Joint Industry Plan; Order Approving the National Market System Plan for the Selection and Reservation of Securities Symbols Submitted by the Chicago Stock Exchange, Inc., The Nasdaq Stock Market, Inc., National Association of Securities Dealers, Inc. (n/k/a Financial Industry Regulatory Authority, Inc.), National Stock Exchange, Inc., and Philadelphia Stock Exchange, Inc., 67218-67235 [E8-26880]
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and increases the accessibility of the
certificates to both Commission staff
and interested investors. Commission
staff estimates that on an annual basis
it takes: (i) 1 hour of clerical time to
prepare and file Form N–17f–1; and (ii)
0.5 hour for the fund’s chief compliance
officer to review Form N–17f–1 prior to
filing with the Commission, for a total
of 1.5 hours. Each fund is required to
make 3 filings annually, for a total
annual burden per fund of
approximately 4.5 hours.1 Commission
staff estimates that an average of 5 funds
currently file Form N–17f–1 with the
Commission 3 times each year, for a
total of 15 responses annually.2 The
total annual hour burden for Form N–
17f–1 is therefore estimated to be
approximately 22.5 hours.3
The estimate of average burden hours
is made solely for the purposes of the
Paperwork Reduction Act, and is not
derived from a comprehensive or even
a representative survey or study of the
costs of Commission rules. Compliance
with the collections of information
required by Form N–17f–1 is mandatory
for funds that place their assets in the
custody of a national securities
exchange member. Responses will not
be kept confidential. An agency may not
conduct or sponsor, and a person is not
required to respond to a collection of
information unless it displays a
currently valid control number.
The Commission requests written
comments on: (a) Whether the
collections of information are necessary
for the proper performance of the
functions of the Commission, including
whether the information has practical
utility; (b) the accuracy of the
Commission’s estimate of the burdens of
the collection of information; (c) ways to
enhance the quality, utility, and clarity
of the information collected; and (d)
ways to minimize the burden of the
collection of information on
respondents, including through the use
of automated collection techniques or
other forms of information technology.
Consideration will be given to
comments and suggestions submitted in
writing within 60 days of this
publication.
Please direct your written comments
to Lewis W. Walker, Acting Director/
CIO, Securities and Exchange
Commission, C/O Shirley Martinson,
1 This estimate is based on the following
calculation: (1.5 hours × 3 responses annually = 4.5
hours).
2 This estimate is based on a review of Form N–
17f–1 filings made with the Commission over the
last three years.
3 This estimate is based on the following
calculations: (4.5 hours × 5 funds = 22.5 total
hours).
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6432 General Green Way, Alexandria,
VA 22312; or send an e-mail to:
PRA_Mailbox@sec.gov.
Dated: November 5, 2008.
Florence E. Harmon,
Acting Secretary.
[FR Doc. E8–26958 Filed 11–12–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–58904; File No. 4–533]
Joint Industry Plan; Order Approving
the National Market System Plan for
the Selection and Reservation of
Securities Symbols Submitted by the
Chicago Stock Exchange, Inc., The
Nasdaq Stock Market, Inc., National
Association of Securities Dealers, Inc.
(n/k/a Financial Industry Regulatory
Authority, Inc.), National Stock
Exchange, Inc., and Philadelphia Stock
Exchange, Inc.
November 6, 2008.
I. Introduction
On July 17, 2007, the Commission
published for comment 1 a detailed
summary of two proposed plans for the
purpose of the selection and reservation
of securities symbols: the FiveCharacters Plan and the ThreeCharacters Plan. On January 25, 2008,
the Commission published Amendment
No. 1 to the Three-Characters Plan for
public comment.2 The proposed plans
were filed jointly by two different
groups of self-regulatory organizations
(‘‘SROs’’) pursuant to Rule 608 of
Regulation NMS under the Securities
Exchange Act of 1934 (‘‘Act’’) (‘‘Rule
608’’).3 The Chicago Stock Exchange,
Inc. (‘‘CHX’’), The Nasdaq Stock Market,
Inc. (‘‘Nasdaq’’), National Association of
Securities Dealers, Inc. (‘‘NASD’’)
(n/k/a Financial Industry Regulatory
Authority, Inc. (‘‘FINRA’’)),4 National
Stock Exchange, Inc. (‘‘NSX’’), and
1 See Securities Exchange Act Release No. 56037
(July 10, 2007), 72 FR 39096 (File Nos. 4–533 and
4–534) (‘‘Symbology Notice’’). The full text of each
plan is also available to interested persons on the
Commission’s Web site at https://www.sec.gov/rules/
sro/nms.shtml#4-534 and https://www.sec.gov/rules/
sro/nms.shtml#4-533, respectively.
2 See Securities Exchange Act Release No. 57171
(January 18, 2008), 73 FR 4645.
3 17 CFR 242.608.
4 On July 26, 2007, the Commission approved a
proposed rule change filed by NASD to amend
NASD’s Certificate of Incorporation to reflect its
name change to Financial Industry Regulatory
Authority Inc., or FINRA, in connection with the
consolidation of the member firm regulatory
functions of NASD and NYSE Regulation, Inc. See
Securities Exchange Act Release No. 56146 (July 26,
2007), 72 FR 42190 (August 1, 2007) (SR–NASD–
2007–053).
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Philadelphia Stock Exchange, Inc.
(‘‘Phlx’’) filed the Five-Characters Plan.5
The American Stock Exchange LLC
(‘‘Amex’’), Chicago Board Options
Exchange, Incorporated (‘‘CBOE’’),
International Securities Exchange, LLC
(‘‘ISE’’), the New York Stock Exchange
LLC (‘‘NYSE’’), and NYSE Arca, Inc.
(‘‘NYSE Arca’’) filed the ThreeCharacters Plan.6
Although the two plans are identical
in many respects, they differ on several
significant matters. The primary
difference between the two plans is
their scope. The Three-Characters Plan
would only cover one-, two-, and threecharacter symbols; the Five-Characters
Plan would cover one-, two-, three-,
four-, and five-character symbols. In
addition, the plans differ with regard to
the parties that are eligible to join the
plan; the reservation rights for perpetual
and limited-time reservations; the
portability of symbols for issuers that
move their listing from one market to
another; the allocation of costs relating
to the plan; and the process of
withdrawing from the plan.
The Commission received 61
comments on the proposed plans from
56 commenters.7 Twenty-two
5 FINRA, Nasdaq, NSX, and Phlx filed the FiveCharacters Plan with the Commission on March 23,
2007. CHX, FINRA, Nasdaq, NSX, and Phlx filed a
Supplement to this proposed plan on April 23,
2007. In the Supplement, CHX joined as a party
proposing the Five-Characters Plan.
6 On March 23, 2007, Amex, NYSE and NYSE
Arca filed the Three-Characters Plan with the
Commission. In Amendment No. 1 to the ThreeCharacters Plan, filed on August 3, 2007, CBOE and
ISE joined as parties to the proposed plan.
7 Letters to the Commission from Edward F.
Tancer, Vice President & General Counsel, FPL
Group, Inc., dated March 28, 2007 (‘‘FPL Letter’’);
Jason Korstange, SVP, Director of Corporate
Communications, TCF Financial Corporation, dated
March 28, 2007 (‘‘TCF Letter’’); Timothy J.
O’Donovan, Chairman of the Board, Chief Executive
Officer, Wolverine World Wide, Inc., dated March
28, 2007 (‘‘Wolverine Letter’’); Leo Liebowitz,
Chairman and Chief Executive Officer, Getty Realty
Corp., dated March 29, 2007 (‘‘Getty Letter’’);
Edward W. Moore, Vice President, General Counsel
& Secretary, RPM International Inc., dated March
29, 2007 (‘‘RPM Letter’’); Cathy Burzik, President
and Chief Executive Officer, Kinetic Concepts, Inc.,
dated March 30, 2007 (‘‘KCI Letter’’); Clifton H.
Morris, Jr., Chairman, AmeriCredit Corp., dated
April 2, 2007 (‘‘AmeriCredit Letter’’); David M.
Brain, President and CEO, Entertainment Properties
Trust, dated April 3, 2007 (‘‘Entertainment
Properties Letter’’); Steven S. Fishman, Chairman,
Chief Executive Officer and President, Big Lots,
Inc., dated April 4, 2007 (‘‘Big Lots Letter’’); Mary
J. McGinn, Secretary and Deputy General Counsel,
The Allstate Corporation, dated April 5, 2007
(‘‘Allstate Letter’’); Eric W. Nodiff, Sr. V.P. and
General Counsel, Cantel Medical Corp., dated April
9, 2007 (‘‘Cantel Letter’’); James C. Smith, Chairman
and CEO, Webster Financial Corporation, dated
April 16, 2007 (‘‘Webster Letter’’); Michael
Tenenbaum, PE, Trustee, Strategic Technologies
Employees Pension Fund Trust, dated May 2, 2007
(‘‘Strategic Technologies Letter’’); Craig D. Mallick,
Corporate Secretary, United States Steel
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Corporation, dated May 4, 2007 (‘‘U.S. Steel
Letter’’); Bart J. Ward, Chief Executive Officer, Ward
& Company, dated May 8, 2007 (‘‘Ward Letter’’);
Jack Sennott, Senior Vice President and Chief
Financial Officer, Darwin Professional
Underwriters, Inc., dated May 8, 2007 (‘‘Darwin
Letter’’); James J. Angel, Ph.D., CFA, Associate
Professor of Finance, McDonough School of
Business, Georgetown University, dated May 9,
2007 (‘‘Angel Letter I’’); M. Farooq Kathwari,
Chairman, President and CEO, Ethan Allen
Interiors, Inc., dated May 9, 2007 (‘‘Ethan Allen
Letter’’); Carol Kaufman, Sr. VP Legal Affairs, The
Cooper Companies, Inc., dated May 14, 2007
(‘‘Cooper Letter’’); Jack R. Hartung, Chief Finance
and Development Officer, Chipotle Mexican Grill,
Inc., dated May 15, 2007 (‘‘Chipotle Letter’’); Larry
A. Mizel, Chairman of the Board and Chief
Executive Officer, M.D.C. Holdings, Inc., dated May
17, 2007 (‘‘MDC Letter’’); Will Matthews, dated May
21, 2007 (‘‘Matthews Letter’’); Stephen M. Klein,
J.D., Chairman and Chief Executive Officer, Omni
National Bank, dated May 21, 2007 (‘‘Omni Letter’’);
Edward J. Resch, Executive Vice President, Chief
Financial Officer and Treasurer, State Street
Corporation, dated May 21, 2007 (‘‘State Street
Letter’’); Faith Pomeroy-Ward, Manager, Investor
Relations, Adams Respiratory Therapeutics, dated
May 22, 2007 (‘‘Adams Letter’’); Shayn Carlson,
Director of Investor Relations, G&K Services, dated
May 22, 2007 (‘‘G&K Letter’’); Alan R. Spachman,
dated May 22, 2007 (‘‘Spachman Letter’’); Mark L.
Heimbouch, Chief Financial Officer and EVP,
Jackson Hewitt Tax Service Inc., dated July 10, 2007
(‘‘Jackson Hewitt Letter’’); Daniel R. Coker,
President & CEO, Amerigon Incorporated, dated
July 31, 2007 (‘‘Amerigon Letter’’); Betsy Atkins,
dated August 2, 2007 (‘‘Atkins Letter’’); Eric A.
Blanchard, Senior Vice President, General Counsel
and Secretary, United Stationers Supply Company,
dated August 3, 2007 (‘‘United Stationers Letter’’);
Albert A. Pimentel, Executive Vice President and
Chief Financial Officer, Glu Mobile Inc., dated
August 3, 2007 (‘‘Glu Letter’’); Ryan Ellis, Executive
Director, American Shareholders Association, dated
August 3, 2007 (‘‘ASA Letter’’); Rick Stewart, CEO,
Amarin Corporation plc, dated August 9, 2007
(‘‘Amarin Letter’’); Steve Bene, Senior Vice
President and General Counsel, Electronic Arts Inc.,
dated August 9, 2007 (‘‘Electronic Arts Letter’’);
Bing Yeh, President & CEO, Silicon Storage
Technology, Inc., dated August 10, 2007 (‘‘Silicon
Storage Letter’’); Kathy Lanterman, Senior Vice
President and Chief Financial Officer, Silicon
Graphics, Inc., dated August 9, 2007 (‘‘SGI Letter’’);
Paul Jennings, President and CEO, Innospec Inc.,
dated August 10, 2007 (‘‘Innospec Letter’’); Harry
W. Kellogg, Jr., Vice Chairman, SVB Financial
Group, dated August 10, 2007 (‘‘SVB Letter’’); Arlen
W. Gelbard, Chief Administrative Officer and
General Counsel, E*Trade, dated August 10, 2007
(‘‘E*Trade Letter’’); MDS Office, Sobha Developers
Ltd, dated August 10, 2007 (‘‘Sobha Letter’’); John
Ritchie, Chief Financial Officer, Electronics For
Imaging, dated August 10, 2007 (‘‘EFI Letter’’); Adi
Bar-Lev, Director of IR, Top Image Systems Ltd.,
dated August 13, 2007 (‘‘Top Image Letter’’); Lonnie
R. Brock, CFO, Double Eagle Petroleum Co., dated
August 13, 2007 (‘‘Double Eagle Letter’’); Joe
Ovsenek, Senior Vice President, Corporate, Silver
Standard Resources Inc., dated August 15, 2007
(‘‘Silver Standard Letter’’); James J. Angel, Ph.D.,
CFA, Associate Professor of Finance, McDonough
School of Business, Georgetown University, dated
August 16, 2007 (‘‘Angel Letter II’’); Manisha
Kimmel, Executive Director, Financial Information
Forum, dated August 23, 2007 (‘‘FIF Letter I’’);
Patrick J. Healy, Issuer Advisory Group, dated
September 6, 2007 (‘‘Issuer Advisory Letter’’); S.
Lee Clifford, President and CEO, SFB Market
Systems, dated September 25, 2007 (‘‘SFB Letter’’);
Joan C. Conley, Senior Vice President and Corporate
Secretary, The NASDAQ Stock Market LLC, dated
November 2, 2007 (‘‘Nasdaq Letter I’’); Barbara
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17:13 Nov 12, 2008
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commenters generally supported the
Three-Characters Plan or aspects
thereof,8 while 22 commenters generally
supported the Five-Characters Plan or
aspects thereof.9 The remaining 12
commenters did not expressly support
one plan or another.10
This order approves the FiveCharacters Plan, with changes and
subject to conditions as the Commission
deems necessary or appropriate, thus
authorizing CHX, FINRA, Nasdaq, NSX,
and Phlx to act jointly to implement the
Five-Characters Plan, as modified
herein, as a means of facilitating a
national market system in accordance
with the requirements of Section 11A of
the Act.11 This order also requires,
within 60 days of this approval order,
that any SRO that chooses to list
securities or to designate securities for
quoting on a quotation medium to join
the Five-Characters Plan, as modified
herein, and to act jointly with CHX,
Sweeney, Senior Vice President and Corporate
Secretary, The Financial Industry Regulatory
Authority, Inc., dated November 27, 2007 (‘‘FINRA
Letter’’); Mary Yeager, Assistant Secretary, New
York Stock Exchange, LLC, dated January 15, 2008
(‘‘NYSE Letter’’); James J. Angel, Ph.D., CFA,
Associate Professor of Finance, McDonough School
of Business, Georgetown University, dated February
13, 2008 (‘‘Angel Letter III’’); Manisha Kimmel,
Executive Director, Financial Information Forum,
dated February 14, 2008 (‘‘FIF Letter II’’); Marianne
Brown, Chief Executive Officer, Omgeo, LLC, dated
February 15, 2008 (‘‘Omgeo Letter’’); Joan Conley,
Senior Vice President & Corporate Secretary, The
NASDAQ Stock Market LLC, dated February 26,
2008 (‘‘Nasdaq Letter II’’); John Panchery, Managing
Director, Art Trager, Vice President, and Ann Vlcek,
Managing Director and Associate General Counsel,
Securities Industry and Financial Markets
Association, dated February 28, 2008 (‘‘SIFMA
Letter’’); Julian Rainero, Partner, Bracewell &
Guiliani LLP, dated March 10, 2008 (‘‘Bracewell &
Guiliani Letter’’); Jamie Shay, Head of SWIFT
Standards, Society for Worldwide Interbank
Financial Telecommunication, dated March 18,
2008 (‘‘SWIFT Letter’’); Scott Atwell, FPL Global
Steering Committee Co-Chair, FIX Protocol, dated
March 24, 2008 (‘‘FIX Letter’’); and Thomas P.
Moran, Associate Vice President & Associate
General Counsel, Nasdaq, dated March 26, 2008
(‘‘Nasdaq Letter III’’).
8 See FPL Letter, TCF Letter, Wolverine Letter,
Getty Letter, Kinetic Concepts Letter, AmeriCredit
Letter, Entertainment Properties Letter, Big Lots
Letter, Allstate Letter, Cantel Letter, Webster Letter,
Strategic Technologies Letter, U.S. Steel Letter,
Ward Letter, Darwin Letter, Ethan Allen Letter,
Cooper Letter, Chipotle Letter, MDC Letter, State
Street Letter, Jackson Hewitt Letter, and NYSE
Letter.
9 See Matthews Letter, Omni Letter, Adams
Letter, G&K Letter, Amerigon Letter, Atkins Letter,
United Stationers Letter, Glu Letter, ASA Letter,
Amarin Letter, Electronic Arts Letter, Silicon
Storage Letter, SGI Letter, Innospec Letter, SVB
Letter, E*Trade Letter, Sobha Letter, EFI Letter, Top
Image Letter, Double Eagle Letter, Silver Standard
Letter, Nasdaq Letter I, and Nasdaq Letter II.
10 See RPM Letter, Angel Letter I, Angel Letter II,
Angel Letter III, Spachman Letter, FIF Letter I, FIF
Letter II, Issuer Advisory Letter, SFB Letter, FINRA
Letter, Omgeo Letter, SIFMA Letter, Bracewell &
Guiliani Letter, SWIFT Letter, and FIX Letter.
11 15 U.S.C. 78k–1. See also 17 CFR 242.608(b)(2).
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FINRA, Nasdaq, NSX, and Phlx to
implement the approved plan.12 The
approved Five-Characters Plan is
attached here as Appendix A.
II. Background
A. Section 11A of the Act
In 1975, Congress directed the
Commission, through the enactment of
Section 11A of the Act,13 to facilitate the
establishment of a national market
system to link together the individual
markets that trade securities. Congress
found the development of a national
market system to be in the public
interest and appropriate for the
protection of investors and the
maintenance of fair and orderly markets
to assure fair competition among the
exchange markets.14 Section
11A(a)(3)(B) of the Act directs the
Commission, ‘‘by rule or order, to
authorize or require self-regulatory
organizations to act jointly with respect
to matters as to which they share
authority under this title in planning,
developing, operating, or regulating a
national market system (or a subsystem
thereof) or one or more facilities.’’ 15 The
Commission’s approval of a national
market system plan is conditioned upon
a finding that the proposed plan is
‘‘necessary or appropriate in the public
interest, for the protection of investors
and the maintenance of fair and orderly
markets, to remove impediments to, and
perfect the mechanism of, a national
market system, or otherwise in
furtherance of the purposes of the
Act.’’ 16
B. Limited Symbol Supply
Pursuant to Rule 601 of Regulation
NMS under the Act,17 all SROs are
required to report every trade in listed
equity securities 18 and Nasdaq
securities 19 made through their
facilities, and to make such information
public. Each SRO reports every
transaction to the ticker tape using the
ticker symbol for that security, the
volume of the trade, and the price of the
trade. Currently, there are three ticker
tapes: Tape A reports the stocks that are
listed on NYSE, Tape B reports the
12 15
U.S.C. 78k–1(a)(3)(B).
U.S.C. 78k–1.
14 15 U.S.C. 78k–1(a)(1)(C).
15 15 U.S.C. 78k–1(a)(3)(B).
16 17 CFR 242.608(b)(2). See also 15 U.S.C. 78k–
1(a).
17 17 CFR 242.601.
18 17 CFR 242.600(b)(34) defines ‘‘listed equity
security’’ as ‘‘any equity security listed and
registered, or admitted to unlisted trading
privileges, on a national securities exchange.’’
19 17 CFR 242.600(b)(41) defines ‘‘Nasdaq
security’’ as ‘‘any registered security listed on The
Nasdaq Stock Market, Inc.’’
13 15
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stocks that are listed on Amex, as well
as securities listed on any other national
securities exchange (except securities
also listed on NYSE and Nasdaq), and
Tape C reports the stocks that are listed
on Nasdaq. Tapes A and B disseminate
market information pursuant to the
Consolidated Tape Association Plan
(‘‘CTA Plan’’), while Tape C
disseminates market information
pursuant to the Nasdaq Unlisted
Trading Privileges Plan.
