the consolidated entity; (iii) owns more
than 5% of the equity securities of any broker or dealer, whose
investments in brokers or dealers exceed 10% of his or her net
worth, or whose ownership interest otherwise permits him or her to
be engaged in the day-to-day management of a broker or dealer; (iv)
provides professional services to brokers or dealers, and such
services constitute 20% or more of the professional revenues
received by the Industry Director or 20% or more of the gross
revenues received by the Industry Director's firm or partnership;
(v) provides professional services to a director, officer, or
employee of a broker, dealer, or corporation that owns 50% or more
of the voting stock of a broker or dealer, and such services relate
to the director's, officer's, or employee's professional capacity
and constitute 20% or more of the professional revenues received by
the Industry Director or 20% or more of the gross revenues received
by the Industry Director's firm or partnership; or (vi) has a
consulting or employment relationship with or provides professional
services to BSE or any affiliate thereof or to FINRA or has had any
such relationship or provided any such services at any time within
the prior three years. See Article I(t), BSE By-Laws.
\59\ See Section 4.3(a), BSE By-Laws. ``Member Representative
Director'' is a BSE Director who has been elected by NASDAQ OMX as
the sole stockholder after having been nominated by the Member
Nominating Committee or voted upon by BSE members pursuant to the
BSE By-Laws (or elected by the stockholders without such nomination
or voting in the case of the initial Member Representative Directors
elected pursuant to Section 4.3(b) of the BSE By-Laws). See Article
I(x), BSE By-Laws.
\60\ See Section 4.4, BSE By-Laws, and Section 14, BOXR By-Laws.
\61\ See Section 4.3(a), BSE By-Laws.
\62\ ``Staff Director'' is a BSE Director, selected at the sole
discretion of the BSE Board, who is an officer of BSE. See Article
I(g), BSE By-Laws.
\63\ The exclusion of Staff Directors from the definition of
Industry Director is consistent with provisions previously approved
by the Commission. See Securities Exchange Act Release No. 53128
(January 13, 2006), 71 FR 3550 (January 23, 2006) (order approving
application of Nasdaq for registration as a national securities
exchange) (``Nasdaq Exchange Approval Order''). See also Securities
Exchange Act Release No. 44280 (May 8, 2001), 66 FR 26892 (May 15,
2001) (order approving amendment to the National Association of
Securities Dealers (``NASD'') By-Laws to allow for the treatment of
Staff Governors as ``neutral'' for purposes of Industry/Non-Industry
balancing on the NASD Board of Governors).
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The initial BSE Board would be selected by NASDAQ OMX, as the sole
stockholder, immediately following the BSE Acquisition. NASDAQ OMX
would hold a special meeting (or sign a consent in lieu thereof) for
the purpose of electing the BSE Board. The initial BSE Board would
satisfy the compositional requirements in the BSE By-Laws.\64\
Specifically, the initial BSE Board would consist of at least three
Public Directors, one or two Staff Directors, at least two Member
Representative Directors,\65\ an Industry Director representing BOX
Participants,\66\ at least one Non-Industry Director representative of
issuers and investors, and such additional Industry and Non-Industry
Directors as NASDAQ OMX, as the sole stockholder, deems appropriate,
consistent with the compositional requirements of the BSE By-Laws.\67\
As soon as practicable after election of the initial BSE Board, BSE
would hold its annual meeting for the purpose of electing directors in
accordance with the procedures set forth in the BSE By-Laws.\68\ For
subsequent boards, BSE Directors, other than the Member Representative
Directors and the BOX Participant Director,\69\ would be nominated by a
Nominating Committee appointed by the BSE Board \70\ and then elected
by NASDAQ OMX as sole stockholder.\71\
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\64\ See Section 4.3(b), BSE By-Laws.
\65\ The initial Member Representative Directors would be
officers, directors, or employees of BSE members. See BSE Governance
Proposal Notice, supra note 3, at 73 FR 26162.
\66\ ``BOX Participant'' is a firm or organization that is
registered with BOX for purposes of participating in options trading
on the BOX Market as an order flow provider or market maker. See
Section 1.1, 6th BOX LLC Agreement. See also BOX Rules, Chapter II.