Securities symbols are a key element
in the operation of a national market
system and essential to the
dissemination of trade information in a
common format. The term ‘‘ticker
symbol’’ originates from the ticker
tape.20 Prior to the introduction of the
ticker, it was customary for messengers
to manually disseminate quotations.21
In 1867, an employee of the NYSE
developed the stock ticker.22 A system
of symbols and abbreviations developed
as the only practical method for
reporting transactions, because the full
description of the issuer, security,
number of shares sold, the price, and
other market data would slow the
dissemination of trade information so
that the ticker would fall behind the
market.23 In December 1966, the ticker
tape was fully automated.24
Recently, concerns about the scarcity
of available symbols have highlighted
the need for a symbol reservation
national market system plan to
efficiently and fairly manage symbol
supply. As the securities markets have
grown over the years, the availability of
one-, two-, and three-character symbols
has diminished.25 Several factors have
been increasing the demand for one-,
two-, and three-character symbols. In
recent years, exchanges have begun
listing new and innovative products,
such as exchange-traded funds, that are
20 The ticker tape started in 1867, when all trades
made on an exchange were sent out by telegraph
and printed on a piece of paper. Although the
process is now automated, the securities industry
participants continue to refer to the electronic
reporting of information as the ‘‘tape.’’ See Hal
McIntyre, How the US Securities Industry Works,
194–95 (The Summit Group Press) (2000).
21 See S. S. Huebner, Ph.D., Sc.D., The Stock
Market, 218 (Appleton-Century-Crofts, Inc.) (1934).
22 E.A. Calahan. See George L. Leffler, Ph.D., The
Stock Market, 162 (The Ronald Press Company)
(1951).
23 See note 21 supra at 222. The first ticker was
very slow and not practical, until Thomas A.
Edison, another employee of the NYSE, improved
its speed and efficiency. See note 22 supra at 162.
24 See Richard J. Teweles and Edward S. Bradley,
The Stock Market, 148 (John Wiley & Sons, Inc.)
(1998).
25 There are 26 combinations for one-character
symbols, 676 combinations for two-character
symbols, and 17,576 combinations for threecharacter symbols, for a total of 18,278 one-,
two-, and three-character symbols.
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18:08 Nov 12, 2008
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now competing with listed companies
for symbols.
In addition, Nasdaq, which when
operated as a facility of NASD (n/k/a
FINRA) 26 only listed securities with
four- and five-character symbols, has
begun using two- and three-character
symbols and has expressed its desire to
use one-character symbols as well for
Nasdaq-listed issuers. It has been the
practice of the NYSE to list companies
using one-, two-, and three-character
symbols and of other exchanges
(including Amex and regional
exchanges) to list companies using twoand three-character symbols. Until
recently, Nasdaq was the only listing
market that did not assign securities
one-, two-, or three-character symbols;
instead, Nasdaq had assigned securities
it listed four- and five-character
symbols. In November 2005, however,
Nasdaq announced its intention to begin
listing companies with one-, two-, and
three-character symbols.27 Since that
time, Nasdaq has made a series of
announcements detailing its plans, and
has worked with the industry to test
trading systems to ensure the proper
functionality for such symbols.28 In
March 2007, Nasdaq filed with the
Commission a proposed rule change to
allow companies transferring their
listings to Nasdaq to retain their threecharacter symbols.29 And, in April
2008, Nasdaq filed with the Commission
an immediately effective proposed rule
change to allow an issuer with a twocharacter symbol to transfer its listing to
Nasdaq and retain its two-character
symbol.30
26 Nasdaq began operations as a national
securities exchange in Nasdaq-listed securities on
August 1, 2006, and in non-Nasdaq-listed securities
on February 12, 2007. See https://www.nasdaq.com/
about/FAQsExchange.stm. See also Securities
Exchange Act Release No. 53128 (January 13, 2006),
71 FR 3550 (January 23, 2006) (File No. 10–131).
27 See Head Trader Alert 2005–133 (November 14,
2005), available at https://www.nasdaqtrader.com.
28 See e.g., Nasdaq Head Trader Alerts 2006–144
(September 29, 2006), 2006–193 (November 16,
2006), 2006–201 (December 6, 2006), and 2007–008
(January 25, 2007), each available at https://
www.nasdaqtrader.com.
29 See Securities Exchange Act Release No. 55563
(March 30, 2007), 72 FR 16391 (April 4, 2007) (SR–
NASDAQ–2007–031) (notice for the proposal to
allow three-character symbol portability for
companies transferring their listings to Nasdaq).
The Commission approved this proposal in July
2007. See Securities Exchange Act Release No.
56028 (July 9, 2007), 72 FR 38639 (July 13, 2007)
(‘‘Nasdaq Three-Character Portability Order’’). See
also Securities Exchange Act Release No. 55519
(March 26, 2007), 72 FR 15737 (April 2, 2007) (SR–
NASDAQ–2007–025) (allowing a single company,
Delta Financial Corp., to retain its three-character
symbol upon transferring its listing from Amex to
Nasdaq).
30 See Securities Exchange Act Release No. 57696
(April 22, 2008), 73 FR 22987 (April 28, 2008) (SR–
NASDAQ–2008–034). The Commission notes that
its approval of the Five-Characters Plan, as
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Finally, the proliferation of
standardized options has decreased the
availability of three-character
symbols.31 Developing a formal process
to reserve, select, and allocate symbols
fairly and efficiently among the listing
markets should help promote a fair and
orderly national market system and
protect investors.
C. Weaknesses in the Existing
Reservation System
Currently, the listing markets assign
securities symbols under an informal
understanding among the markets.
Under this system, each SRO keeps its
own records of reserved symbols. If an
SRO wishes to reserve a particular
symbol, the SRO will consult its own
list of reserved symbols and then, if it
believes that the symbol is available,
will notify the other SROs that it is
reserving that symbol. If no other SRO
objects, then the listing SRO has
successfully reserved that symbol and
each SRO would be responsible for
updating its own records of reserved
symbols accordingly.
There are several weaknesses in the
current informal system. The absence of
universal reservation records may lead
to confusion about the availability of
certain symbols and may result in
disputes between listing markets about
the availability of particular symbols.
Any such confusion or disagreement
between the listing markets could
disrupt the listing process or raise the
potential for symbol duplication and
investor confusion.
In addition, under the existing
system, listing markets may reserve an
excess amount of symbols indefinitely,
which could exacerbate the strain on
symbol supply. Market fears about
supply constraints and competition for
listings could drive listing markets to
reserve an excess amount of symbols,
either to protect their interests in the
event of needing such symbols in the
future or to give themselves advantages
over their competitors in securing future
listings. For example, a listing market
could use the existing symbol
reservation system to withhold unused
symbols from their competitors, trade
reserved symbols only with certain,
allied exchanges, or use their power to
modified herein, is consistent with this change and
with its approval of the Nasdaq Three-Character
Portability Order. See id. As discussed further
below, see infra notes 105–117 and accompanying
text, the approved plan would allow the automatic
portability of all one-, two-, three-, four-, and fivecharacter symbols of issuers transferring their
listing from one exchange to another.
31 The options exchanges have expressed their
intention to shift to a different symbology. See
https://www.theocc.com/initiatives/symbology/
default.jsp.
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withhold desired symbols to compel
other listing markets not to trade
symbols with their direct competitors.
Finally, the existing system does not
universally permit issuers transferring
their listing to a new exchange to keep
their ticker symbols. Thus, the original
listing market and the new listing
market for a transferred listing could
become embroiled in a dispute over the
right to use the issuer’s ticker symbol,
which could disrupt trading in that
security, and such uncertainty could
affect an issuer’s decision in selecting a
listing venue or moving from one venue
to another.
Disagreements over the use of
securities symbols have arisen in the
past. For example, in 1999, NYSE,
Amex, and Nasdaq were involved in a
dispute regarding the symbol ‘‘Q,’’
which Amex and Nasdaq planned to use
for the Nasdaq 100 Trust. However,
NYSE claimed that it had reserved that
symbol and sued to enjoin the use of
that symbol. Amex and Nasdaq
eventually agreed to use a different
symbol for the Nasdaq 100 Trust.32
These weaknesses in the existing
informal symbol reservation system
could potentially have significant
market consequences as exchanges
compete more aggressively for listings
and the supply of available symbols
becomes more restricted over time. For
this reason, the Commission believes
that it is necessary to adopt a national
market system plan for reserving and
allocating symbols among the SROs to
maintain fair and orderly markets.
Consistent with the principles of
Section 11A of the Act, in February
2005, Commission staff requested the
listing markets to commence joint
discussions to develop such a national
market system plan.33 A national market
system plan for symbology should
mitigate confusion or disagreement
about the rights to particular securities
symbols and should allow symbols to be
used in a manner that is efficient and
promotes competition between the
listing markets.
III. Discussion
In the notice publishing for comment
both the Three-Characters Plan and the
Five-Characters Plan, the Commission
asked for comments on whether it
should approve one or two plans. Four
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32 See,
e.g., Big Board Drops its Lawsuit Against
Amex, The New York Times, March 10, 1999,
Section C, p. 10.
33 See Letters from Annette L. Nazareth, then
Director of the Division of Market Regulation,
Commission, to Amex, Boston Stock Exchange
(‘‘BSE’’), CBOE, CHX, ISE, Nasdaq, NASD, NSX,
NYSE, Pacific Exchange (the predecessor to NYSE
Arca) and Phlx, dated February 7, 2005 (‘‘February
2005 Letters’’).
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17:13 Nov 12, 2008
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commenters provided feedback on this
issue and each supported the approval
of a single symbology plan.34 One of
these commenters stated that having
two different plans for short and long
tickers adds needless complexity to an
already complex market structure and
that the additional complexity of two
plans would create increased costs for
SROs as well as additional costs to the
Commission to regulate two plans,
which would be borne ultimately by
taxpayers and investors.35 The
Commission agrees with these
commenters that approving two plans
for the reservation of symbols would
place undue costs and burdens on
listing SROs, including new entrants.
The Commission also notes that,
currently, the proposed plans both
establish a process for the selection and
reservation of one-, two-, and threecharacter securities symbols. Therefore,
approval of both plans would establish
two competing, inconsistent systems for
selecting and reserving one-, two-, and
three-character symbols, which the
Commission believes would not be in
furtherance of the purposes of the Act.
The Commission finds that approving a
single plan, rather than both plans, is
necessary or appropriate in the public
interest, for the protection of investors
and the maintenance of fair and orderly
markets, to remove impediments to, and
perfect the mechanisms of a national
market system and is in furtherance of
the purposes of the Act because a single
plan would promote the smooth and
orderly operation of the marketplace.
After carefully considering the
proposed plans and the issues raised by
the comment letters, the Commission
has determined to approve, pursuant to
Section 11A(a)(3)(B) of the Act 36 and
Rule 608,37 the Five-Characters Plan,
with changes and subject to conditions
set forth herein as the Commission has
deemed necessary or appropriate.38 As
34 See FIF Letter I, FIF Letter II at 1, Angel Letter
II at 3, Angel Letter III at 1, Omgeo Letter at 1, and
SWIFT Letter.
35 See Angel Letter II at 3 and Angel Letter III at
2.
36 15 U.S.C. 78k–1(a)(3)(B).
37 17 CFR 242.608.
38 The Commission has modified the proposed
Five-Characters Plan to make the following changes:
(i) To modify the plan to state that, 90 days
following the Commission’s approval, it will be the
exclusive means of allocating and using symbols of
one-, two-, three-, four-, and five-characters in
length and to specify that there is no difference
between capital and lowercase letters (see infra note
41 and accompanying text); (ii) to modify the start
date for the initial reservation process from upon
Commission approval of the plan to 60 days
following the Comission’s approval (see infra notes
141–143 and 190–191 and accompanying text); (iii)
to limit the use of one-, two-, and three-character
symbols for securities listed on a national securities
exchange and to restrict securities trading over-the-
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discussed in detail below, in approving
the Five-Characters Plan, the
Commission finds that the FiveCharacters Plan is necessary and
appropriate in the public interest and in
furtherance of the purposes of the Act.
The Five-Characters Plan is more
comprehensive than the ThreeCharacters Plan because it covers one-,
two-, three-, four-, and five-character
symbols. The Commission also believes
it would better promote fair competition
among exchanges that list securities
because it does not constrain the
portability of symbols (as the ThreeCharacters Plan does), but instead
makes all symbols automatically
portable when a listed issuer transfers
its listing to another exchange. This
portability would enable issuers to make
listing decisions based on factors that
relate to the quality of the listing
markets such as trading quality, costs,
and branding, rather than on
considerations of symbol portability. In
summary, the Five-Characters Plan
provides a system for reserving and
allocating securities symbols that
should provide clarity and order to the
symbol reservation process, mitigate the
current constraints on symbol supply,
and promote fair competition between
the various SROs.
This order authorizes CHX, FINRA,
Nasdaq, NSX, and Phlx to act jointly to
implement the Five-Characters Plan, as
modified herein, as a means of
facilitating a national market system in
accordance with the requirements of
Section 11A of the Act.39 This order also
requires any SRO that chooses to list
securities on its market or to designate
securities for quoting on a quotation
medium to join the Five-Characters Plan
and to act jointly with other parties to
the plan to implement the approved
plan.40
In connection with requiring SROs
that list, or designate for quoting,
securities, the Commission is also
modifying the plan to provide that, 90
days from the date of this Order, the
Five-Characters Plan shall be the
exclusive means of allocating and using
symbols of one-, two-, three-, four-, or
five-characters in length. In addition, for
clarity, the Commission is specifying
that there will be no difference between
capital letters and lowercase letters,
counter to using only four- or five-character
symbols (see infra notes 85–89 and accompanying
text); and (iv) to clarify that securities that de-list
and trade on the over-the-counter market would not
have portability rights for the original listing
symbol (see infra notes 168–172 and accompanying
text).
39 15 U.S.C. 78k–1.
40 15 U.S.C. 78k–1(a)(3)(B). The Commission did
not receive any comments regarding whether it
should require SROs to join an approved plan.
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thus limiting the choices of letters to 26.
The Commission believes these changes
are necessary and appropriate for the
dissemination of trade information in a
common format.41
A. Five-Characters Plan’s Consistency
With Section 11A of the Act
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Many of the provisions of the
proposed Five-Characters Plan are
similar or identical to parallel
provisions in the proposed ThreeCharacters Plan. Particularly, the plans
would establish the Intermarket Symbol
Reservation Authority (‘‘ISRA’’)
composed of plan participants and set
forth how it would be administered.
Both plans also have the same
provisions regarding the use of a thirdparty processor and a symbol
reservation database, the general process
of reserving perpetual and limited-time
reservations, the use of a waiting list,
the right to reuse a symbol, the ability
to request the release of a symbol, the
terms of confidentiality, the nontransferability of rights under the plan,
and the process of amending the plan.42
Despite these significant areas of
consensus, however, there are several
important differences between the
proposed plans.
Many of the commenters that favored
the proposed Five-Characters Plan
asserted that it would enhance
competition among markets by putting
all exchanges on a fair and level playing
field and would reduce the potential for
investor confusion by allowing a fair
framework for symbol portability.43
Several commenters stated that the
proposed Five-Characters Plan would
give all exchanges equal rights under
the proposal.44 Some of these
commenters also stated that the
proposed Five-Characters Plan would
provide greater choice for public
companies and cause less confusion for
investors.45 One commenter asserted
that the proposed Five-Characters Plan
41 The Commission notes that, while the proposed
plans were silent on these points, this clarification
is necessary to avoid the possibility of confusion
regarding the scope of the approved plan.
42 See discussion infra Part III(B) for a discussion
of these provisions.
43 See Amerigon Letter, United Stationers Letter,
Glu Letter, Electronic Arts Letter, Silicon Storage
Letter, Silicon Graphics Letter, Innospec Letter,
SVB Letter, E*Trade Letter, EFI Letter, Top Image
Letter, Double Eagle Letter, and Silver Standard
Letter.
44 See Adams Letter, Atkins Letter, and Sobha
Letter. See also ASA Letter, which stated that fair
and equal competition is the core of the FiveCharacters Plan.
45 See Amerigon Letter, United Stationers Letter,
Glu Letter, Amarin Letter, Electronic Arts Letter,
Silicon Graphics Letter, SVB Letter, E*Trade Letter,
Top Image Letter, Double Eagle Letter, and Silver
Standard Letter.
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is inherently more fair and reasonable
than the proposed Three-Characters
Plan.46
The Commission agrees with the
commenters supporting the FiveCharacters Plan and finds that, as
discussed in greater detail below, the
Five-Characters Plan, as modified
herein, is consistent with Section 11A of
the Act, and is necessary and
appropriate in the public interest, for
the protection of investors and the
maintenance of fair and orderly markets.
1. Scope of Plan
One primary difference between the
two proposed plans relates to scope: the
proposed Three-Characters Plan would
only cover one-, two-, and threecharacter symbols; the Five-Characters
Plan, on the other hand, would cover
the reservation and allocation of all
one-, two-, three-, four-, and fivecharacter symbols. Both of the proposed
plans would cover only root symbols,
without any suffix or special
conditional identifier.47
The Commission believes that the
Five-Characters Plan, which would
establish a uniform system for the
selection and reservation of symbols
(‘‘Symbol Reservation System’’) of
one-, two-, three-, four-, or five-character
securities symbols,48 is more
comprehensive, and therefore offers a
more efficient and effective mechanism
for allocating symbols than the ThreeCharacters Plan.49 The Three-Characters
Plan would leave unanswered the
appropriate methodology for allocating
four- and five-character symbols.
Although Nasdaq is currently the
primary listing exchange for issuers
using four- and five-character
symbols,50 the Commission believes
46 See
Matthews Letter.
Section IV(a) of the proposed plans.
48 See Section I(b) of the Five-Characters Plan.
The Five-Characters Plan would cover only root
symbols (i.e., without any suffix or special
conditional identifier) that are NMS securities as
currently defined in Rule 600(a)(46) of Regulation
NMS under Act and any other equity securities
quoted, traded, and/or trade reported through an
SRO facility. See Preamble and Sections I(b) and
IV(a) of the Five-Characters Plan. The ThreeCharacters Plan would cover only root symbols of
one-, two- or three-characters for Network A and
Network B Eligible Securities (as defined in the
CTA Plan) and listed options reported to OPRA.
The Three-Characters Plan states that, for listed
equity securities, no such symbols would be
allocated or used other than for Network A or
Network B Eligible Securities. See Sections I(b) and
IV(a) of the Three-Characters Plan.
49 As discussed below, one commenter suggested
expanding the length of securities symbols to 10 or
12 characters. See Angel Letter III at 3. Currently,
the markets only use root symbols of one- through
five-characters in length.
50 The Commission notes that NYSE Arca
currently lists an issuer with a four-character
47 See
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that it will further the purposes of the
Act to approve a plan for the reservation
and allocation of symbols with one-,
two-, three-, four-, and five-character
symbols in order to permit all exchanges
to begin utilizing such symbols,
particularly in light of the limited
availability of one-, two-, and threecharacter symbols. Indeed, the
Commission believes that allowing all
exchanges to list four- and five-character
securities symbols should help ensure
that the supply of available securities
symbols does not become constrained.
Some commenters urged a broader
scope than that proposed in either plan.
Seven commenters advocated the
adoption of a national market system
plan that provides a single suffix
symbology across all SROs.51 In
response, Nasdaq had initially
commented that the plan should only
cover root symbols because the use of
symbol suffixes is unique to individual
markets.52 Subsequently, however,
Nasdaq urged that the Commission
commence a process for adopting a
uniform inter-market equity symbol
suffix plan.53 The Commission is
supportive of considering such an
initiative. To avoid a delay in the
implementation of a symbology national
market system plan for root symbols,
however, the Commission believes it is
appropriate to consider any such
initiative separately following the
approval of the Five-Characters Plan.
Accordingly, the Commission finds the
scope of the Five-Characters Plan in its
focus on root symbols is appropriate in
the public interest and that it will
further the purposes of the Act.
2. Parties to the Plan
The proposed plans have different
criteria for determining the eligibility
for parties to join their plan. The
security symbol, namely Golden Cycle Gold
Corporation (ticker symbol: GCGC).
51 See FIF Letter I, FIF Letter II at 1, Angel Letter
II at 3, Angel Letter III at 1, Omgeo Letter at 1,
SIFMA Letter, Bracewell & Guiliani Letter, SWIFT
Letter, and FIX Letter. One commenter also noted
that current inconsistencies in suffix symbology
and condition identifiers make it difficult for data
vendors to pass through accurate data, which can
cause confusion and loss for investors. See Angel
Letter I at 8 and Angel Letter III at 1. This
commenter also believed that the plan should
cover, in addition to equity securities, options,
futures, securities futures, mutual funds, and
indices and that it should incorporate
representation from the derivatives exchanges,
issuers, investors, and brokers. See Angel Letter I
at 10, Angel Letter II at 4, and Angel Letter III at
1. In addition, this commenter urged the
development of a new symbology plan in what he
anticipates will be a global trading environment.
See Angel Letter III at 2.
52 See Nasdaq Letter II at 3.
53 See Nasdaq Letter III. See also Head Trader
Alert 2008–36 (March 27, 2008), available at
https://www.nasdaqtrader.com.
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mstockstill on PROD1PC66 with NOTICES
proposed Three-Characters Plan would
only allow an SRO to join the plan if it
maintains a market for the listing and
trading of securities that are identified
by one-, two-, or three-character
symbols and if their listed equity
securities are also ‘‘Network A’’ or
‘‘Network B’’ ‘‘Eligible Securities’’ as
those terms are defined in the CTA
Plan.54
The Five-Characters Plan, on the other
hand, would allow any SRO to join the
plan as long as it maintains a market for
the listing and trading of securities that
are identified by one-, two-, three-,
four-, or five-character symbols.55 A
party would also be required to have the
actual technical and physical capability
through its facilities to immediately
quote and report trades in securities
either using one-, two-, or threecharacter symbols, if it seeks to reserve
symbols of one-, two-, or threecharacters in length, or using four-or
five-character symbols, if it seeks to
reserve symbols of four-or fivecharacters in length.56 In addition, this
plan would require, as conditions to
becoming a new participant, that an
SRO pay a proportionate share of the
aggregate development costs and sign a
current copy of the plan.57
Many commenters argued that Nasdaq
should not be allowed to list one-,
two-, and three-character symbols
because such symbols are indicative of
an NYSE listing.58 Some of these
commenters argued that an issuer’s use
of a one-, two-, or three-character
symbol signaled the NYSE brand and
‘‘companies listed on NYSE meet the
highest corporate governance and
financial standards in the world;’’ 59
54 The CTA Plan defines ‘‘Network A Eligible
Securities’’ to mean Eligible Securities listed on
NYSE and ‘‘Network B Eligible Securities’’ to mean,
in relevant part, Eligible Securities listed on the
Amex, BSE, CBOE, CHX, ISE, NSX, NYSE Arca,
Phlx or on any other exchange other than Nasdaq,
but not also listed on NYSE.
55 See also supra note 48.
56 See Section I(b) of the Five-Characters Plan.
57 See Section I(c) of the Five-Characters Plan. For
additional discussion regarding the plan’s provision
relating to costs, see discussion infra notes 118–124
and accompanying text.
58 See FPL Letter, TCF Letter, Wolverine Letter,
Getty Letter, KCI Letter, AmeriCredit Letter,
Entertainment Properties Letter, Big Lots Letter,
Allstate Letter, Cantel Letter, Webster Letter,
Strategic Technologies Letter, U.S. Steel Letter,
Ward Letter, Darwin Letter, Ethan Allen Letter,
Cooper Letter, Chipotle Letter, State Street Letter,
and Jackson Hewitt Letter. See also NYSE Letter at
2.
59 See Allstate Letter; see also, e.g., FPL Letter,
TCF Letter, Wolverine Letter, Getty Letter, KCI
Letter, AmeriCredit Letter, Entertainment Properties
Letter, Big Lots Letter, Cantel Letter, Webster Letter,
Strategic Technologies Letter, U.S. Steel Letter,
Darwin Letter, Ethan Allen Letter, Cooper Letter,
Chipotle Letter, State Street Letter, and Jackson
Hewitt Letter. See also NYSE Letter at 4.
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consequently, some stated, the Nasdaq
issuers’ use of such symbols could lead
to investor confusion.60 One such
commenter, a trustee and portfolio
manager of a small pension fund, stated
that it relies on the use of one-, two-,
and three-character symbols to identify
NYSE securities and makes investment
decisions based on such reliance, citing
the financial reporting requirements and
stability of earnings of NYSE securities;
this commenter further stated that it
generally performs ‘‘an extra level of
scrutiny in view of the longevity of
firms that have been listed in the over
the counter market’’ because it
presumes that those securities are not
NYSE-listed securities.61 NYSE also
argued that Nasdaq’s attempt to use
three-character symbols exacerbates the
existing supply problems without
justification.62
Many other commenters, however,
challenged these assertions and argued
that Nasdaq should have the same rights
to list one-, two-, or three-character
symbols as NYSE and any other
exchange.63 One commenter noted that
one-, two-, and three-character ticker
symbols have previously been used by
Amex and other regional exchanges and
that commenters implying that one-,
two-, and three-character symbols are
associated only with NYSE ignore
current practice and the historical
record.64 Another commenter stated
that, due to the fact that markets can no
longer claim a majority share of the
trading in their listed securities, the
correlation of the number of letters in a
ticker symbol and its listing on a
particular exchange is an increasingly
obsolete consideration.65 One
commenter also noted that NYSE and
60 See TCF Letter, Wolverine Letter, Big Lots
Letter, Ward Letter. See also NYSE Letter at 3.
61 See Strategic Technologies Letter. The NYSE
Letter also argued that investors, securities issuers,
and the public rely on the different symbol lengths
to distinguish NYSE and Nasdaq securities. See
NYSE Letter at 2.
62 See NYSE Letter at 5.
63 See G&K Letter, Amerigon Letter, United
Stationers Letter, Glu Letter, Electronic Arts Letter,
Silicon Graphics Letter, E*Trade Letter, Silicon
Storage Letter, Innospec Letter, EFI Letter, and
Nasdaq Letter I. See also SVB Letter, Top Image
Letter, and Double Eagle Letter, which state that all
exchanges and issuers should be able to list threeor fewer character symbols.
64 This commenter stated that Amex, BSE, and
other regional exchanges have used one- or twocharacter ticker symbols in the past. See Angel
Letter I at 6, Angel Letter II at 2, and Angel Letter
III at 2. This commenter also argued that shorter
ticker symbols should go to the most actively-traded
stocks, some of which are Nasdaq-listed, because
the reduced typing and remembering effort required
for such symbols would make it a more
economically efficient solution. See Angel Letter I
at 5.
65 See Issuer Advisory Letter at 2. See also Angel
Letter I at 4.
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67223
Amex issuers, similarly, should have
the flexibility to use longer ticker
symbols that may be more readily
identifiable with their company.66
The Commission believes that any
SRO with the capacity to maintain a
market for the listing of securities that
are identified by one-, two-, three-,
four-, or five-character symbols should
be able to reserve those symbols.67 As
noted above, the Five-Characters Plan
would permit any SRO that maintains a
market for the listing and trading of plan
securities to become a party to the
plan.68 The Commission believes that
SROs that have listing standards for
plan securities, though they may not be
actively listing such securities, and that
maintain a market for the trading of plan
securities would satisfy this
requirement and would be permitted,
though not required, to become parties
to the plan. Joining the plan would
enable such SROs to reserve symbols in
anticipation of beginning a listings
business.69 In addition, the Commission
is requiring any SRO that chooses to list
securities on its market or to designate
securities for quoting on a quotation
medium to join the approved plan.70
The Commission does not agree with
commenters who believe that the use of
one-, two-or three-character symbols by
Nasdaq issuers will ‘‘blur and diminish
the financial and other significant
achievements commonly associated
with NYSE listed companies’’ 71 or
confuse investors who today
purportedly identify such symbols as
associated with NYSE. Many issuers not
listed on NYSE utilize such symbols
and have for a significant period of time
and, therefore, any automatic
association of such symbols with
NYSE’s listing standards or brand is
mistaken.72 Therefore, the Commission
finds that the provision on eligible
parties in the proposed Five-Characters
Plan is preferable and is necessary and
appropriate in the public interest, for
the protection of investors and the
66 See
Angel Letter II at 3.
Commission notes that Nasdaq is no longer
a facility of a national securities association and is
now a national securities exchange. See supra note
26.
68 See Section I(c) of the Five-Characters Plan.
69 Parties to the plan are entitled to place up to
20 symbols on each of its perpetual reservation lists
for one-, two-, or three-character symbols and fouror five-character symbols, respectively. See infra
notes 90 and 93–95 and accompanying text. The
Commission notes that, for limited-time
reservations, the plan requires a party to have a
reasonable basis for using a limited-time reservation
within a 24-month period. See infra notes 91–92
and accompanying text.
70 See infra notes 192 and 197–198 and
accompanying text.
71 See Big Lots Letter.
72 See supra note 64 and accompanying text.
67 The
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maintenance of fair and orderly markets,
and that it assures fair competition
among exchange markets, consistent
with Section 11A(a)(1)(C)(ii) of the
Act.73
The Commission also believes that the
Five-Characters Plan will further the
purposes of the Act because it promotes
competition among listing markets,
including potential new listing markets.
As described in further detail below,
and unlike the Three-Characters Plan,
the Five-Characters Plan provides each
party to the plan with an equal
allotment of perpetual and limited-time
reservations.74 The Five-Characters Plan
also permits the portability of an
issuer’s symbol from one SRO to
another, allowing competing listing
venues to attract transferred listings
without requiring issuers to change their
ticker symbol.75 In addition, the FiveCharacters Plan would allocate to any
new party joining the plan a pro-rata
portion of the initial development costs
based upon the number of symbols
initially reserved by such new party
during its first twelve months as a party
to the plan.76
3. Reservation and Use of Symbols
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Both proposed plans have provisions
allowing parties to the plan to reserve
symbols in perpetuity (‘‘perpetual
reservations’’) and for a limited time
(‘‘limited-time reservations’’).
Specifically, both proposed plans
provide that, within 30 days of
Commission approval of the plan
(unless such time is extended by the
Policy Committee),77 parties may
73 See 15 U.S.C. 78k–1(a)(1)(C)(ii).
One commenter also argued that rights to ticker
symbols should be allocated directly to issuers,
rather than to the SROs. See Issuer Advisory Letter
at 3. See also Angel Letter I at 3 and Angel Letter
III at 4, arguing that issuers have stronger claims to
symbols than their exchanges. The Commission
believes, however, that developing a symbol
reservation plan directly among the issuers would
present significant challenges—including
implementation and administrative challenges, and
believes that continuing to allow listing markets to
reserve and then allocate those symbols to qualified
issuers is more workable and efficient.
Because the Five-Characters Plan, as filed, listed
the name of all SROs, including those that were not
signatories to the plan, the Commission has deleted
the names of SROs listed in Section I(a) of the FiveCharacters Plan who are not signatories to the plan
at this time.
74 See discussion infra notes 77–104 and
accompanying text.
75 See discussion infra notes 105–117 and
accompanying text.
76 See discussion infra notes 118–124 and
accompanying text.
77 ISRA will be administered by a Policy
Committee, which will consist of one voting
member and one alternate voting member
representing each party. See Section II(a) and (c) of
the Five-Characters Plan. See also Section II(a) and
(c) of the Three-Characters Plan, which is identical
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submit to the Processor 78 requests for
initial reservation of symbols.79 The
proposed plans’ differ as follows: (1)
How reservation rights are allocated
among the individual parties; (2) the
number of symbols that may be reserved
on the perpetual reservation and
limited-time reservation lists,
respectively; and (3) how limited-time
reservations may be secured. These
differences and the reasons the
Commission finds that the FiveCharacters Plan’s provisions on
reservation rights, as modified herein,
are appropriate in the public interest for
the maintenance of fair and orderly
markets and fair competition between
the markets, consistent with the Section
11A(a)(1)(C) of the Act,80 are discussed
below.
a. Allocation of Reservation Rights
Among Parties
The proposed Three-Characters Plan
awards greater reservation rights to
NYSE and Amex than to the other
parties to the plan. Specifically, the
proposed Three-Characters Plan would
allow NYSE and Amex each to reserve
200 symbols as perpetual reservations
and 1,500 symbols as limited-time
reservations, while other parties to the
plan could only reserve 40 symbols as
perpetual reservations and up to 500
limited-time reservations.81 The FiveCharacters Plan, on the other hand,
awards equal reservation rights among
all the parties—any eligible party to the
plan could reserve 20 perpetual
reservations and 1,500 limited-time
reservations of one-, two-, and threecharacter symbols and 20 perpetual
reservations and 1,500 limited-time
reservations of four- and five-character
symbols.82 The Five-Characters Plan
also requires a party intending to
to the corresponding provision of the FiveCharacters Plan.
78 The Processor will be an independent third
party to which ISRA will delegate the operation of
the Symbol Reservation System. See Section III of
the Five-Characters Plan. See also Section III of the
Three-Characters Plan, which is identical to the
Five-Characters Plan.
79 The Commission is modifying the FiveCharacters Plan’s provision on the timing for the
initial reservation process. See infra notes 77–104
and accompanying text for the discussion of this
modification.
80 15 U.S.C. 78k–1(a)(1)(C).
81 The proposed Three-Characters Plan, as
amended, provided that NYSE Arca and CBOE each
may have 500 limited-time reservations and that
ISE may have 200 limited-time reservations. The
plan would leave the precise number of limitedtime reservations for other SROs to be decided
when such SROs join the proposed plan.
82 See Section IV(b)(1)(A) and (B) of the FiveCharacters Plan. The Commission notes that the
reservation lists do not apply to securities symbols
already in use, but rather relate to unused ticker
symbols.
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Sfmt 4703
include a symbol on its limited-time
reservations lists to have a reasonable
basis for using such symbol within 24
months.
With respect to these provisions on
reservation rights, the Commission finds
that the Five-Characters Plan will
further the purposes of the Act. The
Five-Characters Plan allocates all
reservation rights equally among all
parties to the plan, consistent with fair
competition principles. NYSE argued
that the proposed Three-Characters Plan
reservation provisions reflect the reality
of its own likelihood to list a greater
number of securities than the other
markets.83 Nasdaq, however, disputed
this assertion and stated that the
allocation of reservations in this
provision of the Three-Characters Plan
is out of proportion to historic symbol
usage.84 Nasdaq also argued that this
provision would be discriminatory and
that such discrimination is not
compelled by market needs and is
inconsistent with the equal regulation
and pro-competition mandates of the
Act. While the Commission recognizes
that currently NYSE and Amex markets
encompass the overwhelming majority
of primary listings for issuers with
one-, two-, and three-character symbols,
the Commission does not believe that
the dominance of any particular market
should be enshrined in a national
market system plan. Moreover, the
Commission believes that the FiveCharacters Plan’s proposed allotments
would permit active listing markets to
reserve more than enough securities
symbols for their listing business. The
Five-Characters Plan, in contrast to the
proposed Three-Characters Plan, would
promote fair competition among the
markets by providing all participants
with the same number of reservations.
Such equal reservation rights make it
easier for an existing SRO or new
entrant to compete on an equal basis
with primary listing markets.
One commenter stated that OTC
Bulletin Board (‘‘OTCBB’’)85 and Pink
Sheet 86 issuers should not have the
same rights to use securities symbols as
issuers listed on national securities
exchanges.87 The commenter noted that,
83 See
NYSE Letter at 6.
Nasdaq Letter II at 2.
85 The OTCBB is a quotation service for over-thecounter equity securities run by FINRA, a national
securities association.
86 Pink Sheets is an interdealer electronic
quotation system that displays quotes from market
makers for many over-the-counter securities. To be
quoted on the Pink Sheets, an issuer need only find
one market maker to quote its shares, and Pink
Sheets-traded issuers need not have audited
financial statements. See https://
www.pinksheets.com.
87 See Angel Letter I at 10.
84 See
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in the past, if a Nasdaq-listed firm
desired to use a ticker symbol that was
in use by an OTCBB or Pink Sheet
issuer, it could usually get such a
symbol. In addition, the commenter
noted that such issuers have not paid
any listing fees to be traded on those
markets and that many of them are shell
companies with no operations or
defunct companies. The commenter
believed that only ‘‘legitimate’’ SEC
registrants that meet the listing
standards of the exchanges should be
able to establish rights to ticker symbols.
The Commission agrees and believes
that significant investor confusion and
harm could occur if such securities,
which currently trade using four-or fivecharacter symbols, were to begin trading
with one-, two-, or three-character
symbols. The Commission believes that
it is important to distinguish between
securities trading only on over-thecounter trading venues and those listed
on national securities exchanges.
Exchange listing standards are approved
by the Commission and must include
corporate governance requirements that
comply with Rule 10A–3 under the
Act.88 Issuers traded on over-thecounter equity venues (including the
OTCBB and Pink Sheets) are not subject
to such listing standards. Therefore,
such securities can be substantially
different from those listed on a national
securities exchange. The Commission
does not believe any similar distinction
exists among the national securities
exchanges. Accordingly, the
Commission believes that it is
appropriate to limit securities not listed
on a national securities exchange to
using four-or five-character symbols,
whereas it is not appropriate to
similarly distinguish between exchangelisted securities. The Commission
believes that issuers trading solely on
the OTCBB, Pink Sheets, and any other
over-the-counter venue should be
limited to using four- and five-character
symbols, as they do today, as any
change from this current practice would
unnecessarily confuse investors and
could lead to investor harm. The
Commission finds that it is necessary
and appropriate in the public interest,
and for the protection of investors and
the maintenance of fair and orderly
markets, that only issuers listed on a
national securities exchange be allowed
to use one-, two-, and three-character
symbols.89 Therefore, the Commission
is modifying the Five-Characters Plan to
prohibit an SRO from reserving or using
one-, two-, and three-character symbols
88 17
CFR 240.10A–3.
89 17 CFR 242.608.
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for any issuer not listed on a national
securities exchange.
b. Number of Perpetual and LimitedTime Reservations
The Three-Characters Plan
contemplates allocating some SROs as
many as 200 perpetual reservations. In
contrast, the Five-Characters Plan would
allow no more than 40 perpetual
reservations for each party.90 The
Commission believes that, because the
Five-Characters Plan allows the
overwhelming majority of unused
symbols remain available for future use,
exchanges would not be able to hold
securities symbols in a manner that
stifles or burdens competition. In this
regard, the Commission believes that the
perpetual reservation provisions of the
Five-Characters Plan are more favorable
to new entrants. The Commission also
believes that the Five-Characters Plan’s
allotment of 1,500 limited-time
reservations for one-, two-, and threecharacter symbols and 1,500 limitedtime reservations for four- and fivecharacter symbols should adequately
offset the low number of permitted
perpetual reservations, and allow SROs
to reserve a sufficient number of
symbols in the short-term for any
pending use.
Both proposed plans permit limitedtime reservations for a period of 24
months, after which time the Processor
would release such symbols to be
available for reservation by parties on
the waiting list for a given symbol or, in
the absence of a waiting list, for general
availability.91 The Five-Characters Plan
requires a party to have a reasonable
basis for using a limited-time
reservation within such 24-month
period while the Three-Characters Plan
has no such comparable requirement.92
Under the Five-Characters Plan, if a
party does not use a limited-time
reservation within the 24-month
reservation period and no party reserves
90 The Five-Characters Plan would allow each
party to place 20 symbols on each of its perpetual
reservation lists for one-, two-, or three-character
symbols and four- or five-character symbols,
respectively.
91 See Sections IV(b)(1)(B) and IV(b)(5) of the
proposed plans.
92 Because ‘‘reasonable basis’’ was not defined in
the Five-Characters Plan, the Commission requested
comment about it in the Symbology Notice. No
commenters specifically responded to this request.
The Commission believes that it is necessary and
appropriate in the public interest to have the Policy
Committee determine the appropriate interpretation
and application of terms used in the plan, such as
the term ‘‘reasonable basis.’’ To the extent that any
of the parties to the plan are aggrieved by the
determination of the Policy Committee in this
regard, the Commission notes that it has the
authority to hear appeals by such parties. See Rule
608(d), 17 CFR 242.608(d); see also supra notes
133–137 and accompanying text.
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67225
the symbol after the Processor releases
it, then the original party would be able
to subsequently reserve the symbol for
an additional 24-month period, once
again subject to the requirement that it
has a reasonable basis for doing so. The
Commission does not view the
‘‘reasonable basis’’ requirement in the
Five-Characters Plan as mandating the
usage of a symbol within 24 months, but
believes that this requirement should
help prevent the arbitrary reservation of
symbols, particularly in an anticompetitive manner.
One commenter argued that there
should be no perpetual reservations
because having a perpetual reservation
would allow an exchange to exclude
others from ever using a symbol.93 The
Commission notes that, though they
disagreed on the precise number of
perpetual reservations each party
should be able to reserve, the signatory
SROs to both proposed plans agreed to
the availability of perpetual
reservations,94 and believes that
perpetual reservations are not
inconsistent with Rule 608 under the
Act, which requires that the plan be
necessary or appropriate in the public
interest, for the protection of investors
and the maintenance of fair and orderly
markets, to remove impediments to, and
perfect the mechanisms of, a national
market system, or otherwise in
furtherance of the purposes of the Act.
Nonetheless, the Commission believes
that the number of such perpetual
reservations should be kept to a
minimum and believes that the FiveCharacters Plan’s allocation of 40
perpetual reservations to each party is
appropriate. The Commission
acknowledges that new entrants that
join the plan after the initial reservation
process would have fewer options for
selecting their perpetual reservations, as
compared to the parties participating in
the initial reservation process. But the
Commission believes that, given the
relatively low number of perpetual
reservations allowed under the FiveCharacters Plan (particularly as
compared to the Three-Characters Plan),
such new entrants would still have
access to an adequate number of
symbols and notes that they would also
have the same right to have 40 perpetual
reservations each. In addition, the
Commission notes that, once an SRO
assigns a symbol from its perpetual
reservation list to an issuer, that symbol
becomes portable to other listing
markets if the issuer using the symbol
were to transfer its listing to another
93 See Angel Letter I at 6, 9 and Angel Letter II
at 3, and Angel Letter III at 4.
94 See Section IV(b)(1)(A) of the proposed plans.
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SRO.95 Because the Five-Characters
Plan would limit each party to no more
than 40 perpetual reservations and
because an issuer using such a symbol
could transfer its listing to another SRO
if it chose to do so, the Commission
finds that the Five-Characters Plan’s
provisions with respect to perpetual
reservations are not anticompetitive and
are appropriate in the public interest.
Finally, one commenter also stated
that symbols should be allocated on a
‘‘first-come, first-served’’ basis with a
‘‘use it or lose it’’ feature.96 The
Commission believes that the FiveCharacters Plan’s provisions relating to
processing symbol requests for limitedtime reservations incorporate this very
principle.
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c. Legacy Reservations
Under both proposed plans, during
the initial reservation process, a party in
reserving a symbol that it claims was
properly reserved under the current
informal system prior to the effective
date of the plan would have priority
over other parties also reserving such
symbol.97 Under the Five-Characters
Plan, however, such party would have
priority over other SROs to retain
reservation of that symbol (a ‘‘legacy
reservation’’) only if the party represents
that it has a reasonable basis 98 to
believe that it would utilize such
symbol within the next six months.