\67\ See Section 4.3(b), BSE By-Laws. See also BSE Governance
Proposal Notice, supra note 3, 73 FR at 26162.
\68\ Id. Specifically, in accordance with Section 14.4(b) of the
BSE By-Laws, the initial BSE Board selected by NASDAQ OMX would
appoint a Nominating Committee and Member Nominating Committee, and
such committees would nominate candidates for election pursuant to
the procedures set forth in Section 4.4 of the BSE By-Laws, which
process is described below. Telephone conversation between John
Yetter, Vice President and Deputy General Counsel, Nasdaq, and Nancy
Burke-Sanow, Assistant Director, and Jennifer Dodd, Special Counsel,
Division of Trading and Markets, Commission, on June 11, 2008. In
Amendment No. 1 to the BSE Governance Proposal, BSE states that the
initial BSE Board will populate the Committees of the BSE Board and
BSE's standing committees in accordance with the compositional
requirements of Sections 4.13 and 4.14 of the BSE By-Laws. See
Amendment No. 1 to the BSE Governance Proposal, supra note 4. The
Commission notes that this would include the initial Nominating
Committee and Member Nominating Committee. See Section 4.14(b), BSE
By-Laws.
\69\ See infra notes 207-216 and accompanying text for a
description of the nomination and election process for the BOX
Participant Director who would serve on the BSE Board.
\70\ See Section 4.14(b), BSE By-Laws.
\71\ See Section 4.4(a), BSE By-Laws.
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The BSE Board also would appoint a Member Nominating Committee
composed of no fewer than three and no more than six members.\72\ All
members of the Member Nominating Committee would be associated persons
of a current BSE member. The BSE Board would appoint such individuals
after appropriate consultation with representatives of BSE members. The
Member Nominating Committee would nominate candidates for the Member
Representative Director positions to be filled. The candidates
nominated by the Member Nominating Committee would be included on a
formal list of candidates (``List of Candidates'').
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\72\ See Section 4.14, BSE By-Laws.
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BSE members may nominate additional candidates for inclusion on the
List of Candidates by submitting, within the prescribed timeframe that
is based on the preceding year's voting date (``Voting Date''),\73\ a
timely written
[[Page 46941]]
petition executed by the authorized representatives of 10% or more of
all BSE members. If there is only one candidate for each Member
Representative Director seat by the date on which a BSE member may no
longer submit a timely nomination, the Member Representative Directors
would be elected by NASDAQ OMX directly from the List of Candidates
nominated by the Member Nominating Committee. If the number of
candidates on the List of Candidates exceeds the number of Member
Representative Director positions to be filled, there would be a
Contested Vote,\74\ in which case each BSE member would have the right
to cast one vote for each Member Representative Director position to be
filled.\75\ The persons on the List of Candidates who receive the most
votes would be submitted to NASDAQ OMX for election,\76\ and NASDAQ OMX
would elect those candidates.\77\
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\73\ The Voting Date is a date selected by the BSE Board for BSE
members to vote with respect to Member Representative Directors in
the event there is more than one candidate for a Member
Representative Director position (``Contested Vote''). As described
below, the BSE Board would select a Voting Date each year. However,
a vote would be conducted on the Voting Date only in the event of
Contested Vote. See BSE Governance Proposal Notice, supra note 3, 73
FR at 26161, n.11.
In Amendment No. 1 to the BSE Governance Proposal, BSE states
that: ``In order to make the intent of this definition clearer,
immediately following the closing of the [BSE Acquisition], [BSE]
will propose to the newly constituted Board of the Exchange an
amendment to the definition to read as follows: `` `Voting Date'
means the date selected by the Board on an annual basis, on which
[BSE members] may vote with respect to Member Representative
Directors in the event of a Contested Vote.'' Following approval by
the [BSE] Board, [BSE] will immediately file the amendment as a
proposed rule change for approval by the Commission. This clarifying
change could not be included in this filing because Article XX of
[BSE's] current Constitution, which is being replaced by the
proposed [BSE] By-Laws, provides that [BSE's] members must approve
amendments to the [BSE] Constitution. The [BSE] members voted, on
December 4, 2007, to approve the [BSE] By-Laws as submitted in this
filing and it would have been impracticable and unduly expensive to
seek a second member vote for approval of this clarifying change.