Moreover, such reservation would not
count towards the party’s perpetual
reservations or limited-time
reservations, but instead be reserved as
a separate, additional legacy
reservation.99 If the party does not use
such symbol within the allotted sixmonth period, it would lose the
reservation unless the party requests an
extension for an additional six-month
period. In requesting such an extension,
the party would have to have a
reasonable basis to believe that it would
utilize such symbol within the
additional six-month period. If the
symbol has not been used within the
additional six-month period, the symbol
would be released by the Processor.100
The Three-Characters Plan also assigns
priority for symbol reservations to
parties that claim to have properly
reserved such symbols under the
current informal system prior to the
effective date of the plan, but it does not
place such reservations on a separate
‘‘legacy reservation’’ list nor does it
95 See
96 See
Section IV(f) of the Five-Characters Plan.
Angel Letter I at 9 and Angel Letter III at
4.
97 See
Section IV(b)(2)(A) of the proposed plans.
supra note 92.
99 See Section IV(b)(2)(A) of the proposed plans.
100 See id.
98 See
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establish a separate process for using
such symbols.101
One commenter suggested
establishing a 90-day remaining life to
all symbols currently reserved by the
exchanges, after which all symbol
reservations by exchanges will cease to
exist.102 Another commenter endorsed
an approach similar to that in the FiveCharacters Plan, proposing a transitional
provision allowing for an exchange to
assert a legacy reservation for up to 12
months for a pending use.103 The
Commission finds that the legacy
reservation provision in the FiveCharacters Plan is in the public interest,
consistent with Section 11A(a)(1)(C) of
the Act, because it provides an
appropriate transition period for symbol
reservations held prior to the
Commission’s approval of the FiveCharacters Plan.104
4. Portability of Symbols
Another key difference between the
two proposed plans relates to the
portability of symbols. In Amendment
No. 1 to the proposed Three-Characters
Plan, that plan was amended to allow
for the automatic portability of threecharacter symbols (i.e., allowing an
issuer with a three-character ticker
symbol to automatically continue to use
that symbol upon transferring its listing
to another SRO).105 Nonetheless, the
proposed Three-Characters Plan
maintains that one- and two-character
symbols would not be automatically
portable if a listed issuer moves to
another exchange. Under that proposed
plan, the rights to a one-or two-character
symbol of the issuer transferring to
another exchange would remain with
the former SRO unless the former SRO
consents to the transfer of the symbol to
the new SRO. The only exception would
be, in the case of two-character symbols,
if the new SRO demonstrates that it has
a compelling business need that
substantially outweighs the business
needs of the former SRO. This
101 See
Section IV(b)(2)(A) of the Three-Characters
106 See
Plan.
102 See
Issuer Advisory Letter at 3.
103 See Sobha Letter.
104 15 U.S.C. 78k–1(a)(1)(C).
105 Two commenters expressed concerns that an
earlier proposed rule change of Nasdaq to allow the
transfer of issuers with three-character symbols to
Nasdaq (SR–NASDAQ–2007–031) could circumvent
efforts to develop a national market system plan for
symbology. See RPM Letter and MDC Letter. In the
Nasdaq Three-Character Portability Order, see supra
note 29, the Commission addressed this concern
and noted that its approval of that proposed rule
change was independent of its consideration of the
proposed NMS plans. As the Commission stated
then, ‘‘[p]articipants in any such plan would be
required to comply with its requirements, which
could necessitate changes to SRO rules.’’ See
Nasdaq Three-Character Portability Order at 38641.
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determination would be made by the
Processor and would be final. Under the
proposed Three-Characters Plan, this
exception would not apply to onecharacter symbols, which could not be
transferred to a new SRO without the
consent of the former SRO, even if the
new SRO was able to demonstrate a
compelling business need that
substantially outweighed the business
needs of the former SRO. In contrast, the
Five-Characters Plan would provide the
automatic portability of any symbol in
the event that an issuer transfers its
listing to another exchange (i.e., without
requiring the consent of the former
SRO).106
Many commenters have supported the
portability provision of the FiveCharacters Plan.107 Some commenters
argued that the portability provision of
the proposed Three-Characters Plan
would create artificial restrictions on
symbol use and portability that would
not benefit listed companies or the
investing public.108 One commenter
stated that disallowing symbol
portability is an anti-competitive and
unfair practice.109 Another commenter
argued that the inconvenience and
transition costs involved with requiring
a company to change its ticker symbol
upon transferring from the NYSE to
another exchange amount to an unfair
restraint of trade.110 Two commenters
also likened securities symbols to
telephone numbers and argued that they
should belong to the issuer and be fully
portable.111
One commenter noted that issuers
expend more effort and resources to
associate a particular symbol with their
company than anyone else, and
therefore should be allowed to take their
symbol with them when they move to
another exchange.112 This commenter
also stated that, over time, investors
tend to associate a particular ticker
symbol far more with a company than
with a particular exchange and that,
therefore, in terms of reducing investors’
search and transaction costs, it makes
Frm 00109
Fmt 4703
Sfmt 4703
Section IV(f) of the Five-Characters Plan.
Omni Letter, Adams Letter, Amerigon
Letter, Atkins Letter, United Stationers Letter, Glu
Letter, ASA Letter, Electronic Arts Letter, Silicon
Storage Letter, Silicon Graphics Letter, E*Trade
Letter, Innospec Letter, SVB Letter, EFI Letter, Top
Image Letter, and Double Eagle Letter, and Nasdaq
Letter II at 3.
108 See Amerigon Letter, United Stationers Letter,
Glu Letter, Electronic Arts Letter, Silicon Storage
Letter, Silicon Graphics Letter, Innospec Letter,
E*Trade Letter, EFI Letter, Top Image Letter, Double
Eagle Letter.
109 See Issuer Advisory Letter at 2.
110 See ASA Letter.
111 See Spachman Letter, Angel Letter I at 5–6,
Angel Letter II at 2, and Angel Letter III at 3 and
4.
112 See Angel Letter I at 4.
107 See
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sense to award the rights to a particular
ticker symbol to the issuer that has been
using the ticker symbol, rather than the
exchange where it originally listed.113
Furthermore, this commenter stated that
changing an issuer’s ticker symbol can
result in confusion for investors and
researchers and be the source of costly
investment mistakes, noting that data
vendors often do not catch a symbol
change on time.114 One issuer cited its
own experience with transferring its
listing from NYSE to Nasdaq and
consequently changing its symbol;
though it ultimately decided to switch
listing venues, the issuer stated the need
to change its ticker symbol was a
negative factor because of the time and
resources it had to expend to make sure
its investors were aware of the symbol
change.115 Finally, one commenter also
noted that allowing symbol portability
would strengthen competition between
markets.116
The Commission finds that allowing
the automatic portability of a symbol in
the event that an issuer transfers its
listing to another exchange will further
the purposes of the Act and should
reduce investor confusion by allowing
the symbol already associated with the
issuer to continue to be used by the
issuer on the new exchange. The
Commission also finds that allowing
automatic symbol portability would
remove a burden on competition among
markets not necessary or appropriate in
furtherance of the purposes of the Act
by making it easier for listed issuers to
transfer their listings to another
exchange, thereby enhancing
competition among exchanges in the
business of providing a listing venue.
Eliminating the costs and administrative
efforts associated with acquiring a new
symbol for transferred listings should
allow listed issuers to make decisions
about listing based on factors such as
listing costs and the quality of markets.
The Commission believes that automatic
symbol portability is preferable to
allowing an issuer’s former listing
exchange to retain the rights to a symbol
once a listed issuer has transferred to
another market, particularly as the
former market likely would not reuse
the symbol in the near term without
causing undue investor confusion.
Therefore, the Commission finds that
the automatic symbol portability
provision in the Five-Characters Plan is
in the public interest, appropriate for
113 Id.
114 See Angel Letter I at 5. See also Nasdaq Letter
II at 3.
115 See E*Trade Letter. See also Nasdaq Letter II
at 3.
116 See Angel Letter II at 2.
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the protection of investors and the
maintenance of fair and orderly markets,
and assures fair competition among
exchange markets, consistent with the
Section 11A(a)(1)(C) of the Act.117
5. Allocation of Plan Costs
The two proposed plans also differ
with respect to the allocation of the
initial development costs and ongoing
costs of the plan. The proposed ThreeCharacters Plan would have all initial
and ongoing costs shared equally among
all the parties.
The Five-Characters Plan provides
that the parties would share the initial
development costs pro-rata based on the
number of symbols initially reserved by
each party. Any new party that joins the
plan would also be responsible for a
pro-rata portion of the initial
development costs based upon the
number of symbols initially reserved by
such new party during the first twelve
months of the new party’s membership
in the plan.118 The Five-Characters Plan
also provides that the continuing costs
and expenses of ISRA would be shared
among the parties pro-rata based on the
number of additional symbols reserved
in each calendar year, estimated
quarterly.119 In addition, under the
Five-Characters Plan, the Policy
Committee 120 may develop alternative
cost-allocation methodologies for
special development projects outside
the initial development period. One
commenter expressed support for this
provision in the Five-Characters Plan as
it would require exchanges to bear the
costs of the system only to the extent
they reserve and use symbols.121
The Commission finds that the FiveCharacters Plan’s provision for the
allocation of costs will further the
purposes of the Act in that it establishes
an equitable means of allocating costs
among the plan parties.122 The SROs
supportive of the Three-Characters Plan
anticipate that certain SROs, such as
NYSE and Amex, would likely use the
reservation system more than other
SROs.123 It is the proposed Five117 15
U.S.C. 78k–1(a)(1)(C).
Section V(a) of the Five-Characters Plan.
119 See Section V(b) of the Five-Characters Plan.
120 See infra notes 125–137 and accompanying
text.
121 See Adams Letter.
122 One commenter argued, based on its belief
that the issuers have rights to the symbols, that
issuers should pay for the plan in accordance with
the Regulation NMS market data revenue formula.
See Angel Letter II at 3. The Commission notes,
however, that the listing markets charge initial and
ongoing listing fees to issuers listed on their
markets, and therefore issuers are likely to pay
indirectly.
123 This expectation is the basis for the proposed
Three-Characters Plan providing more reservations
118 See
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67227
Characters Plan, however, that
recognized this likelihood by allocating
costs based on an SRO’s use of the
reservation system. Moreover, the
parties’ usage of the system will likely
vary as markets compete for listings.
Under the Five-Characters Plan, the cost
allocation will similarly vary with any
changes in use of the reservations.
Therefore, the Commission finds that
the cost allocation provision of the FiveCharacters Plan is in the public interest,
appropriate for the protection of
investors and the maintenance of fair
and orderly markets, and assures fair
competition among exchange markets,
consistent with Section 11A(a)(1)(C) of
the Act.124
B. Similar Provisions Among the
Proposed Plans
Other than the areas of substantive
differences between the proposed plans
discussed above, the remaining
provisions of the Five-Characters Plan
are substantially similar or identical to
parallel provisions in the proposed
Three-Characters Plan. The Commission
believes that such similarities evidence
a broad consensus among the SROs as
to the overall framework and most of the
main provisions of the Five-Characters
Plan, a result of the collaboration by and
negotiations between the SROs
following the issuance of the February
2005 Letters to discuss the terms of an
appropriate national market system plan
for the reservation and allocation of
securities symbols. Therefore, the
Commission believes that these aspects
of the Five-Characters Plan represent a
fair and workable symbol reservation
system for the prospective parties to the
plan.
The following section discusses the
remaining provisions of the FiveCharacters Plan, which are substantially
similar or identical to provisions in the
proposed Three-Characters Plan.
1. Administration of ISRA
The Five-Characters Plan would
establish a body composed of the
signatory SROs called the Intermarket
Symbols Reservation Authority.125 A
Policy Committee, consisting of
representatives of each of the signatory
SROs, would administer the ISRA and,
unless expressly provided otherwise in
the plan, would make all policy
decisions on behalf of the ISRA in
furtherance of the functions and
objectives of the ISRA under the Act
and the plan. Specifically, the Policy
to NYSE and Amex than the other SROs. See NYSE
Letter at 6.
124 15 U.S.C. 78k–1(a)(1)(C).
125 See Section II(a) of the Five-Characters Plan.
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Committee would: (1) Oversee the
operation of the Symbol Reservation
System; (2) make all determinations
pertaining to contracts with parties to
the plan and persons who provide goods
or services to the ISRA; and (3)
determine all other questions pertaining
to the planning, developing, and
operating of the ISRA, including those
pertaining to budgetary or financial
matters.126
One voting member and one alternate
voting member representing each party
would compose the Policy
Committee.127 Each party would have
one vote on all matters voted upon by
the Policy Committee and actions of the
ISRA under each plan would be
authorized by a majority vote of the
Policy Committee members, subject to
Commission approval when required by
applicable securities law.128 Authorized
actions under the plan would be
binding upon all the parties. However,
an aggrieved party may present contrary
views to any regulatory body or in any
other appropriate forum.129 A meeting
of the Policy Committee would be held
at least annually and other meetings
would be held as determined by the
Policy Committee, subject to the notice
provisions for regular and special
meetings and the organization of the
meetings.130
The Commission finds that the
provisions of the Five-Characters Plan
relating to the establishment of the ISRA
and the administration of the ISRA by
the Policy Committee will further the
purposes of the Act and should assure
fair competition between exchange
markets, consistent with Section
11A(a)(1)(C) of the Act.131 The
Commission believes that, because the
Policy Committee is composed of one
voting member representing each party,
that each party would be limited in its
ability to act in an anti-competitive
manner.132
Two commenters have recommended
the adoption of a formal dispute
resolution mechanism for the plan.133
The Commission notes that Section 11A
of the Act and Rule 608 require national
market system plans to describe, to the
extent applicable, the method by which
disputes in connection with the
operation of the plan will be
resolved.134 The Five-Characters Plan
126 See
Section II(b) of the Five-Characters Plan.
Section II(c) of the Five-Characters Plan.
128 See Section II(d) of the Five-Characters Plan.
129 Id.
130 See Section II(e) of the Five-Characters Plan.
131 15 U.S.C. 78k–1(a)(1)(C).
132 See Section II(c) of the Five-Characters Plan.
133 See Angel Letter I at 11. See also Issuer
Advisory Letter at 3.
134 See 17 CFR 242.608(a)(5)(iv).
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127 See
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specifies a dispute resolution
mechanism with respect to the initial
reservation of securities symbols, where
disagreements are most likely to
arise.135 With regard to the operation of
the plan following the initial reservation
period, the Commission believes that
the likelihood of disputes among the
parties arising under the plan is
minimal because the plan specifies the
methods relating to submitting
reservation requests, requesting releases
of symbols, the operation of waiting
lists, the reuse of symbols, and all other
aspects of reserving and allocating
symbols.136 To the extent that disputes
nonetheless arise and the parties are not
able to resolve them, the Commission
notes that under Rule 608(d) of the Act,
the Commission has broad discretion to
review, either on its own motion or
upon the application of any person
aggrieved thereby, actions taken (or
failures to act) by any person in
connection with an effective national
market system plan.137 Therefore, the
Commission finds that the FiveCharacters Plan’s provision on dispute
resolution is appropriate in the public
interest.
2. The Processor for the Symbol
Reservation System
Under the Five-Characters Plan, the
ISRA would delegate the operation of
the Symbol Reservation System to an
independent third party (the
‘‘Processor’’) and would enter into
contracts with the Processor relating to
the operation of the Symbol Reservation
System.138 The Processor would receive
reservation requests from the parties
and reserve and allocate symbols among
the parties in accordance with the terms
of the plan.139 To this end, the Processor
would create and maintain a symbol
reservation database.140 Parties to the
Five-Characters Plan would determine
the method and frequency of the
evaluation of the Processor at a later
time.
The Commission finds that provisions
of the Five-Characters Plan relating to
the Processor promote the maintenance
135 See
Section IV(b)(2) of the Five-Characters
of fair and orderly markets by ensuring
that a symbol is used for only one
security. The capacity and capability of
the Processor to completely maintain
processes and systems for the
reservation and allocation of symbols
under the plan is integral to this plan’s
effective implementation. Accordingly,
the Commission expects the parties to
the Five-Characters Plan to regularly
evaluate the Processor’s performance.
3. Symbol Reservation System
The Five-Characters Plan provides
that, within 30 days of the
Commission’s approval of the FiveCharacters Plan (unless such time is
extended by the Policy Committee), a
participant in the plan may submit to
the Processor requests for the initial
reservation of symbols.141 A party may
reserve symbols for: (i) The listing of
common stock or any other security,
including options; (ii) with respect to
four- and five-character symbols,142 the
trading of any over-the-counter security;
(iii) the dissemination of a securities
index or other index information; or (iv)
any other purpose authorized by a
majority vote.
To provide sufficient time for SROs to
join the plan and for the plan
participants and the Processor to
implement the Symbol Reservation
System, the Commission is modifying
Section IV(b)(1) of the plan to provide
that the initial symbol reservation
process will begin 60 days after the
Commission’s approval of the plan and
will ensue for a 30-day period.143
a. Perpetual and Limited-Time
Reservations
As noted earlier, under the FiveCharacters Plan, a party may reserve a
limited number of symbols in
perpetuity.144 There would be two
perpetual reservation lists for each
party—one list for one-, two-, and threecharacter symbols and one list for fourand five-character symbols. Each party
could reserve up to 20 one-, two-, or
three-character symbols as perpetual
reservations, and up to 20 four- or five141 See
Section IV(b)(1) of the Five-Characters
Plan.
Plan.
136 See Sections IV(b)(6), IV(c), and IV(d),
respectfully, of the Five-Characters Plan.
137 See Rule 608(d)(1).
138 See Section III of the Five-Characters Plan.
139 One commenter suggested that the
Commission could assign the rights to unused
ticker symbols directly to issuers by auction. See
Angel Letter III at 4–5. The Commission believes
that the proposed allocation of symbol reservation
rights using the Processor under the Five-Characters
Plan is in furtherance of the purposes of the Act.
140 See infra notes 175–178 and accompanying
text for further discussion of the plan provisions on
the database.
142 See discussion supra notes 85–89 and
accompanying text relating to limiting the use of
securities symbols by issuers traded other than on
national securities exchanges to four- and fivecharacter symbols.
143 To conform to the Commission’s modification
of the initial reservation process, the Commission
is also modifying Section IV(c)(1) of the FiveCharacters Plan to clarify that the waiting list
procedure applies during the initial reservation
period rather than within 30 days of the effective
date of the plan.
144 See Section IV(b)(1)(A) of the Five-Characters
Plan.
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character symbols as perpetual
reservations.
A party that requests perpetual
reservations for more symbols than
permitted would be required to place its
symbols requests in priority ranking. A
party could not add symbols to its
perpetual reservation list after the initial
reservation process, except when
reserving a symbol for reuse.145
Symbols could also be reserved for a
limited-time period of 24 months.146
Each party would have two limited-time
reservation lists—one list for one-,
two-, and three-character symbols and
one list for four- and five-character
symbols. Each party could reserve up to
1,500 symbols under the one-, two-, or
three-character limited-time
reservations list and up to 1,500
symbols under the four-or five-character
limited-time reservations list. A party
may not make a limited-time reservation
with respect to a particular symbol
unless the party has a reasonable basis
to utilize the symbol within the next 24
months.
As with perpetual reservation
requests, a party that requests limitedtime reservations for more symbols than
permitted would be required to place its
symbols requests in priority ranking.
b. Processing Reservation Requests
If there is only one party that claims
a legacy reservation, such party would
have priority over other SROs to retain
its reservation of that symbol.147 If more
than one party lays claim to a single
legacy reservation, the Five-Characters
Plan provides a process for resolving
such claims.148 This process is as
follows: First, the Processor would
notify all such parties of the conflicting
claims. Then the parties would have
five business days to reach a mutually
acceptable agreement as to which party
would be permitted to reserve the
symbol. In the absence of an agreement,
the Policy Committee would resolve the
issue by a majority vote of the parties
not claiming the symbol. Where there is
no agreement but the Policy Committee
is able to determine which party has the
earliest proper claim to such symbol,
the plan would require it to resolve the
disagreement in favor of such party. In
the event of a tie vote, the Policy
Committee would establish a random
order of the parties to determine which
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145 See
infra notes 166–174 and accompanying
text for discussion of the plan provision on reusing
a symbol.
146 See Section IV(b)(1)(B) of the Five-Characters
Plan.
147 See supra notes 97–104 and accompanying
text for a discussion of the legacy reservation
process.
148 See Section IV(b)(2)(B) of the Five-Characters
Plan.
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party may reserve the symbol.149 The
Commission believes that the plan
provisions with respect to resolving
legacy reservation claims are consistent
with Rule 608 under the Act which
requires the plan be necessary or
appropriate in the public interest, for
the protection of investors and the
maintenance of fair and orderly markets,
to remove impediments to, and perfect
the mechanisms of, a national market
system, or otherwise in furtherance of
the purposes of the Act.