Following adoption of the new By-Laws, the [BSE] Board will have
authority to approve By-Law amendments.'' See Amendment No. 1 to the
BSE Governance Proposal, supra note 4.
Also, in the case of the first annual meeting held pursuant to
the new BSE By-Laws, a nomination for the Member Representative
Director positions would be considered timely if delivered not
earlier than the close of business on the later of the 120th day
prior to the first Voting Date and not later than the close of
business on the 90th day prior to the first Voting Date, or the 10th
day following the day on which public announcement of such Voting
Date is first made. See BSE Governance Proposal Notice, supra note
3, 73 FR at 26161, n.12. See also Section 4.4(d), BSE By-Laws.
\74\ See Section 1(k), BSE By-Laws.
\75\ In Amendment No. 1 to the BSE Governance Proposal, BSE
states that: ``In order to limit the influence that a single
affiliated group of members might exercise over [BSE], immediately
following the closing of the [BSE Acquisition], [BSE] will propose
to the newly constituted [BSE Board] an amendment to stipulate that
no [BSE member], either alone or together with its affiliates, may
account for more than 20% of the votes cast for a candidate, and any
votes cast by such [BSE member], either alone or together with its
affiliates, in excess of such 20% limitation shall be disregarded.
Following approval by the [BSE] Board, [BSE] will immediately file
the amendment as a proposed rule change for approval by the
Commission. This clarifying change could not be included in this
filing because Article XX of [BSE's] current Constitution, which is
being replaced by the proposed [BSE] By-Laws, provides that [BSE's]
members must approve amendments to the Constitution. The members
voted, on December 4, 2007, to approve the By-Laws as submitted in
this filing and it would have been impracticable and unduly
expensive to seek a second member vote for approval of this
clarifying change. Following adoption of the new [BSE] By-Laws, the
[BSE] Board will have authority to approve [BSE] By-Law
amendments.'' See Amendment No. 1 to the BSE Governance Proposal,
supra note 4.
\76\ See Section 4.4(f), BSE By-Laws.
\77\ See Section 4.4(b), BSE By-Laws.
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The Commission finds that the proposed changes regarding the
composition of the BSE Board are consistent with the Act, including
Section 6(b)(1) of the Act,\78\ which requires, among other things,
that a national securities exchange be organized to carry out the
purposes of the Act and comply with the requirements of the Act. The
Commission previously has stated its belief that the inclusion of
public, non-industry representatives on exchange oversight bodies is
critical to an exchange's ability to protect the public interest.\79\
Further, public representatives help to ensure that no single group of
market participants has the ability to systematically disadvantage
other market participants through the exchange governance process. The
Commission believes that public directors can provide unique, unbiased
perspectives, which should enhance the ability of the BSE Board to
address issues in a non-discriminatory fashion and foster the integrity
of BSE. The Commission also finds that the composition of the BSE Board
satisfies Section 6(b)(3) of the Act,\80\ which requires that one or
more directors be representative of issuers and investors and not be
associated with a member of the exchange or with a broker or dealer.
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\78\ 15 U.S.C. 78f(b)(1).
\79\ See Regulation of Exchanges and Alternative Trading
Systems, Securities Exchange Act Release No. 40760 (December 8,
1998), 63 FR 70844 (December 22, 1998). See also Securities Exchange
Act Release Nos. 53382, supra note 29, 71 FR at 11261 n.121 and
accompanying text; 53128, supra note 63, 71 FR at 3553, n.54 and
accompanying text; and 44442 (June 18, 2001), 66 FR 33733, n.13 and
accompanying text, (June 25, 2001) (SR-PCX-01-03).
\80\ 15 U.S.C. 78f(b)(3).