For the reservation of symbols other
than legacy reservations, if only one
party seeks to reserve a symbol, then the
Processor would reserve such symbol
for that party.150 If multiple parties seek
to reserve a symbol, the Processor
would reserve the symbol based on a
random ordering established by the
Policy Committee.151 If a symbol is not
available for reservation, the Processor
would place the requesting party on a
wait list.152 The Processor would
process a party’s symbol reservation
requests by first reserving symbols up to
the party’s limit for its perpetual
reservations list and then reserving the
remaining requested symbols up to the
limit for its limited-time reservations.153
After the initial reservation process, if
a party submits to the Processor a
request for a limited-time reservation
and the symbol is available, the
Processor would reserve such symbol,
provided that the party has not already
reached its maximum number of
allowed limited-time reservations.154 If
a symbol requested is not available, the
Processor would place the requesting
149 See id. Because the ‘‘random order’’ process
was not described in the proposed plans, the
Commission requested comment about it in the
Symbology Notice. No commenters specifically
responded to this request. The Commission believes
that it is necessary and appropriate in the public
interest to have the Policy Committee determine the
appropriate interpretation and application of the
plan provisions relating to the ‘‘random order’’
process. However, the Commission believes that the
Policy Committee must establish a random order
process that will not be susceptible to gaming by
parties to the plan. For example, the Policy
Committee should not use a system which would
allow SROs to know ahead of time if they are the
party next in line to reserve a given symbol. To the
extent that any of the parties to the plan are
aggrieved by the determination of the Policy
Committee in this regard, the Commission notes
that it has the authority to hear appeals by such
parties. See Rule 608(d), 17 CFR 242.608(d); see
also supra notes 133–137 and accompanying text.
150 See Section IV(b)(2)(C) of the Five-Characters
Plan.
151 See Section IV(b)(2)(D) of the Five-Characters
Plan. See also supra note 149.
152 See Section IV(b)(2)(E) of the Five-Characters
Plan. See also infra notes 162–165 and
accompanying text for a discussion on the waiting
list plan provision.
153 See Section IV(b)(2)(F) of the Five-Characters
Plan.
154 See Section IV(b)(3)(A) of the Five-Characters
Plan.
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party on the waiting list for such
symbol.155
c. Non-Use or Release of Symbols
Within Time Period
The Processor would release any
limited-time reservation symbols not
used within the 24-month time
period.156 A party could also voluntarily
release a reserved symbol. In either case,
upon the release of a symbol, the
Processor would notify the parties on
the waiting list, if any, of the symbol’s
availability. If there is no waiting list or
if no party on the waiting list elects to
reserve such symbol, the Processor
would notify all parties to the plan of
the availability of the symbol. Then, if
more than one party requests the
reservation of such symbol within two
business days of the notice, the
Processor would assign the symbol to
one party and place the other parties on
the waiting list pursuant to a random
order of priority established by the
Policy Committee.157
d. Request for Release of a Symbol
If a party has an immediate need to
use a symbol that another party has
reserved, the requesting party would ask
the party that reserved the symbol and
any other parties on the waiting list
whether such parties would be willing
to release the reserved symbol.158 If the
parties do not agree to release the
symbol, the requesting party would not
obtain the reserved symbol. If the
parties do agree to release the symbol,
the requesting party could include such
symbol as one of its limited-time
reservations. If the requesting party does
not use a released symbol within the 24month period, absent the consent of all
parties initially required to be
contacted, the reservation and waiting
list priority in effect when the
requesting party first made its request
for the release of the symbol would
again be in effect.159
e. Reserving Symbols after Reaching
Maximum Number of Permitted
Reservations
Paragraph (5) of Section IV(b) of the
proposed plans states that a party may
‘‘redesignate’’ a security in certain
155 See
Section IV(b)(3)(B) of the Five-Characters
Plan.
156 See
Section IV(b)(5) of the Five-Characters
Plan.
157 See
158 See
supra note 149.
Section IV(b)(6) of the Five-Characters
Plan.
159 See infra notes 160–161 and accompanying
text for a discussion of ‘‘redesignation’’ relating to
requests for release of symbols under Section
IV(b)(6) of the Five-Characters Plan, which the
Commission is modifying.
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situations. Specifically, following the
initial reservation process, if a party
wishes to add a symbol to its limitedtime reservations and such party already
has the maximum number of
reservations permitted, such party
‘‘must voluntarily release or redesignate
a symbol, as described in subparagraph
(3)(A) above, before it can reserve the
assigned symbol.’’ 160 Similarly, if a
party has an immediate need to use a
symbol that another party has reserved,
the requesting party would ask the party
that reserved the symbol, and any other
parties on the waiting list, whether such
parties would be willing to release the
reserved symbol.161 Then, under
paragraph (6) of Section IV(b) of the
Five-Characters Plan, if the requesting
party is already at the maximum
number of limited-time reservations, the
party could either surrender or
redesignate a symbol as described in
subparagraph (3)(A) of the Plan, before
it can reserve the assigned symbol.
The Commission requested comment
as to the meaning of ‘‘redesignating’’ a
symbol when a party is at the maximum
number of limited-time reservations, but
did not receive any comments. Because
subparagraph (3)(A) of Section IV(b) of
either plan does not discuss
redesignating symbols, the Commission
finds it is necessary and appropriate in
the public interest to remove the
reference to ‘‘redesignate’’ in paragraphs
(5) and (6) of Section IV(b) of the FiveCharacters Plan. Thus, if a requesting
party is already at the maximum
number of limited-time reservations
when reserving a requested symbol,
such party would have to surrender
another symbol in order to reserve the
requested symbol.
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f. Waiting Lists
When one or more parties request to
reserve a symbol that another party has
reserved, the Processor would place
such parties on the waiting list for that
symbol.162 The waiting list would be
based on time priority—that is, the
earliest request would have precedence.
However, as proposed, the FiveCharacters Plans states that, if more than
one party seeks to use a symbol already
in use within either 30 days of the
effective date of the plan or two
business days of notice of a symbol’s
availability, the Policy Committee
would establish a random order of such
160 See
161 See
Section IV(b)(5) of the proposed plans.
Section IV(b)(6) of the Five-Characters
Plan.
162 See
Section IV(c)(1) of the Five-Characters
Plan.
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parties to determine priority on the
waiting list.163
When a symbol becomes available,
the Processor would notify the party
with priority on the waiting list.164 Such
party would then have two business
days to reserve that symbol; otherwise,
the Processor would repeat the process
as necessary with all parties on the
waiting list, in order of priority. The
maximum number of symbols for which
a party may be on the waiting list at any
time would be 100 symbols.165
g. Reuse of a Symbol and Portability of
Symbols in Use
If a party ceases to use a symbol, such
party automatically reserves that
symbol, notwithstanding any other
limits on the number of reserved
symbols under the plan.166
However, there is an exception to this
automatic reservation right when an
issuer transfers its listing from one SRO
to another. In this case, the SRO to
which a listing is transferred would
have the rights to that issuer’s
symbol.167 One commenter, FINRA,
noted that Section (IV)(f) of the FiveCharacters Plan allows the portability of
a symbol only when an issuer ‘‘lists’’ on
a new SRO.168 FINRA noted that this
language may create some ambiguity in
the case when a security delists from an
exchange and is traded on an SRO’s
OTC equity market. A strict
interpretation of the text of Section
(IV)(f) of the Five-Characters, as
proposed, could lead to the conclusion
that an issuer that delists from an
exchange and trades on an OTC market
would lose its rights to its original
symbol. FINRA asked that this provision
of the Five-Characters Plan be amended
to explicitly provide that the portability
rights for an issuer transferring its
listing to another exchange also be
extended to issuers that delist from an
exchange and trade on an OTC equity
market.
NYSE, however, argued that securities
have always lost their listed symbols
after delisting for failure to meet
continue listing standards, and that this
practice is desirable because it alerts
investors as to the failure of the issuer
163 To ensure consistency with the Commission’s
modification of the initial reservation process
timeline (see discussion supra notes 141–143 and
accompanying text), the Commission is also
modifying Section IV(c)(1) of the Five-Characters
Plan to clarify that the waiting list procedure
applies during the initial reservation process.
164 See Section IV(c)(2) of the Five-Characters
Plan.
165 See Section IV(c)(3) of the Five-Characters
Plan.
166 See Section IV(d) of the Five-Characters Plan.
167 See Section IV(f) of the Five-Characters Plan.
168 See FINRA Letter at 2.
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to meet those standards.169 NYSE noted
that, otherwise, investors might mistake
the delisted security for a security that
continues to meet exchange listing
standards. The Commission agrees with
NYSE’s comments with respect to the
potential for investor confusion and
hereby clarifies that issuers that delist
from an exchange and trade on an OTC
equity market shall not have portability
rights for their original symbol.170 In
such cases, Section IV(d) of the FiveCharacters Plan would apply and the
SRO from which the issuer delisted
would automatically have such symbol
reserved. At the same time, the
Commission believes that the near-term
reuse of a delisted security’s original
symbol while the delisted security
trades on an OTC equity market could
cause investor confusion.171 A symbol
could not be reused by a party to
identify a new security unless the party
reasonably determines that such use
would not cause investor confusion.172
A symbol being reused pursuant to
this provision could be reserved as a
perpetual reservation if the party has
not yet reserved the full number of
perpetual reservations available to it.173
Otherwise, such symbol would be
169 See
NYSE Letter at 7.
discussed above, see supra notes 85–89
and accompanying text, securities that trade solely
over-the-counter, which are not subject to listing
standards approved by the Commission, should be
clearly distinguished from exchange-listed
securities. The Commission believes that a change
to an issuer’s symbol following delisting is
desirable to inform investors of the change in status
of the issuer. Therefore, the Commission believes
that it is appropriate to prohibit symbol portability
rights for delisted issuers that trade on an OTC
equity market with security symbols of any length,
including symbols with four- or five-characters.
171 See Section IV(d) of the Five-Characters Plan
(providing that a symbol may not be reused by a
party to the plan to identify a new security, other
than the security that has been trading under such
symbol, unless the party reasonably determines that
such use would not cause investor confusion).
172 See Section IV(d) of the Five-Characters Plan.
One commenter stated that symbols should not be
reassigned until six months after an issuer ceases
to use such symbol in order to avoid customer
confusion. See Angel Letter I at 9. The Commission
notes that this plan provision, without providing a
specific timeframe, prohibits an exchange from
assigning a reused symbol at any time if doing so
would cause investor confusion. The Commission
does not believe that specifying a six-month
timeframe to be appropriate as such a time period
may, in some cases, be too short and the reuse of
a security symbol in such cases may still cause
investor confusion. Although the passage of time is
one key factor, other factors may need to be
considered as well. For example, whether the
original issuer’s securities are traded over-thecounter or have ceased trading altogether is another
factor in evaluating the potential for confusion with
regards to the original listing symbol.
173 Section IV(d) of the Five-Characters Plan also
provides that a party could move a symbol from its
perpetual reservations list to its limited-time
reservations list in order to place the symbol being
reused on its perpetual reservations list.
170 As
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reserved as a limited-time reservation
and the additional symbol could exceed
the limit of the maximum number of
limited-time reservations permitted to a
party under the plan.
The Commission finds that the
foregoing symbol reservation system
provisions of the Five-Characters Plan
will further the purposes of the Act and
that, in particular, they should maintain
fair and orderly markets to assure fair
competition between exchange markets,
consistent with Section 11A(a)(1)(C) of
the Act.174
4. Database
Under the Five-Characters Plan, the
Processor would create and maintain a
symbol reservation database.175 The
database would show all symbols
currently in use and the party using
such symbols.176 A party would be
required to notify the Processor when
the party begins using a reserved
symbol. In addition, the database would
show all symbols reserved on the
perpetual reservations and limited-time
reservations lists, including the
reserving party and the expiration date
for limited-time reservations.177 The
database would also show the waiting
list and the priority order of the waiting
list for each symbol.178
The Commission finds that the
provisions of the Five-Characters Plan
relating to the symbols database will
further the purposes of the Act because
the database of symbols is essential to
ensure that a symbol is used to identify
only one security and therefore will
help in the maintenance of fair and
orderly markets.
5. Confidentiality
The Processor would maintain all
information received from the parties in
strictest confidence and the only
information that the Processor would
make available to the parties is the
symbol reservation database.179 The
Processor would not make the symbol
reservation database available to any
person except the Commission or the
parties, unless otherwise required by
applicable law.
One commenter questioned the need
for confidentiality of the information in
U.S.C. 78k-1(a)(1)(C).
Section IV(e) of the Five-Characters Plan.
One commenter has expressed an interest in acting
as the Processor for the adopted plan. See SFB
Letter. Another commenter suggested that FINRA be
the Processor. See Issuer Advisory Letter at 3.
176 See Section IV(e)(1) of the Five-Characters
Plan.
177 See Section IV(e)(2) of the Five-Characters
Plan.
178 See Section IV(e)(3) of the Five-Characters
Plan.
179 See Section VI of the Five-Characters Plan.
this database, arguing that issuers may
want to know if a symbol is available to
reserve it in advance.180 The
Commission does not believe that the
Act imposes any requirement to make
this information available publicly.181
Therefore, the Commission finds that
the confidentiality provisions of the
Five-Characters Plan are appropriate in
the public interest.
6. Term of Plan Withdrawal—NonTransferability of Rights under the Plan
A party wishing to withdraw from the
plan would be required to provide at
least six months prior written notice to
the other parties.182 The withdrawing
party would remain liable for its
proportionate share of costs and
expenses during the time it was a party
to the plan, but would have no further
obligations after the withdrawal.
In addition, an SRO would cease to be
a party to the plan when it ceases to
maintain a facility for the quoting and
trade reporting of securities transactions
or ceases to use symbols subject to the
plan, except upon the agreement of the
remaining parties.183 To be approved as
a continuing party, the plan would
require a majority vote of the remaining
parties.
The right of a party to participate in
the Symbol Reservation System under
the plan is not transferable without the
consent of the other parties.184
However, if a party is subject to a
merger, combination, or other
reorganization or the sale of all or
substantially all of its assets, including
its registration as an SRO, the surviving
entity would automatically become
subject to the plan and could use the
Symbol Reservation System.
The Commission finds that the
provisions of the Five-Characters Plan
relating to a party withdrawing from the
plan will further the purposes of the Act
because, by specifying a party’s terms of
withdrawal, the plan helps to ensure a
fair and orderly market.
7. Amendments to the Plan
The plan may be amended from time
to time when authorized by the
affirmative vote of all the parties,
subject to any required approval of the
Commission.185 One commenter
67231
questioned the efficacy of requiring
unanimous approval for plan
changes.186 Although the Commission
agrees that the plan’s unanimity
provision with respect to amendments
may, in some cases, not be the most
efficient method, the Commission notes
that the signatory SROs to both
proposed plans agreed to this required
voting methodology and the
Commission is reluctant to require a
different voting methodology for plan
amendments at this time.
The Commission finds that the
provision of the Five-Characters Plan
relating to amendments to the plan is in
furtherance of the purposes of the Act
in that it specifies the method by which
the plan may be amended. The
Commission will monitor this process to
determine whether the unanimity
provision is used for anti-competitive
purposes or for any other purpose not
consistent with the Act. The
Commission notes that SROs proposing
an amendment to a national market
system plan must file such amendment
with the Commission pursuant to Rule
608 under the Act.187 The Commission
also notes that it has the authority to
amend any effective national market
system plan under Rule 608 under the
Act.188
8. Development and Implementation
Phases of the Plan
The Five-Characters Plan states that it
would be implemented upon the
Commission’s approval. Although the
letters accompanying both proposed
plans state that the parties will
determine the development and
implementation phase later or in
accordance to a timetable to which the
parties and the Processor will agree,189
the plans as submitted to the
Commission both provided that the
parties would commence the initial
reservation process upon Commission
approval.190 As discussed above,
however, the Commission has modified
the Five-Characters Plan to commence
the initial reservation process 60 days
from the Commission’s approval of the
plan.191 The Commission has made this
modification in order to give the SROs
that are not signatories to the FiveCharacters Plan time to obtain the
174 15
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175 See
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180 See
Angel Letter II at 5.
Commission also notes that the
confidentiality requirement under the plan applies
only to the Processor, and that nothing under the
plan requires confidentiality on the part of the
parties. Therefore, to the extent an issuer wants to
know if a symbol is available, it could request such
information from one of the parties.
182 See Section VII of the Five-Characters Plan.
183 See Section I(d) of the Five-Characters Plan.
184 See Section VII of the Five-Characters Plan.
185 See Section VIII of the Five-Characters Plan.
181 The
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186 See Angel Letter II at 4. The Commission
notes, however, that other national market system
plans have similar provisions (see, e.g., the Options
Linkage Plan at https://www.optionsclearing.com/
initiatives/ola/ola.jsp).
187 See 17 CFR 242.608(a).
188 See 17 CFR 242.608(a)(2) and (b)(2).
189 See Paragraph 4 of the letters accompanying
each proposed plan.
190 See Sections IV(b)(1) of both proposed plans.
191 See discussion supra notes 141–143 and
accompanying text.
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necessary approvals to join the
approved plan. The Commission
believes 60 days is a reasonable period
of time to obtain such approval. The
Commission notes that this approval
order only requires SROs that choose to
list securities or designate securities for
quoting on a quotation medium to join
the plan (and all such SROs were party
to one of the two submitted plans);
those SROs that do not intend to list or
designate securities for quoting are not
required to join the plan.192
The Commission finds that the
modified implementation provision of
the Five-Characters Plan will further the
purposes of the Act because it allots
additional time for non-signatory SROs
to join the approved plan.
9. Terms and Conditions of Access
Any SRO that meets the eligibility
standards of the plan may become a
party thereto by signing a current copy
of the plan and paying to the other
parties a share of the aggregate
development costs previously paid by
such parties to the Processor.
The Commission finds that this
provision of the Five-Characters Plan
will further the purposes of the Act in
that it should assure fair competition
among exchange markets, in particular
new SROs, consistent with Section
11A(a)(1)(C)(ii) of the Act.193
IV. Conclusion
It is hereby ordered, that pursuant to
Section 11A(a)(3)(B) of the Act1 194 and
Rule 608,195 that the Five-Characters
Plan submitted by CHX, FINRA,
Nasdaq, NSX, and Phlx, as modified
herein, is approved and declared
effective,196 and that CHX, FINRA,
Nasdaq, NSX, and Phlx are authorized
to act jointly to implement the FiveCharacters Plan as a means of
facilitating a national market system.
It is hereby further ordered, that,
within 60 days from the date of this
approval order, any SRO that chooses to
list securities on its market or to
designate securities for quoting on a
quotation medium must join the FiveCharacters Plan, as modified herein,197
and act jointly with other parties to the
plan to implement the approved FiveCharacters Plan.198
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192 See
supra notes 68–70 and accompanying text.
U.S.C. 78k–l(a)(1)(C)(ii).
194 15 U.S.C. 78k–l(a)(3)(B).
195 17 CFR 242.608.
196 The approved plan is attached here as
Appendix A.
197 Id.
198 See 17 CFR 242.608(b)(2).
193 15
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The self-regulatory organizations (‘‘SROs’’)
named below as the parties to this Plan (as
defined below), and any other SROs that may
subsequently become parties to this Plan,
maintain facilities for the quoting and trade
reporting of securities that: (i) Are NMS
securities as currently defined in Rule
600(a)(46) under the Securities Exchange Act
of 1934; and (ii) any other equity securities
quoted, traded and/or trade reported through
an SRO facility (collectively, ‘‘Plan
Securities’’). These SROs have determined
that in order to enhance the effectiveness and
efficiency of the national market system and
to provide for the fair competition between
the SROs, they should establish a uniform
system for the selection and reservation of
securities symbols (the ‘‘Symbol Reservation
System’’). These SROs therefore have jointly
developed and agreed upon the following
Plan for this purpose, and have agreed to file
it with the Securities and Exchange
Commission (‘‘Commission’’) as a national
market system plan in accordance with and
subject to Rule 608 under the Securities
Exchange Act of 1934, as amended (the
‘‘Exchange Act’’). The term ‘‘Plan’’ as used
herein shall mean this plan as from time to
time amended in accordance with the
provisions hereof. As of 90 days from the
Commission’s approval of this Plan, this Plan
will be the exclusive means of allocating and
using symbols of 1, 2, 3, 4, or 5 characters
in length, and there will be no difference
between capital and lowercase letters under
this Plan.
The Intermarket Symbols Reservation
Authority (‘‘ISRA’’) shall mean the parties to
the Plan acting jointly pursuant to the terms
of the Plan. Pursuant to Section 11A(a)(3)(B)
of the Exchange Act, the Commission’s
approval of the Plan and any amendments
thereto shall authorize and require the parties
to the Plan to act jointly with respect to
matters as to which they share authority
hereunder in planning, developing and
operating the systems and facilities used for
this purpose, provided that such joint action
shall be limited to circumstances in which it
is necessary in order to fulfill the purposes
and objectives as stated in the Plan.
and having its principal place of business at
One Liberty Plaza, New York, NY, 10006.
National Stock Exchange, Inc. (‘‘NSX’’),
registered as a national securities exchange
under the Exchange Act and having its
principal place of business at 440 South
LaSalle Street, Suite 2600, Chicago, IL 60605.
Philadelphia Stock Exchange, Inc.
(‘‘PHLX’’), registered as a national securities
exchange under the Exchange Act and having
its principal place of business at 1900 Market
Street, Philadelphia, Pennsylvania 19103.
(b) Each of the parties represents to the
other parties that (i) at any time it seeks to
reserve symbols using 1, 2 or 3 characters, it
will have the actual technical and physical
capability through its facilities to
immediately quote and trade report in Plan
Securities using 1, 2 or 3 characters, and (ii)
at any time it seeks to reserve symbols using
4 or 5 letter characters, it will have the actual
technical and physical capability through its
facilities to immediately quote and trade
report trades in Plan Securities using 4 or 5
characters. This Plan shall not apply in any
respect to any suffix or special conditional
identifier that may follow a ‘‘root’’ symbol of
1, 2, 3, 4 or 5 characters in length.
(c) Any other SRO that maintains a market
for the listing or trading of Plan Securities,
in accordance with rules approved by the
Commission, which securities are identified
by one, two or three character symbols, on
the one hand, or four or five character
symbols, on the other hand, in each case
prior to any suffix or special conditional
identifier (‘‘Applicant’’), may become a party
to the Plan. An Applicant may become a
party to the Plan by signing a current copy
of the Plan and paying to the other parties
a proportionate share of the aggregate
development costs previously paid by such
parties to the Processor (as defined in Section
III below), which aggregate development
costs totaled $[amount to be determined after
Plan effectiveness and implementation, and
filed with the Commission as an amendment
to the Plan].
(d) Subject to Section VII below concerning
the continuing liability of former parties for
certain obligations under the Plan, an SRO
that is a party to the Plan shall cease to be
a party at such time as it ceases to maintain
a facility for the quoting and trade reporting
of securities transactions or ceases to use
symbols subject to the Plan, unless such SRO
asks to continue as a party and the other
parties to the Plan, by a majority vote,
approve such SRO to continue as a party.
I. Parties
(a) The parties to the Plan are the following
SROs:
Chicago Stock Exchange, Inc. (‘‘CHX’’),
registered as a national securities exchange
under the Exchange Act and having its
principal place of business at 440 South
LaSalle Street, Chicago, IL 60605.
Financial Industry Regulatory Authority,
Inc., registered as a national securities
association under the Exchange Act and
having its principal place of business at 1735
K Street, NW., Washington, DC 20006.
The Nasdaq Stock Market LLC
(‘‘NASDAQ’’) registered as a national
securities exchange under the Exchange Act
II. Administration of ISRA
(a) ISRA Policy Committee. ISRA shall be
administered by a Policy Committee, which
shall be constituted as provided in paragraph
II(c), below.
(b) Authority of Policy Committee. Except
as otherwise expressly provided in the Plan,
the ISRA Policy Committee shall make all
policy decisions on behalf of ISRA in
furtherance of the functions and objectives of
ISRA under the Exchange Act and under the
Plan, including but not limited to the
following:
(1) Overseeing the operation of the Symbol
Reservation System and making all
administrative decisions necessary with
By the Commission.
Florence E. Harmon,
Acting Secretary.
Appendix A—National Market System
Plan for the Selection and Reservation
of Securities Symbols
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respect to the operation of the system in
accordance with the Plan;
(2) Making all determinations pertaining to
contracts with parties to the Plan or with
other persons who provide goods or services
to ISRA;
(3) Determining all other questions
pertaining to the planning, developing and
operating of ISRA, including those pertaining
to budgetary or financial matters.
(c) Composition and Selection of Policy
Committee. The Policy Committee shall
consist of one voting member representing
each party and one alternate voting member
representing each party, with each alternate
having a right to vote only in the absence of
that party’s voting member. Each of the
voting and alternate voting members of the
Policy Committee shall be appointed by the
party that he or she represents, and shall
serve at the will of the party appointing such
member.
(d) Action of Policy Committee. Each of the
parties shall have one vote on all matters
voted upon by the Policy Committee and,
except as otherwise provided herein, action
of ISRA under the Plan shall be authorized
by the affirmative vote of a majority of the
members of the Policy Committee, subject to
the approval of the Commission whenever
such approval is required under applicable
provisions of the Exchange Act and the rules
of the Commission thereunder. Action
authorized in accordance with the Plan shall
be binding upon all of the parties, without
prejudice to the rights of any party to present
contrary views to any regulatory body or in
any other appropriate forum.
(e) Meetings of the Policy Committee.
Regular meetings of the Policy Committee
may be attended by each party’s voting
representative or alternate voting
representative, by one or more nonvoting
representatives of the parties, and by such
other persons that the Committee may invite
to attend. Meetings of the Policy Committee
shall be held at least annually and at such
other times as shall from time to time be
determined by the Policy Committee, on not
less than ten (10) business days’ notice.
Special meetings of the Policy Committee
may be called upon the request of two or
more parties on not less than two (2) business
days’ notice. At each meeting of the Policy
Committee, the Committee shall designate
one of the representatives of the parties to
preside as Chairman of the meeting and shall
designate a person in attendance to act as
Secretary to record the minutes thereof. The
location of the regular and special meetings
of the Policy Committee shall be determined
by the Committee. Members of the Policy
Committee may be present at a meeting by
conference telephone or other electronic
means that enables each of them to hear and
be heard by all others present at the meeting,
and action may be taken without a meeting
if all of the members entitled to vote consent
thereto in writing.
III. Performance of Functions
As determined by its Policy Committee,
ISRA will delegate the operation of the
Symbol Reservation System to an
independent third party (the ‘‘Processor’’),
and will enter into contracts with such party
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describing the functions to be performed by
it and the service levels and other terms
related thereto. The Processor shall be
required to agree that any nonpublic
information that becomes known to it shall
be held in confidence, except as it may be
shared with the Commission or other
appropriate governmental regulatory
authorities or as otherwise required by
applicable law.
IV. The Symbol Reservation System
(a) Scope of the Symbol Reservation
System. The Symbol Reservation System
shall cover the allocation of all symbols used
to identify Plan Securities. This Plan covers
only the ‘‘root’’ symbol to be disseminated,
which is the one through five character
symbol, in each case prior to any suffix or
special conditional identifier.
(b) Reservation and Use of Symbols.
(1) Submission of Initial Reservation
Requests. Beginning 60 days after the
Commission’s approval of this Plan, for a
period of 30 days, with respect to symbols for
which a party meets the requirements of
Section I.(b) at the time of approval, and
within 45 days after a party meets the
requirements of Section I.(b) with respect to
other symbols (unless such time is extended
by the Policy Committee), such party may
submit to the Processor requests for the
initial reservation of symbols as follows. A
party may request a symbol for: (i) The listing
of common stock or any other security,
including options; (ii) with respect to fourand five-character symbols, the trading of any
security over-the-counter; (iii) the
dissemination of a securities index or other
index information; or (iv) any other purpose
authorized by a majority vote of the parties.
However, no party may reserve or use a 1, 2
or 3 character symbol for a security not listed
on a national securities exchange. All initial
symbol requests must specify whether the
party believes that it had ‘‘reserved’’ a
requested symbol in the system in use prior
to the Commission’s approval of this Plan.
Initial requests may be for perpetual as well
as limited-time reservations as specified
below.
(A) Perpetual Reservations. A requesting
party may request to reserve a limited
number of symbols without any time or other
limitations or restrictions. A perpetual
reservation is a ‘‘List A reservation.’’ A
separate List A shall be maintained for
symbols using one, two or three characters,
on the one hand, and symbols using four or
five characters, on the other hand, and this
Plan shall be applied separately to each List
A. For the avoidance of doubt, symbols under
the List A for one, two or three characters
and symbols under the List A for four or five
characters are not interchangeable with one
another for any purpose under this Plan.
Subject to paragraph (d) below, a party may
not add symbols to a given List A after the
initial reservation process for that given list
A. With respect to symbols using one, two or
three characters, a party may not have more
than 20 List A reservations. With respect to
symbols using four or five characters, a party
may not have more than 20 List A
reservations. A party requesting to reserve
more symbols than permitted pursuant to
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67233
this paragraph must place its List A
reservation requests in priority ranking.
(B) Limited-Time Reservations. In addition
to List A reservations, a party may submit
requests to reserve symbols for a limited time
period (‘‘List B reservations’’). A separate List
B shall be maintained for symbols using one,
two or three characters, on the one hand, and
symbols using four or five characters, on the
other hand, and this Plan shall be applied
separately to each List B. Symbols under the
two lists are not interchangeable for any
purpose under this Plan. With respect to
symbols using one, two or three characters
each party may have a total of up to 1,500
List B reservations at any given time. With
respect to symbols using four or five
characters, each party may have up to a total
of 1,500 List B reservations. A party’s
permitted List B reservations shall be for 24
months. A party requesting to reserve more
symbols than permitted pursuant to this
paragraph must place its List B reservation
requests in priority ranking. Notwithstanding
anything else herein this sub-paragraph (B),
no party shall make a List B reservation
request with respect to a particular symbol
unless said party has a reasonable basis to
believe it will utilize such symbol within the
next 24 months.
(2) The Processing of Initial Reservation
Requests.
(A) If only one party claims that it had a
symbol properly ‘‘reserved’’ prior to the
effective date of this Plan (A ‘‘Legacy
Reservation’’), the Processor shall reserve
such symbol for that party, provided that
party represents it has a reasonable basis to
believe it will utilize such symbol within the
next six (6) months. Legacy Reservations
shall not be counted as List A or List B
reservations for the purposes of subparagraphs (1)(A) and (1)(B) of this Section.
Should the relevant party not use a symbol
that is the subject of a Legacy Reservation
within the six (6) month period, said symbol
shall be released by the Processor pursuant
to paragraph 5 below, provided that a party
may request an extension of a Legacy
Reservation for an additional six (6) month
period provided said party has a reasonable
basis to believe it will utilize such symbol
within that period. If not so used within that
period, said symbol shall be released by the
Processor pursuant to paragraph 5 below.
(B) If multiple parties meeting the
requirements of sub-paragraph (A) above
claim to have properly reserved a symbol
prior to the Commission’s approval of this
Plan, the Processor shall notify all parties
making such claims of that fact, whereupon
such parties shall have five business days in
which to reach a mutually acceptable
agreement as to which party shall be
permitted to reserve such symbol. If the
parties fail to reach agreement during such
period, then the Policy Committee shall
resolve such conflicting claims (in favor of
the party with the earliest proper claim to
such symbol, if that fact can be determined)
by a majority vote of the parties not claiming
such symbol, it being understood that proper
reservation of a symbol includes reservation
under the reservation system in effect prior
to the adoption of this Plan. The Policy
Committee shall provide each such party the
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opportunity to provide evidence of how and
when it reserved such symbol, and the
members of the Policy Committee who vote
in these matters shall in good faith consider
such evidence in reaching their decision. In
the event of a tie vote, the Policy Committee
shall establish a random order of the parties
to determine which party may reserve the
symbol.
(C) If only one party seeks to reserve a
symbol that no party has properly reserved
prior to the Commission’s approval of this
Plan, then the Processor shall reserve that
symbol for that party.
(D) If multiple parties seek to reserve a
symbol, but no such party claims to have
properly reserved the symbol prior to the
Commission’s approval of this Plan, then the
Processor shall reserve such symbol pursuant
to a random ordering of the parties that the
Policy Committee shall establish.
(E) If a party requests a symbol that is not
available because the symbol is in use or has
properly been reserved by another party, the
Processor will place all such parties on a
waiting list for the symbol pursuant to
paragraph (c) below.
(F) Using this methodology, the Processor
will reserve for a party all requested symbols
up to the limits specified above for List A
and List B based on the requesting party’s
priority ranking. Once a party has reached its
limit on the number of permitted List A
reservations, the Processor will process all
such party’s remaining requests for List A
symbols as List B requests before processing
that party’s requests for List B reservations.
(3) Subsequent Reservations. At any time
following the initial allocation of symbols
pursuant to paragraphs (1) and (2) above, a
party may submit to the Processor a request
for a List B reservation of one or more
symbols as follows:
(A) If a requested symbol is available the
Processor will reserve the symbol for the
requesting party if at that time it does not
hold the maximum number of List B
reservations available to it. If necessary to
stay within the maximum number of
reservations permitted under subparagraph
(1)(B) above, the party must provide the
Processor with a List B symbol to release
upon reservation of the new symbol.
(B) If a requested symbol is not available
either because it is in use or because another
party has reserved the symbol, the Processor
will place the party on the waiting list
pursuant to paragraph (c) below.
(4) Notice of Use of Reserved Symbols. A
party shall notify the Processor when it
begins to use a reserved symbol.
(5) Non-Use or Release of Symbols Within
Time Period. If a symbol reserved on List B
is not used within the specified 24-month
time limit, the Processor shall release the
symbol. In addition, a party at any time may
voluntarily release a reserved symbol by so
notifying the Processor. In either case, the
Processor shall make the symbol available for
reservation to those parties on the waiting list
pursuant to subparagraph (c)(2) below. If
there is no waiting list for the symbol, or if
no party on such list decides to reserve the
symbol, the Processor shall give reasonable
notice to all parties of the availability of the
symbol, and any party may request the
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reservation of such symbol. If more than one
party requests the reservation of such symbol
within two business days of such notice, the
Processor shall assign the symbol to one such
party and shall place the other parties on the
waiting list pursuant to a random order of
priority that the Policy Committee shall
establish. If necessary to stay within the
maximum number of reservations permitted
under subparagraph (1)(B) above, the
requesting party must voluntarily release a
symbol, as described in subparagraph (3)(A)
above, before it can reserve the assigned
symbol.
(6) Request for Release of a Symbol. If a
party has an immediate need to use a symbol
that another party reserved, it can ask (i) the
party that has the symbol reserved and (ii)
any other parties on the waiting list with
priority over the requesting party whether
such parties are willing to release such
symbols. If any such party does not agree to
the release, the then-current reservation and
waiting list priority shall remain unchanged.
If all such parties agree to the release, then
the requesting party may include such
symbol as one of its List B reservations for
24 months. If necessary to stay within the
maximum number of reservations permitted
under subparagraph (1)(B) above, the
requesting party must voluntarily release a
symbol, as detailed in subparagraph (3)(A)
above, before it can reserve the requested
symbol. If the requesting party does not use
the symbol within 24 months, absent the
consent of all the parties initially required to
be contacted, the reservation and waiting list
priority in effect when the requesting party
first made its request shall again be in force.
(c) Waiting List.
(1) Placing a Party on a Waiting List.
Pursuant to subparagraphs (2)(D) and (3)(B)
above, if one or more parties request to
reserve a symbol that another party has under
reservation, the Processor shall place such
parties on a waiting list for such symbol. The
Processor shall prioritize parties on the
waiting list based on the earliest time that
each requested the reservation from the
Processor; provided, however, that if more
than one party seeks to use a symbol already
in use either (A) during the initial reservation
period or (B) within two business days of
notice of a symbol’s availability under
subparagraph (b)(5) above, the Policy
Committee shall establish a random order of
those parties to determine priority on the
waiting list.
(2) Availability of Symbols. Subject to
paragraph (d) below, if a symbol becomes
available for any reason, the Processor shall
provide the party with time priority on the
waiting list as to that symbol with notice of
such availability. Such party shall have two
business days to reserve the symbol. If the
party with priority does not reserve the
symbol, the Processor shall repeat this
process as needed with all parties on the
waiting list in the order of their priority. If
necessary to stay within the maximum
number of reservations permitted under
subparagraph (b)(1)(B) above, the reserving
party must voluntarily release or redesignate
a symbol, as detailed in subparagraph
(b)(3)(A) above, before it can reserve the
requested symbol.
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(3) Waiting List Limits. No party may be on
the waiting list for more than 100 symbols at
any given time.
(d) Reuse of a Symbol. Subject to paragraph
(f) below, if a party ceases to use a symbol
(due, for example, but not limited to, the
delisting of a security through merger or
otherwise), such party automatically shall
have that symbol reserved for a period of 24
months, notwithstanding any other limits on
the number of reserved symbols specified in
this Plan. If at the time it ceases to use a
symbol that party does not then have
reserved on List A the full number of
symbols initially available to it pursuant to
subparagraph (b)(1)(A) above, the party may
place such symbol on List A. If the party has
reserved on List A the full number of
symbols available to it, that party may move
a List A symbol to List B in order to place
the symbol to be reused on List A,
notwithstanding the fact that the party may
then have the maximum number of symbols
reserved on List B. If the party does not place
the symbol on List A, and if the party does
not use the symbol within 24 months, the
symbol shall be released for use pursuant to
subparagraph (b)(5) above. A symbol may not
be reused by a party to identify a new
security (other than the security that has been
trading under such symbol), unless the party
reasonably determines that such use would
not cause investor confusion.
(e) Database. The Processor shall create
and maintain a symbol reservation database
(‘‘Database’’). All parties and the Commission
(but no other person) shall have access to the
Database except to the extent required by
applicable law. The Database shall show:
(1) All symbols that are currently in use,
identifying the party using a symbol;
(2) All symbols that are reserved on Lists
A and B (separately for symbols using one,
two or three characters on the one hand, and
four or five characters on the other hand),
including the party reserving each symbol
and the date on which List B reservations
will lapse if the symbol is not used; and
(3) Whether there is a waiting list for a
symbol, and if so, the identities and priorities
of the parties on the waiting list.
(f) Portability of Symbols in Use. If an SRO
(a ‘‘New SRO’’) lists a security or product
that previously was listed on another SRO (a
‘‘Former SRO’’), the New SRO shall have the
rights to that symbol unless, in its discretion,
it consents to the symbol being retained by
the Former SRO.
V. Financial Matters.
(a) Initial Development Costs. The parties
will share the initial development costs prorata based on the number of symbols initially
reserved by each party pursuant to Section
IV, paragraph B(1) hereof. Any new party that
joins the plan shall be liable for a pro-rata
portion of the initial development costs
based upon the number of symbols reserved
by said party during the first twelve (12)
months of such party’s membership.
(b) Continuing Costs. Costs and expenses of
ISRA (other than development costs) will be
shared among the parties pro-rata based on
the number of additional symbols reserved in
each calendar year, estimated quarterly.
Notwithstanding the foregoing, the Policy
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Committee may devise alternative costallocation methodology with respect to
special non-initial development projects.
VI. Confidentiality
The Processor will maintain in the strictest
confidence all of the information it receives
from the parties. The only information the
Processor will make available to the parties
is the Database. The Processor will not make
the Database available to any person other
than the parties or the Commission, except to
the extent required by applicable law.
VII. Term of Plan Withdrawal; NonTransferability of Rights Under the Plan
The Plan shall remain in effect so long as
there are two or more parties to the Plan. Any
party may withdraw from the Plan at any
time on not less than six months prior
written notice to each of the other parties.
Any party withdrawing from the Plan shall
remain liable for its proportionate share of
costs and expenses allocated to it pursuant to
Section V above for the period during which
it was a party, but it shall have no further
obligations under the Plan or to any of the
other parties with respect to the period
following the effectiveness of its withdrawal.
The right of a party to participate in the
Symbol Reservation System under the Plan
shall not be transferable without the consent
of the other parties, provided, however, that
if a party is subject to a merger, combination
or other reorganization or the sale of all or
substantially all of its assets, including it’s
registration as an SRO, the surviving or
acquiring entity shall automatically become
subject to the Plan and may use the Symbol
Reservation System instead of the prior party
and with its rights and subject to its
liabilities under the Plan.
VIII. Amendments to the Plan
The Plan may be amended from time to
time when authorized by the affirmative vote
of all of the parties subject to any required
approval of the Commission.
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IX. Applicability of Exchange Act
The rights and obligations of the parties to
the Plan shall at all times be subject to any
applicable provisions of the Exchange Act
and any rules and regulations promulgated
hereunder.
X. Notices
Any notice given to any of the parties or
to ISRA for purposes of the Plan shall be via
electronic mail. All notices shall be deemed
given immediately, unless the sender
receives notification of a failure to deliver the
electronic mail. Alternatively, a party may
give notice in writing, and shall be deemed
given 48 hours after being sent if sent by
prepaid registered or certified United States
mail, return receipt requested (if available),
or by overnight mail with a nationally
recognized overnight mail courier, addressed
to the party at its address indicated below in
the case of notice to one or more parties, or
addressed to all of the parties at their
addresses listed in Section I above.
XI. Counterparts and Signatures
The Plan may be executed in any number
of counterparts, no one of which need
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contain all signatures of all Participants, and
as many of such counterparts as shall
together contain all such signatures shall
constitute one and the same instrument.
IN WITNESS WHEREOF, this Plan has been
executed as of the l day of ll by each of
the parties hereto.
CHICAGO STOCK EXCHANGE, INC.
By: lllllllllllllllllll
FINANCIAL INDUSTRY REGULATORY
AUTHORITY, INC.
BY: lllllllllllllllllll
THE NASDAQ STOCK MARKET, LLC
By: lllllllllllllllllll
NATIONAL STOCK EXCHANGE, INC.
By: lllllllllllllllllll
PHILADELPHIA STOCK EXCHANGE, INC.
By: lllllllllllllllllll
[FR Doc. E8–26880 Filed 11–12–08; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–58902; File No. SR–CBOE–
2008–112]
Self-Regulatory Organizations;
Chicago Board Options Exchange,
Incorporated; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Relating to Temporary
Membership Status and Interim
Trading Permit Access Fees
November 5, 2008.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 notice is hereby given that on
October 31, 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 the CBOE. The Commission
is publishing this notice to solicit
comments on the proposed rule change
from interested parties.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
CBOE proposes to adjust (1) the
monthly access fee for persons granted
temporary CBOE membership status
(‘‘Temporary Members’’) pursuant to
Interpretation and Policy .02 under
CBOE Rule 3.19 (‘‘Rule 3.19.02’’) and (2)
the monthly access fee for Interim
Trading Permit (‘‘ITP’’) holders under
CBOE Rule 3.27. 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’s Public Reference Room.
1 15
PO 00000
U.S.C. 78s(b)(1).
Frm 00118
Fmt 4703
Sfmt 4703
67235
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. The 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
The current access fee for Temporary
Members under Rule 3.19.02 2 and the
current access fee for ITP holders under
Rule 3.27 3 are both $10,118 per month.