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The fair representation requirement in Section 6(b)(3) of the Act
is intended to give members a voice in the selection of the exchange's
directors and the administration of its affairs. The Commission finds
that the requirement under BSE By-Laws that at least 20% of the BSE
Directors represent members,\81\ and the process for selecting Member
Representative Directors, are designed to ensure the fair
representation of BSE members on the BSE Board. The Commission believes
that the method for selecting Member Representative Directors on the
BSE Board allows members to have a voice in BSE's use of its self-
regulatory authority.\82\ In particular, the Commission notes that the
Member Nominating Committee is composed solely of persons associated
with BSE members and is selected after consultation with
representatives of BSE members. In addition, the BSE By-Laws include a
process by which members can directly petition and vote for
representation on the BSE Board. The Commission therefore finds that
the process for selecting Member Representative Directors to the BSE
Board is consistent with Section 6(b)(3) of the Act.\83\ The Commission
also notes that these provisions are consistent with previous proposals
approved by the Commission.\84\
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\81\ See Section 4.3(a), BSE By-Laws.
\82\ In addition, the BSE By-Laws provide that one BSE Director
would represent BOX Participants. See infra notes 207-216 and
accompanying text for a description of the nomination and election
process for the BOX Participant Director who would serve on the BSE
Board.
\83\ 15 U.S.C. 78f(b)(3).
\84\ See, e.g., Securities Exchange Act Release Nos. 58179,
supra note 27; 53128, supra note 63; and 49098 (January 16, 2004),
69 FR 3974 (January 27, 2004) (order approving the demutualization
of Phlx).
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4. Committees
The proposed new BSE By-Laws would include provisions governing the
composition and authority of various BSE committees established by the
BSE Board.\85\ The BSE By-Laws would establish several standing BSE
Board committees that are composed solely of BSE Directors and would
delineate their general duties and compositional requirements.\86\
These committees are the Executive Committee, the Finance Committee,
the Management Compensation Committee, the Audit Committee, and the
Regulatory Oversight Committee (``BSE ROC''). In addition to these
committees, the BSE By-Laws provide for the appointment by the BSE
Board of certain standing committees, not composed solely of BSE
Directors, to administer various provisions of the rules that BSE
expects to propose with respect to governance,
[[Page 46942]]
listing, equity trading, and member discipline.\87\ These committees
include the Member Nominating Committee, the Nominating Committee, the
BSE Listing and Hearings Review Council, the BSE Review Council, the
Quality of Markets Committee, the Market Operations Review Committee,
the Arbitration and Mediation Committee, and the Market Regulation
Committee.
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\85\ See Sections 4.12-4.14, BSE By-Laws.
\86\ See Section 4.13, BSE By-Laws.
\87\ See Section 4.14 and Articles VI-VII, BSE By-Laws.
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As noted above, all members of the Member Nominating Committee must
be associated persons of a BSE member. In addition, at least 20% of the
members of the BSE Listing and Hearings Review Council, the BSE Review
Council, the Quality of Markets Committee, and the Market Operations
Review Committee must be composed of Member Representatives. Moreover,
the Nominating Committee, the BSE Review Council, the Quality of
Markets Committee, the Arbitration and Mediation Committee, and the
Market Regulation Committee must be compositionally balanced between
Industry members \88\ and Non-Industry members.\89\ These compositional
requirements are designed to ensure that members are protected from
unfair, unfettered actions by an exchange pursuant to its rules, and
that, in general, an exchange is administered in a way that is
equitable to all those who trade on its market or through its
facilities. The Commission believes that the proposed compositional
balance of these BSE committees is consistent with the Section 6(b)(3)
of the Act because it provides for the fair representation of BSE
members in the administration of the affairs of BSE.\90\
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\88\ See Article I(u), BSE By-Laws.
\89\ See Article I(cc), BSE By-Laws.
\90\ See, e.g., Securities Exchange Act Release Nos. 58179,
supra note 27; 53128, supra note 63; and 49098, supra note 84.
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5. Regulatory Oversight Responsibilities and Regulatory Funds
The BSE By-Laws would provide that the BSE Board, when evaluating
any proposal, would, to the fullest extent permitted by applicable law,
take into account: (i) the potential impact thereof on the integrity,
continuity, and stability of BSE and the other operations of BSE, on
the ability to prevent fraudulent and manipulative acts and practices
and on investors and the public, and (ii) whether such would promote
just and equitable principles of trade, foster cooperation and
coordination with persons engaged in regulating, clearing, settling,
processing information with respect to and facilitating transactions in
securities, or assist in the removal of impediments to or perfection of
the mechanisms for a free and open market and a national market
system.\91\ Taken together, these provisions reinforce the notion that
BSE, while wholly-owned by NASDAQ OMX, is not solely a commercial
enterprise, but rather is an SRO registered pursuant to the Act and
subject to the obligations imposed by the Act.
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\91\ See Section 4.9, BSE By-Laws.
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The BSE ROC would be composed of Public Directors, each of whom
also would need to qualify as an independent director pursuant to
Nasdaq Rule 4200.\92\ The BSE ROC would be responsible for monitoring
the adequacy and effectiveness of BSE's regulatory program and
assisting the BSE Board in reviewing BSE's regulatory plan and the
overall effectiveness of BSE's regulatory functions.\93\ BSE also would
have a Chief Regulatory Officer (``BSE CRO'') who would have general
supervision of the BSE's regulatory operations, including
responsibility for overseeing BSE's surveillance, examination, and
enforcement functions and for administering any regulatory services
agreements with another SRO to which BSE is a party.\94\ The BSE CRO
would have to meet with the BSE ROC in executive session at regularly
scheduled meetings of such committee and at any time upon request of
the BSE CRO or any member of the BSE ROC. The BSE CRO could also serve
as the General Counsel of BSE.\95\
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\92\ See Section 4.13(e), BSE By-Laws.
\93\ Id.
\94\ See Section 5.10, BSE By-Laws.
\95\ Id. The Commission has previously approved a similar
structure. See Nasdaq Exchange Approval Order, supra note 63, 71 FR
at 3555, n.103 and accompanying text (order approving application of
Nasdaq for registration as a national securities exchange, including
the ability of the CRO to serve as General Counsel).
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In addition, the BSE By-Laws would contain a stipulation that
dividends could not be paid to the stockholders using regulatory funds,
which are fees, fines, or penalties derived from the regulatory
operations of BSE.\96\ This restriction on the use of regulatory funds
is intended to preclude BSE from using its authority to raise
regulatory funds for the purpose of benefiting its shareholders, or for
other non-regulatory purposes, such as executive compensation.
Regulatory funds, however, would not be construed to include revenues
derived from listing fees, market data revenues, transaction revenues,
or any other aspect of the commercial operations of BSE, even if a
portion of such revenues are used to pay costs associated with the
regulatory operations of BSE.\97\
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\96\ See Section 9.8, BSE By-Laws. See also Section 1(ii), BSE
By-Laws.
\97\ The Commission further notes that the BSX Operating
Agreement is being amended to adopt a restriction on distributions
of regulatory funds comparable to the restriction proposed for
inclusion in the BSE By-Laws. See proposed Section 9.2, BSX
Operating Agreement.
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Section 6(b)(1) of the Act \98\ requires an exchange to be so
organized and have the capacity to be able to carry out the purposes of
the Act. The Commission believes that BSE's regulatory structure is
designed to insulate its regulatory functions from its market and other
commercial interests so that it can carry out its regulatory
obligations and, therefore, BSE's proposal is consistent with the Act.
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\98\ 15 U.S.C. 78f(b)(1).