Both access fees are currently set at the
indicative lease rate (as defined below)
for October 2008. The Exchange
proposes to adjust both access fees
effective at the beginning of November
2008 to be equal to the indicative lease
rate for November 2008 (which is
$9,937). Specifically, the Exchange
proposes to revise both the Temporary
Member access fee and the ITP access
fee to be $9,937 per month commencing
on November 1, 2008.
The indicative lease rate is defined
under Rule 3.27(b) as the highest
clearing firm floating monthly rate 4 of
the CBOE Clearing Members that assist
in facilitating at least 10% of the CBOE
transferable membership leases.5 The
Exchange determined the indicative
lease rate for November 2008 by polling
each of these Clearing Members and
obtaining the clearing firm floating
monthly rate designated by each of
these Clearing Members for that month.
The Exchange used the same process
to set the proposed Temporary Member
2 See Securities Exchange Act Release No. 56458
(September 18, 2007), 72 FR 54309 (September 24,
2007) (SR–CBOE–2007–107) for a description of the
Temporary Membership status under Rule 3.19.02.
3 See Securities Exchange Act Release No. 58178
(July 17, 2008), 73 FR 42634 (July 22, 2008) (SR–
CBOE–2008–40) for a description of the Interim
Trading Permits under Rule 3.27.
4 Rule 3.27(b) defines the clearing firm floating
monthly rate as the floating monthly rate that a
Clearing Member designates, in connection with
transferable membership leases that the Clearing
Member assisted in facilitating, for leases that
utilize that monthly rate.
5 The concepts of an indicative lease rate and of
a clearing firm floating month rate were previously
utilized in the CBOE rule filings that set and
adjusted the Temporary Member access fee. Both
concepts are also codified in Rule 3.27(b) in relation
to ITPs.
E:\FR\FM\13NON1.SGM
13NON1
Agencies
[Federal Register Volume 73, Number 220 (Thursday, November 13, 2008)]
[Notices]
[Pages 67218-67235]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: E8-26880]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-58904; File No. 4-533]
Joint Industry Plan; Order Approving the National Market System
Plan for the Selection and Reservation of Securities Symbols Submitted
by the Chicago Stock Exchange, Inc., The Nasdaq Stock Market, Inc.,
National Association of Securities Dealers, Inc. (n/k/a Financial
Industry Regulatory Authority, Inc.), National Stock Exchange, Inc.,
and Philadelphia Stock Exchange, Inc.
November 6, 2008.
I. Introduction
On July 17, 2007, the Commission published for comment \1\ a
detailed summary of two proposed plans for the purpose of the selection
and reservation of securities symbols: the Five-Characters Plan and the
Three-Characters Plan. On January 25, 2008, the Commission published
Amendment No. 1 to the Three-Characters Plan for public comment.\2\ The
proposed plans were filed jointly by two different groups of self-
regulatory organizations (``SROs'') pursuant to Rule 608 of Regulation
NMS under the Securities Exchange Act of 1934 (``Act'') (``Rule
608'').\3\ The Chicago Stock Exchange, Inc. (``CHX''), The Nasdaq Stock
Market, Inc. (``Nasdaq''), National Association of Securities Dealers,
Inc. (``NASD'') (n/k/a Financial Industry Regulatory Authority, Inc.
(``FINRA'')),\4\ National Stock Exchange, Inc. (``NSX''), and
Philadelphia Stock Exchange, Inc. (``Phlx'') filed the Five-Characters
Plan.\5\ The American Stock Exchange LLC (``Amex''), Chicago Board
Options Exchange, Incorporated (``CBOE''), International Securities
Exchange, LLC (``ISE''), the New York Stock Exchange LLC (``NYSE''),
and NYSE Arca, Inc. (``NYSE Arca'') filed the Three-Characters Plan.\6\
---------------------------------------------------------------------------
\1\ See Securities Exchange Act Release No. 56037 (July 10,
2007), 72 FR 39096 (File Nos. 4-533 and 4-534) (``Symbology
Notice''). The full text of each plan is also available to
interested persons on the Commission's Web site at https://
www.sec.gov/rules/sro/nms.shtml#4-534 and https://www.sec.gov/rules/
sro/nms.shtml#4-533, respectively.
\2\ See Securities Exchange Act Release No. 57171 (January 18,
2008), 73 FR 4645.
\3\ 17 CFR 242.608.
\4\ On July 26, 2007, the Commission approved a proposed rule
change filed by NASD to amend NASD's Certificate of Incorporation to
reflect its name change to Financial Industry Regulatory Authority
Inc., or FINRA, in connection with the consolidation of the member
firm regulatory functions of NASD and NYSE Regulation, Inc. See
Securities Exchange Act Release No. 56146 (July 26, 2007), 72 FR
42190 (August 1, 2007) (SR-NASD-2007-053).
\5\ FINRA, Nasdaq, NSX, and Phlx filed the Five-Characters Plan
with the Commission on March 23, 2007. CHX, FINRA, Nasdaq, NSX, and
Phlx filed a Supplement to this proposed plan on April 23, 2007. In
the Supplement, CHX joined as a party proposing the Five-Characters
Plan.
\6\ On March 23, 2007, Amex, NYSE and NYSE Arca filed the Three-
Characters Plan with the Commission. In Amendment No. 1 to the
Three-Characters Plan, filed on August 3, 2007, CBOE and ISE joined
as parties to the proposed plan.
---------------------------------------------------------------------------
Although the two plans are identical in many respects, they differ
on several significant matters. The primary difference between the two
plans is their scope. The Three-Characters Plan would only cover one-,
two-, and three-character symbols; the Five-Characters Plan would cover
one-, two-, three-, four-, and five-character symbols. In addition, the
plans differ with regard to the parties that are eligible to join the
plan; the reservation rights for perpetual and limited-time
reservations; the portability of symbols for issuers that move their
listing from one market to another; the allocation of costs relating to
the plan; and the process of withdrawing from the plan.
The Commission received 61 comments on the proposed plans from 56
commenters.\7\ Twenty-two
[[Page 67219]]
commenters generally supported the Three-Characters Plan or aspects
thereof,\8\ while 22 commenters generally supported the Five-Characters
Plan or aspects thereof.\9\ The remaining 12 commenters did not
expressly support one plan or another.\10\
---------------------------------------------------------------------------
\7\ Letters to the Commission from Edward F. Tancer, Vice
President & General Counsel, FPL Group, Inc., dated March 28, 2007
(``FPL Letter''); Jason Korstange, SVP, Director of Corporate
Communications, TCF Financial Corporation, dated March 28, 2007
(``TCF Letter''); Timothy J. O'Donovan, Chairman of the Board, Chief
Executive Officer, Wolverine World Wide, Inc., dated March 28, 2007
(``Wolverine Letter''); Leo Liebowitz, Chairman and Chief Executive
Officer, Getty Realty Corp., dated March 29, 2007 (``Getty
Letter''); Edward W. Moore, Vice President, General Counsel &
Secretary, RPM International Inc., dated March 29, 2007 (``RPM
Letter''); Cathy Burzik, President and Chief Executive Officer,
Kinetic Concepts, Inc., dated March 30, 2007 (``KCI Letter'');
Clifton H. Morris, Jr., Chairman, AmeriCredit Corp., dated April 2,
2007 (``AmeriCredit Letter''); David M. Brain, President and CEO,
Entertainment Properties Trust, dated April 3, 2007 (``Entertainment
Properties Letter''); Steven S. Fishman, Chairman, Chief Executive
Officer and President, Big Lots, Inc., dated April 4, 2007 (``Big
Lots Letter''); Mary J. McGinn, Secretary and Deputy General
Counsel, The Allstate Corporation, dated April 5, 2007 (``Allstate
Letter''); Eric W. Nodiff, Sr. V.P. and General Counsel, Cantel
Medical Corp., dated April 9, 2007 (``Cantel Letter''); James C.
Smith, Chairman and CEO, Webster Financial Corporation, dated April
16, 2007 (``Webster Letter''); Michael Tenenbaum, PE, Trustee,
Strategic Technologies Employees Pension Fund Trust, dated May 2,
2007 (``Strategic Technologies Letter''); Craig D. Mallick,
Corporate Secretary, United States Steel Corporation, dated May 4,
2007 (``U.S. Steel Letter''); Bart J. Ward, Chief Executive Officer,
Ward & Company, dated May 8, 2007 (``Ward Letter''); Jack Sennott,
Senior Vice President and Chief Financial Officer, Darwin
Professional Underwriters, Inc., dated May 8, 2007 (``Darwin
Letter''); James J. Angel, Ph.D., CFA, Associate Professor of
Finance, McDonough School of Business, Georgetown University, dated
May 9, 2007 (``Angel Letter I''); M. Farooq Kathwari, Chairman,
President and CEO, Ethan Allen Interiors, Inc., dated May 9, 2007
(``Ethan Allen Letter''); Carol Kaufman, Sr. VP Legal Affairs, The
Cooper Companies, Inc., dated May 14, 2007 (``Cooper Letter''); Jack
R. Hartung, Chief Finance and Development Officer, Chipotle Mexican
Grill, Inc., dated May 15, 2007 (``Chipotle Letter''); Larry A.
Mizel, Chairman of the Board and Chief Executive Officer, M.D.C.
Holdings, Inc., dated May 17, 2007 (``MDC Letter''); Will Matthews,
dated May 21, 2007 (``Matthews Letter''); Stephen M. Klein, J.D.,
Chairman and Chief Executive Officer, Omni National Bank, dated May
21, 2007 (``Omni Letter''); Edward J. Resch, Executive Vice
President, Chief Financial Officer and Treasurer, State Street
Corporation, dated May 21, 2007 (``State Street Letter''); Faith
Pomeroy-Ward, Manager, Investor Relations, Adams Respiratory
Therapeutics, dated May 22, 2007 (``Adams Letter''); Shayn Carlson,
Director of Investor Relations, G&K Services, dated May 22, 2007
(``G&K Letter''); Alan R. Spachman, dated May 22, 2007 (``Spachman
Letter''); Mark L. Heimbouch, Chief Financial Officer and EVP,
Jackson Hewitt Tax Service Inc., dated July 10, 2007 (``Jackson
Hewitt Letter''); Daniel R. Coker, President & CEO, Amerigon
Incorporated, dated July 31, 2007 (``Amerigon Letter''); Betsy
Atkins, dated August 2, 2007 (``Atkins Letter''); Eric A. Blanchard,
Senior Vice President, General Counsel and Secretary, United
Stationers Supply Company, dated August 3, 2007 (``United Stationers
Letter''); Albert A. Pimentel, Executive Vice President and Chief
Financial Officer, Glu Mobile Inc., dated August 3, 2007 (``Glu
Letter''); Ryan Ellis, Executive Director, American Shareholders
Association, dated August 3, 2007 (``ASA Letter''); Rick Stewart,
CEO, Amarin Corporation plc, dated August 9, 2007 (``Amarin
Letter''); Steve Bene, Senior Vice President and General Counsel,
Electronic Arts Inc., dated August 9, 2007 (``Electronic Arts
Letter''); Bing Yeh, President & CEO, Silicon Storage Technology,
Inc., dated August 10, 2007 (``Silicon Storage Letter''); Kathy
Lanterman, Senior Vice President and Chief Financial Officer,
Silicon Graphics, Inc., dated August 9, 2007 (``SGI Letter''); Paul
Jennings, President and CEO, Innospec Inc., dated August 10, 2007
(``Innospec Letter''); Harry W. Kellogg, Jr., Vice Chairman, SVB
Financial Group, dated August 10, 2007 (``SVB Letter''); Arlen W.
Gelbard, Chief Administrative Officer and General Counsel, E*Trade,
dated August 10, 2007 (``E*Trade Letter''); MDS Office, Sobha
Developers Ltd, dated August 10, 2007 (``Sobha Letter''); John
Ritchie, Chief Financial Officer, Electronics For Imaging, dated
August 10, 2007 (``EFI Letter''); Adi Bar-Lev, Director of IR, Top
Image Systems Ltd., dated August 13, 2007 (``Top Image Letter'');
Lonnie R. Brock, CFO, Double Eagle Petroleum Co., dated August 13,
2007 (``Double Eagle Letter''); Joe Ovsenek, Senior Vice President,
Corporate, Silver Standard Resources Inc., dated August 15, 2007
(``Silver Standard Letter''); James J. Angel, Ph.D., CFA, Associate
Professor of Finance, McDonough School of Business, Georgetown
University, dated August 16, 2007 (``Angel Letter II''); Manisha
Kimmel, Executive Director, Financial Information Forum, dated
August 23, 2007 (``FIF Letter I''); Patrick J. Healy, Issuer
Advisory Group, dated September 6, 2007 (``Issuer Advisory
Letter''); S. Lee Clifford, President and CEO, SFB Market Systems,
dated September 25, 2007 (``SFB Letter''); Joan C. Conley, Senior
Vice President and Corporate Secretary, The NASDAQ Stock Market LLC,
dated November 2, 2007 (``Nasdaq Letter I''); Barbara Sweeney,
Senior Vice President and Corporate Secretary, The Financial
Industry Regulatory Authority, Inc., dated November 27, 2007
(``FINRA Letter''); Mary Yeager, Assistant Secretary, New York Stock
Exchange, LLC, dated January 15, 2008 (``NYSE Letter''); James J.
Angel, Ph.D., CFA, Associate Professor of Finance, McDonough School
of Business, Georgetown University, dated February 13, 2008 (``Angel
Letter III''); Manisha Kimmel, Executive Director, Financial
Information Forum, dated February 14, 2008 (``FIF Letter II'');
Marianne Brown, Chief Executive Officer, Omgeo, LLC, dated February
15, 2008 (``Omgeo Letter''); Joan Conley, Senior Vice President &
Corporate Secretary, The NASDAQ Stock Market LLC, dated February 26,
2008 (``Nasdaq Letter II''); John Panchery, Managing Director, Art
Trager, Vice President, and Ann Vlcek, Managing Director and
Associate General Counsel, Securities Industry and Financial Markets
Association, dated February 28, 2008 (``SIFMA Letter''); Julian
Rainero, Partner, Bracewell & Guiliani LLP, dated March 10, 2008
(``Bracewell & Guiliani Letter''); Jamie Shay, Head of SWIFT
Standards, Society for Worldwide Interbank Financial
Telecommunication, dated March 18, 2008 (``SWIFT Letter''); Scott
Atwell, FPL Global Steering Committee Co-Chair, FIX Protocol, dated
March 24, 2008 (``FIX Letter''); and Thomas P. Moran, Associate Vice
President & Associate General Counsel, Nasdaq, dated March 26, 2008
(``Nasdaq Letter III'').
\8\ See FPL Letter, TCF Letter, Wolverine Letter, Getty Letter,
Kinetic Concepts Letter, AmeriCredit Letter, Entertainment
Properties Letter, Big Lots Letter, Allstate Letter, Cantel Letter,
Webster Letter, Strategic Technologies Letter, U.S. Steel Letter,
Ward Letter, Darwin Letter, Ethan Allen Letter, Cooper Letter,
Chipotle Letter, MDC Letter, State Street Letter, Jackson Hewitt
Letter, and NYSE Letter.
\9\ See Matthews Letter, Omni Letter, Adams Letter, G&K Letter,
Amerigon Letter, Atkins Letter, United Stationers Letter, Glu
Letter, ASA Letter, Amarin Letter, Electronic Arts Letter, Silicon
Storage Letter, SGI Letter, Innospec Letter, SVB Letter, E*Trade
Letter, Sobha Letter, EFI Letter, Top Image Letter, Double Eagle
Letter, Silver Standard Letter, Nasdaq Letter I, and Nasdaq Letter
II.
\10\ See RPM Letter, Angel Letter I, Angel Letter II, Angel
Letter III, Spachman Letter, FIF Letter I, FIF Letter II, Issuer
Advisory Letter, SFB Letter, FINRA Letter, Omgeo Letter, SIFMA
Letter, Bracewell & Guiliani Letter, SWIFT Letter, and FIX Letter.
---------------------------------------------------------------------------
This order approves the Five-Characters Plan, with changes and
subject to conditions as the Commission deems necessary or appropriate,
thus authorizing CHX, FINRA, Nasdaq, NSX, and Phlx to act jointly to
implement the Five-Characters Plan, as modified herein, as a means of
facilitating a national market system in accordance with the
requirements of Section 11A of the Act.\11\ This order also requires,
within 60 days of this approval order, that any SRO that chooses to
list securities or to designate securities for quoting on a quotation
medium to join the Five-Characters Plan, as modified herein, and to act
jointly with CHX, FINRA, Nasdaq, NSX, and Phlx to implement the
approved plan.\12\ The approved Five-Characters Plan is attached here
as Appendix A.
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\11\ 15 U.S.C. 78k-1. See also 17 CFR 242.608(b)(2).
\12\ 15 U.S.C. 78k-1(a)(3)(B).
---------------------------------------------------------------------------
II. Background
A. Section 11A of the Act
In 1975, Congress directed the Commission, through the enactment of
Section 11A of the Act,\13\ to facilitate the establishment of a
national market system to link together the individual markets that
trade securities. Congress found the development of a national market
system to be in the public interest and appropriate for the protection
of investors and the maintenance of fair and orderly markets to assure
fair competition among the exchange markets.\14\ Section 11A(a)(3)(B)
of the Act directs the Commission, ``by rule or order, to authorize or
require self-regulatory organizations to act jointly with respect to
matters as to which they share authority under this title in planning,
developing, operating, or regulating a national market system (or a
subsystem thereof) or one or more facilities.'' \15\ The Commission's
approval of a national market system plan is conditioned upon a finding
that the proposed plan is ``necessary or appropriate in the public
interest, for the protection of investors and the maintenance of fair
and orderly markets, to remove impediments to, and perfect the
mechanism of, a national market system, or otherwise in furtherance of
the purposes of the Act.'' \16\
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\13\ 15 U.S.C. 78k-1.
\14\ 15 U.S.C. 78k-1(a)(1)(C).
\15\ 15 U.S.C. 78k-1(a)(3)(B).
\16\ 17 CFR 242.608(b)(2). See also 15 U.S.C. 78k-1(a).
---------------------------------------------------------------------------
B. Limited Symbol Supply
Pursuant to Rule 601 of Regulation NMS under the Act,\17\ all SROs
are required to report every trade in listed equity securities \18\ and
Nasdaq securities \19\ made through their facilities, and to make such
information public. Each SRO reports every transaction to the ticker
tape using the ticker symbol for that security, the volume of the
trade, and the price of the trade. Currently, there are three ticker
tapes: Tape A reports the stocks that are listed on NYSE, Tape B
reports the
[[Page 67220]]
stocks that are listed on Amex, as well as securities listed on any
other national securities exchange (except securities also listed on
NYSE and Nasdaq), and Tape C reports the stocks that are listed on
Nasdaq. Tapes A and B disseminate market information pursuant to the
Consolidated Tape Association Plan (``CTA Plan''), while Tape C
disseminates market information pursuant to the Nasdaq Unlisted Trading
Privileges Plan.
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\17\ 17 CFR 242.601.
\18\ 17 CFR 242.600(b)(34) defines ``listed equity security'' as
``any equity security listed and registered, or admitted to unlisted
trading privileges, on a national securities exchange.''
\19\ 17 CFR 242.600(b)(41) defines ``Nasdaq security'' as ``any
registered security listed on The Nasdaq Stock Market, Inc.''
---------------------------------------------------------------------------
Securities symbols are a key element in the operation of a national
market system and essential to the dissemination of trade information
in a common format. The term ``ticker symbol'' originates from the
ticker tape.\20\ Prior to the introduction of the ticker, it was
customary for messengers to manually disseminate quotations.\21\ In
1867, an employee of the NYSE developed the stock ticker.\22\ A system
of symbols and abbreviations developed as the only practical method for
reporting transactions, because the full description of the issuer,
security, number of shares sold, the price, and other market data would
slow the dissemination of trade information so that the ticker would
fall behind the market.\23\ In December 1966, the ticker tape was fully
automated.\24\
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\20\ The ticker tape started in 1867, when all trades made on an
exchange were sent out by telegraph and printed on a piece of paper.
Although the process is now automated, the securities industry
participants continue to refer to the electronic reporting of
information as the ``tape.'' See Hal McIntyre, How the US Securities
Industry Works, 194-95 (The Summit Group Press) (2000).
\21\ See S. S. Huebner, Ph.D., Sc.D., The Stock Market, 218
(Appleton-Century-Crofts, Inc.) (1934).
\22\ E.A. Calahan. See George L. Leffler, Ph.D., The Stock
Market, 162 (The Ronald Press Company) (1951).
\23\ See note 21 supra at 222. The first ticker was very slow
and not practical, until Thomas A. Edison, another employee of the
NYSE, improved its speed and efficiency. See note 22 supra at 162.
\24\ See Richard J. Teweles and Edward S. Bradley, The Stock
Market, 148 (John Wiley & Sons, Inc.) (1998).
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Recently, concerns about the scarcity of available symbols have
highlighted the need for a symbol reservation national market system
plan to efficiently and fairly manage symbol supply. As the securities
markets have grown over the years, the availability of one-, two-, and
three-character symbols has diminished.\25\ Several factors have been
increasing the demand for one-, two-, and three-character symbols. In
recent years, exchanges have begun listing new and innovative products,
such as exchange-traded funds, that are now competing with listed
companies for symbols.
---------------------------------------------------------------------------
\25\ There are 26 combinations for one-character symbols, 676
combinations for two-character symbols, and 17,576 combinations for
three-character symbols, for a total of 18,278 one-, two-, and
three-character symbols.