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6. Restrictions on Affiliation Between BSE and Its Members: Proposed
BSE Chapter XXXIX
a. Limitations on BSE Members' Ownership of NASDAQ OMX
In connection with the transaction, in the BSE Governance Proposal,
BSE proposes to add a new Chapter XXXIX, Section 1 to the BSE Rules to
prohibit BSE members and persons associated with BSE members from
beneficially owning more than 20% of the then-outstanding voting
securities of NASDAQ OMX. Members that trade on an exchange
traditionally have had ownership interests in such exchange. As the
Commission has noted in the past, however, 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.\99\ A member that is a
controlling shareholder of an exchange or an exchange's holding company
might be tempted to exercise that controlling influence by pressuring
or directing the exchange to refrain from, or the exchange otherwise
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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\99\ See, e.g., Securities Exchange Act Release Nos. 57478
(March 12, 2008), 73 FR 14521, 14523 (March 18, 2008) (SR-NASDAQ-
2007-004 and SR-NASDAQ-2007-080) (``NOM Approval Order''); 55389,
supra note 33, 72 FR at 10578; 55293 (February 14, 2007), 72 FR
8033, 8037 (February 22, 2007) (SR-NYSE-2006-120); 53382, supra note
29, 71 FR at 11256; 51149 (February 8, 2005), 70 FR 7531, 7538
(February 14, 2005) (SR-CHX-2004-26); 49718 (May 17, 2004), 69 FR
29611, 29624 (May 24, 2004) (SR-PCX-2004-08); 49098, supra note 84,
69 FR at 3986; 49067 (January 13, 2004), 69 FR 2761, 2767 (January
20, 2004) (SR-BSE-2003-19) (``BOX LLC Agreement Order''); and Nasdaq
Exchange Approval Order, supra note 63, 71 FR at 3552.
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In addition, the NASDAQ OMX Certificate imposes limits on direct
and
[[Page 46943]]
indirect changes in control, which are designed to prevent any
shareholder from exercising undue control over the operation of its SRO
subsidiaries and to ensure that its SRO subsidiaries 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 of NASDAQ OMX in excess of 5% of the
securities generally entitled to vote may vote shares in excess of
5%.\100\ This limitation would mitigate the potential for any NASDAQ
OMX shareholder to exercise undue control over the operations of the
BSE and facilitate BSE's and the Commission's ability to carry out
their regulatory obligations under the Act.
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\100\ See Article Fourth.C., NASDAQ OMX Certificate.
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The NASDAQ OMX Board may approve exemptions from the 5% 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,\101\ provided that the NASDAQ OMX
Board also determines that granting such exemption would be consistent
with the self-regulatory obligations of Nasdaq.\102\ Further, any such
exemption from the 5% voting limitation would not be effective until
approved by the Commission pursuant to Section 19 of the Act.\103\ The
BSE Governance Proposal reflects an amendment to the NASDAQ OMX By-Laws
to require the NASDAQ OMX Board, prior to approving any exemption from
the 5% voting limitation, to determine that granting such exemptions
would also be consistent with BSE's self-regulatory obligations.\104 \
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\101\ 15 U.S.C. 78c(a)(39). See Article Fourth.C.6., NASDAQ OMX
Certificate.
\102\ Specifically, the NASDAQ OMX Board must determine that
granting such exemption would (1) not reasonably be expected to
diminish the quality of, or public confidence in, NASDAQ OMX or
Nasdaq or the other operations of NASDAQ OMX and its subsidiaries,
on the ability to prevent fraudulent and manipulative acts and
practices on investors and the public, and (2) promote just and
equitable principles of trade, foster cooperation and coordination
with persons engaged in regulating, clearing, settling, processing
information with respect to and facilitating transactions in
securities or assist in the removal of impediments to or perfection
of the mechanisms for a free and open market and a national market
system. See Article Fourth.C.6, NASDAQ OMX Certificate.
\103\ See Section 12.5, NASDAQ OMX By-Laws.
\104\ See Amendment No. 1 to the BSE Governance Proposal, supra
note 4. Specifically, the NASDAQ OMX Board must determine that
granting such exemption would (1) not reasonably be expected to
diminish the quality of, or public confidence in, NASDAQ OMX or its
SRO Subsidiaries or the other operations of NASDAQ OMX and its
subsidiaries, on the ability to prevent fraudulent and manipulative
acts and practices on investors and the public, and (2) promote just
and equitable principles of trade, foster cooperation and
coordination with persons engaged in regulating, clearing, settling,
processing information with respect to and facilitating transactions
in securities or assist in the removal of impediments to or
perfection of the mechanisms for a free and open market and a
national market system. See proposed Section 12.5, NASDAQ OMX By-
Laws.
--------------------