---------------------------------------------------------------------------
In addition, Nasdaq, which when operated as a facility of NASD (n/
k/a FINRA) \26\ only listed securities with four- and five-character
symbols, has begun using two- and three-character symbols and has
expressed its desire to use one-character symbols as well for Nasdaq-
listed issuers. It has been the practice of the NYSE to list companies
using one-, two-, and three-character symbols and of other exchanges
(including Amex and regional exchanges) to list companies using two-
and three-character symbols. Until recently, Nasdaq was the only
listing market that did not assign securities one-, two-, or three-
character symbols; instead, Nasdaq had assigned securities it listed
four- and five-character symbols. In November 2005, however, Nasdaq
announced its intention to begin listing companies with one-, two-, and
three-character symbols.\27\ Since that time, Nasdaq has made a series
of announcements detailing its plans, and has worked with the industry
to test trading systems to ensure the proper functionality for such
symbols.\28\ In March 2007, Nasdaq filed with the Commission a proposed
rule change to allow companies transferring their listings to Nasdaq to
retain their three-character symbols.\29\ And, in April 2008, Nasdaq
filed with the Commission an immediately effective proposed rule change
to allow an issuer with a two-character symbol to transfer its listing
to Nasdaq and retain its two-character symbol.\30\
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\26\ Nasdaq began operations as a national securities exchange
in Nasdaq-listed securities on August 1, 2006, and in non-Nasdaq-
listed securities on February 12, 2007. See https://www.nasdaq.com/
about/FAQsExchange.stm. See also Securities Exchange Act Release No.
53128 (January 13, 2006), 71 FR 3550 (January 23, 2006) (File No.
10-131).
\27\ See Head Trader Alert 2005-133 (November 14, 2005),
available at https://www.nasdaqtrader.com.
\28\ See e.g., Nasdaq Head Trader Alerts 2006-144 (September 29,
2006), 2006-193 (November 16, 2006), 2006-201 (December 6, 2006),
and 2007-008 (January 25, 2007), each available at https://
www.nasdaqtrader.com.
\29\ See Securities Exchange Act Release No. 55563 (March 30,
2007), 72 FR 16391 (April 4, 2007) (SR-NASDAQ-2007-031) (notice for
the proposal to allow three-character symbol portability for
companies transferring their listings to Nasdaq). The Commission
approved this proposal in July 2007. See Securities Exchange Act
Release No. 56028 (July 9, 2007), 72 FR 38639 (July 13, 2007)
(``Nasdaq Three-Character Portability Order''). See also Securities
Exchange Act Release No. 55519 (March 26, 2007), 72 FR 15737 (April
2, 2007) (SR-NASDAQ-2007-025) (allowing a single company, Delta
Financial Corp., to retain its three-character symbol upon
transferring its listing from Amex to Nasdaq).
\30\ See Securities Exchange Act Release No. 57696 (April 22,
2008), 73 FR 22987 (April 28, 2008) (SR-NASDAQ-2008-034). The
Commission notes that its approval of the Five-Characters Plan, as
modified herein, is consistent with this change and with its
approval of the Nasdaq Three-Character Portability Order. See id. As
discussed further below, see infra notes 105-117 and accompanying
text, the approved plan would allow the automatic portability of all
one-, two-, three-, four-, and five-character symbols of issuers
transferring their listing from one exchange to another.
---------------------------------------------------------------------------
Finally, the proliferation of standardized options has decreased
the availability of three-character symbols.\31\ Developing a formal
process to reserve, select, and allocate symbols fairly and efficiently
among the listing markets should help promote a fair and orderly
national market system and protect investors.
---------------------------------------------------------------------------
\31\ The options exchanges have expressed their intention to
shift to a different symbology. See https://www.theocc.com/
initiatives/symbology/default.jsp.
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C. Weaknesses in the Existing Reservation System
Currently, the listing markets assign securities symbols under an
informal understanding among the markets. Under this system, each SRO
keeps its own records of reserved symbols. If an SRO wishes to reserve
a particular symbol, the SRO will consult its own list of reserved
symbols and then, if it believes that the symbol is available, will
notify the other SROs that it is reserving that symbol. If no other SRO
objects, then the listing SRO has successfully reserved that symbol and
each SRO would be responsible for updating its own records of reserved
symbols accordingly.
There are several weaknesses in the current informal system. The
absence of universal reservation records may lead to confusion about
the availability of certain symbols and may result in disputes between
listing markets about the availability of particular symbols. Any such
confusion or disagreement between the listing markets could disrupt the
listing process or raise the potential for symbol duplication and
investor confusion.
In addition, under the existing system, listing markets may reserve
an excess amount of symbols indefinitely, which could exacerbate the
strain on symbol supply. Market fears about supply constraints and
competition for listings could drive listing markets to reserve an
excess amount of symbols, either to protect their interests in the
event of needing such symbols in the future or to give themselves
advantages over their competitors in securing future listings. For
example, a listing market could use the existing symbol reservation
system to withhold unused symbols from their competitors, trade
reserved symbols only with certain, allied exchanges, or use their
power to
[[Page 67221]]
withhold desired symbols to compel other listing markets not to trade
symbols with their direct competitors.
Finally, the existing system does not universally permit issuers
transferring their listing to a new exchange to keep their ticker
symbols. Thus, the original listing market and the new listing market
for a transferred listing could become embroiled in a dispute over the
right to use the issuer's ticker symbol, which could disrupt trading in
that security, and such uncertainty could affect an issuer's decision
in selecting a listing venue or moving from one venue to another.
Disagreements over the use of securities symbols have arisen in the
past. For example, in 1999, NYSE, Amex, and Nasdaq were involved in a
dispute regarding the symbol ``Q,'' which Amex and Nasdaq planned to
use for the Nasdaq 100 Trust. However, NYSE claimed that it had
reserved that symbol and sued to enjoin the use of that symbol. Amex
and Nasdaq eventually agreed to use a different symbol for the Nasdaq
100 Trust.\32\
---------------------------------------------------------------------------
\32\ See, e.g., Big Board Drops its Lawsuit Against Amex, The
New York Times, March 10, 1999, Section C, p. 10.
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These weaknesses in the existing informal symbol reservation system
could potentially have significant market consequences as exchanges
compete more aggressively for listings and the supply of available
symbols becomes more restricted over time. For this reason, the
Commission believes that it is necessary to adopt a national market
system plan for reserving and allocating symbols among the SROs to
maintain fair and orderly markets. Consistent with the principles of
Section 11A of the Act, in February 2005, Commission staff requested
the listing markets to commence joint discussions to develop such a
national market system plan.\33\ A national market system plan for
symbology should mitigate confusion or disagreement about the rights to
particular securities symbols and should allow symbols to be used in a
manner that is efficient and promotes competition between the listing
markets.
---------------------------------------------------------------------------
\33\ See Letters from Annette L. Nazareth, then Director of the
Division of Market Regulation, Commission, to Amex, Boston Stock
Exchange (``BSE''), CBOE, CHX, ISE, Nasdaq, NASD, NSX, NYSE, Pacific
Exchange (the predecessor to NYSE Arca) and Phlx, dated February 7,
2005 (``February 2005 Letters'').
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III. Discussion
In the notice publishing for comment both the Three-Characters Plan
and the Five-Characters Plan, the Commission asked for comments on
whether it should approve one or two plans. Four commenters provided
feedback on this issue and each supported the approval of a single
symbology plan.\34\ One of these commenters stated that having two
different plans for short and long tickers adds needless complexity to
an already complex market structure and that the additional complexity
of two plans would create increased costs for SROs as well as
additional costs to the Commission to regulate two plans, which would
be borne ultimately by taxpayers and investors.\35\ The Commission
agrees with these commenters that approving two plans for the
reservation of symbols would place undue costs and burdens on listing
SROs, including new entrants. The Commission also notes that,
currently, the proposed plans both establish a process for the
selection and reservation of one-, two-, and three-character securities
symbols. Therefore, approval of both plans would establish two
competing, inconsistent systems for selecting and reserving one-, two-,
and three-character symbols, which the Commission believes would not be
in furtherance of the purposes of the Act. The Commission finds that
approving a single plan, rather than both plans, is necessary or
appropriate in the public interest, for the protection of investors and
the maintenance of fair and orderly markets, to remove impediments to,
and perfect the mechanisms of a national market system and is in
furtherance of the purposes of the Act because a single plan would
promote the smooth and orderly operation of the marketplace.
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\34\ See FIF Letter I, FIF Letter II at 1, Angel Letter II at 3,
Angel Letter III at 1, Omgeo Letter at 1, and SWIFT Letter.
\35\ See Angel Letter II at 3 and Angel Letter III at 2.
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After carefully considering the proposed plans and the issues
raised by the comment letters, the Commission has determined to
approve, pursuant to Section 11A(a)(3)(B) of the Act \36\ and Rule
608,\37\ the Five-Characters Plan, with changes and subject to
conditions set forth herein as the Commission has deemed necessary or
appropriate.\38\ As discussed in detail below, in approving the Five-
Characters Plan, the Commission finds that the Five-Characters Plan is
necessary and appropriate in the public interest and in furtherance of
the purposes of the Act. The Five-Characters Plan is more comprehensive
than the Three-Characters Plan because it covers one-, two-, three-,
four-, and five-character symbols. The Commission also believes it
would better promote fair competition among exchanges that list
securities because it does not constrain the portability of symbols (as
the Three-Characters Plan does), but instead makes all symbols
automatically portable when a listed issuer transfers its listing to
another exchange. This portability would enable issuers to make listing
decisions based on factors that relate to the quality of the listing
markets such as trading quality, costs, and branding, rather than on
considerations of symbol portability. In summary, the Five-Characters
Plan provides a system for reserving and allocating securities symbols
that should provide clarity and order to the symbol reservation
process, mitigate the current constraints on symbol supply, and promote
fair competition between the various SROs.
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\36\ 15 U.S.C. 78k-1(a)(3)(B).
\37\ 17 CFR 242.608.
\38\ The Commission has modified the proposed Five-Characters
Plan to make the following changes: (i) To modify the plan to state
that, 90 days following the Commission's approval, it will be the
exclusive means of allocating and using symbols of one-, two-,
three-, four-, and five-characters in length and to specify that
there is no difference between capital and lowercase letters (see
infra note 41 and accompanying text); (ii) to modify the start date
for the initial reservation process from upon Commission approval of
the plan to 60 days following the Comission's approval (see infra
notes 141-143 and 190-191 and accompanying text); (iii) to limit the
use of one-, two-, and three-character symbols for securities listed
on a national securities exchange and to restrict securities trading
over-the-counter to using only four- or five-character symbols (see
infra notes 85-89 and accompanying text); and (iv) to clarify that
securities that de-list and trade on the over-the-counter market
would not have portability rights for the original listing symbol
(see infra notes 168-172 and accompanying text).
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This order authorizes CHX, FINRA, Nasdaq, NSX, and Phlx to act
jointly to implement the Five-Characters Plan, as modified herein, as a
means of facilitating a national market system in accordance with the
requirements of Section 11A of the Act.\39\ This order also requires
any SRO that chooses to list securities on its market or to designate
securities for quoting on a quotation medium to join the Five-
Characters Plan and to act jointly with other parties to the plan to
implement the approved plan.\40\
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\39\ 15 U.S.C. 78k-1.
\40\ 15 U.S.C. 78k-1(a)(3)(B). The Commission did not receive
any comments regarding whether it should require SROs to join an
approved plan.
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In connection with requiring SROs that list, or designate for
quoting, securities, the Commission is also modifying the plan to
provide that, 90 days from the date of this Order, the Five-Characters
Plan shall be the exclusive means of allocating and using symbols of
one-, two-, three-, four-, or five-characters in length. In addition,
for clarity, the Commission is specifying that there will be no
difference between capital letters and lowercase letters,
[[Page 67222]]
thus limiting the choices of letters to 26. The Commission believes
these changes are necessary and appropriate for the dissemination of
trade information in a common format.\41\
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\41\ The Commission notes that, while the proposed plans were
silent on these points, this clarification is necessary to avoid the
possibility of confusion regarding the scope of the approved plan.
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A. Five-Characters Plan's Consistency With Section 11A of the Act
Many of the provisions of the proposed Five-Characters Plan are
similar or identical to parallel provisions in the proposed Three-
Characters Plan. Particularly, the plans would establish the
Intermarket Symbol Reservation Authority (``ISRA'') composed of plan
participants and set forth how it would be administered. Both plans
also have the same provisions regarding the use of a third-party
processor and a symbol reservation database, the general process of
reserving perpetual and limited-time reservations, the use of a waiting
list, the right to reuse a symbol, the ability to request the release
of a symbol, the terms of confidentiality, the non-transferability of
rights under the plan, and the process of amending the plan.\42\
Despite these significant areas of consensus, however, there are
several important differences between the proposed plans.
---------------------------------------------------------------------------
\42\ See discussion infra Part III(B) for a discussion of these
provisions.
---------------------------------------------------------------------------
Many of the commenters that favored the proposed Five-Characters
Plan asserted that it would enhance competition among markets by
putting all exchanges on a fair and level playing field and would
reduce the potential for investor confusion by allowing a fair
framework for symbol portability.\43\ Several commenters stated that
the proposed Five-Characters Plan would give all exchanges equal rights
under the proposal.\44\ Some of these commenters also stated that the
proposed Five-Characters Plan would provide greater choice for public
companies and cause less confusion for investors.\45\ One commenter
asserted that the proposed Five-Characters Plan is inherently more fair
and reasonable than the proposed Three-Characters Plan.\46\
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\43\ See Amerigon Letter, United Stationers Letter, Glu Letter,
Electronic Arts Letter, Silicon Storage Letter, Silicon Graphics
Letter, Innospec Letter, SVB Letter, E*Trade Letter, EFI Letter, Top
Image Letter, Double Eagle Letter, and Silver Standard Letter.
\44\ See Adams Letter, Atkins Letter, and Sobha Letter. See also
ASA Letter, which stated that fair and equal competition is the core
of the Five-Characters Plan.
\45\ See Amerigon Letter, United Stationers Letter, Glu Letter,
Amarin Letter, Electronic Arts Letter, Silicon Graphics Letter, SVB
Letter, E*Trade Letter, Top Image Letter, Double Eagle Letter, and
Silver Standard Letter.
\46\ See Matthews Letter.
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The Commission agrees with the commenters supporting the Five-
Characters Plan and finds that, as discussed in greater detail below,
the Five-Characters Plan, as modified herein, is consistent with
Section 11A of the Act, and is necessary and appropriate in the public
interest, for the protection of investors and the maintenance of fair
and orderly markets.
1. Scope of Plan
One primary difference between the two proposed plans relates to
scope: the proposed Three-Characters Plan would only cover one-, two-,
and three-character symbols; the Five-Characters Plan, on the other
hand, would cover the reservation and allocation of all one-, two-,
three-, four-, and five-character symbols. Both of the proposed plans
would cover only root symbols, without any suffix or special
conditional identifier.\47\
---------------------------------------------------------------------------
\47\ See Section IV(a) of the proposed plans.
---------------------------------------------------------------------------
The Commission believes that the Five-Characters Plan, which would
establish a uniform system for the selection and reservation of symbols
(``Symbol Reservation System'') of one-, two-, three-, four-, or five-
character securities symbols,\48\ is more comprehensive, and therefore
offers a more efficient and effective mechanism for allocating symbols
than the Three-Characters Plan.\49\ The Three-Characters Plan would
leave unanswered the appropriate methodology for allocating four- and
five-character symbols.
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\48\ See Section I(b) of the Five-Characters Plan. The Five-
Characters Plan would cover only root symbols (i.e., without any
suffix or special conditional identifier) that are NMS securities as
currently defined in Rule 600(a)(46) of Regulation NMS under Act and
any other equity securities quoted, traded, and/or trade reported
through an SRO facility. See Preamble and Sections I(b) and IV(a) of
the Five-Characters Plan. The Three-Characters Plan would cover only
root symbols of one-, two- or three-characters for Network A and
Network B Eligible Securities (as defined in the CTA Plan) and
listed options reported to OPRA. The Three-Characters Plan states
that, for listed equity securities, no such symbols would be
allocated or used other than for Network A or Network B Eligible
Securities. See Sections I(b) and IV(a) of the Three-Characters
Plan.
\49\ As discussed below, one commenter suggested expanding the
length of securities symbols to 10 or 12 characters. See Angel
Letter III at 3. Currently, the markets only use root symbols of
one- through five-characters in length.
---------------------------------------------------------------------------
Although Nasdaq is currently the primary listing exchange for
issuers using four- and five-character symbols,\50\ the Commission
believes that it will further the purposes of the Act to approve a plan
for the reservation and allocation of symbols with one-, two-, three-,
four-, and five-character symbols in order to permit all exchanges to
begin utilizing such symbols, particularly in light of the limited
availability of one-, two-, and three-character symbols. Indeed, the
Commission believes that allowing all exchanges to list four- and five-
character securities symbols should help ensure that the supply of
available securities symbols does not become constrained.
---------------------------------------------------------------------------
\50\ The Commission notes that NYSE Arca currently lists an
issuer with a four-character security symbol, namely Golden Cycle
Gold Corporation (ticker symbol: GCGC).
---------------------------------------------------------------------------
Some commenters urged a broader scope than that proposed in either
plan. Seven commenters advocated the adoption of a national market
system plan that provides a single suffix symbology across all
SROs.\51\ In response, Nasdaq had initially commented that the plan
should only cover root symbols because the use of symbol suffixes is
unique to individual markets.\52\ Subsequently, however, Nasdaq urged
that the Commission commence a process for adopting a uniform inter-
market equity symbol suffix plan.\53\ The Commission is supportive of
considering such an initiative. To avoid a delay in the implementation
of a symbology national market system plan for root symbols, however,
the Commission believes it is appropriate to consider any such
initiative separately following the approval of the Five-Characters
Plan. Accordingly, the Commission finds the scope of the Five-
Characters Plan in its focus on root symbols is appropriate in the
public interest and that it will further the purposes of the Act.
---------------------------------------------------------------------------
\51\ See FIF Letter I, FIF Letter II at 1, Angel Letter II at 3,
Angel Letter III at 1, Omgeo Letter at 1, SIFMA Letter, Bracewell &
Guiliani Letter, SWIFT Letter, and FIX Letter. One commenter also
noted that current inconsistencies in suffix symbology and condition
identifiers make it difficult for data vendors to pass through
accurate data, which can cause confusion and loss for investors. See
Angel Letter I at 8 and Angel Letter III at 1. This commenter also
believed that the plan should cover, in addition to equity
securities, options, futures, securities futures, mutual funds, and
indices and that it should incorporate representation from the
derivatives exchanges, issuers, investors, and brokers. See Angel
Letter I at 10, Angel Letter II at 4, and Angel Letter III at 1. In
addition, this commenter urged the development of a new symbology
plan in what he anticipates will be a global trading environment.
See Angel Letter III at 2.
\52\ See Nasdaq Letter II at 3.
\53\ See Nasdaq Letter III. See also Head Trader Alert 2008-36
(March 27, 2008), available at https://www.nasdaqtrader.com.
---------------------------------------------------------------------------
2. Parties to the Plan
The proposed plans have different criteria for determining the
eligibility for parties to join their plan. The
[[Page 67223]]
proposed Three-Characters Plan would only allow an SRO to join the plan
if it maintains a market for the listing and trading of securities that
are identified by one-, two-, or three-character symbols and if their
listed equity securities are also ``Network A'' or ``Network B''
``Eligible Securities'' as those terms are defined in the CTA Plan.\54\
---------------------------------------------------------------------------
\54\ The CTA Plan defines ``Network A Eligible Securities'' to
mean Eligible Securities listed on NYSE and ``Network B Eligible
Securities'' to mean, in relevant part, Eligible Securities listed
on the Amex, BSE, CBOE, CHX, ISE, NSX, NYSE Arca, Phlx or on any
other exchange other than Nasdaq, but not also listed on NYSE.
---------------------------------------------------------------------------
The Five-Characters Plan, on the other hand, would allow any SRO to
join the plan as long as it maintains a market for the listing and
trading of securities that are identified by one-, two-, three-, four-,
or five-character symbols.\55\ A party would also be required to have
the actual technical and physical capability through its facilities to
immediately quote and report trades in securities either using one-,
two-, or three-character symbols, if it seeks to reserve symbols of
one-, two-, or three-characters in length, or using four-or five-
character symbols, if it seeks to reserve symbols of four-or five-
characters in length.\56\ In addition, this plan would require, as
conditions to becoming a new participant, that an SRO pay a
proportionate share of the aggregate development costs and sign a
current copy of the plan.\57\
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\55\ See also supra note 48.
\56\ See Section I(b) of the Five-Characters Plan.
\57\ See Section I(c) of the Five-Characters Plan. For
additional discussion regarding the plan's provision relating to
costs, see discussion infra notes 118-124 and accompanying text.
---------------------------------------------------------------------------
Many commenters argued that Nasdaq should not be allowed to list
one-, two-, and three-character symbols because such symbols are
indicative of an NYSE listing.\58\ Some of these commenters argued that
an issuer's use of a one-, two-, or three-character symbol signaled the
NYSE brand and ``companies listed on NYSE meet the highest corporate
governance and financial standards in the world;'' \59\ consequently,
some stated, the Nasdaq issuers' use of such symbols could lead to
investor confusion.\60\ One such commenter, a trustee and portfolio
manager of a small pension fund, stated that it relies on the use of
one-, two-, and three-character symbols to identify NYSE securities and
makes investment decisions based on such reliance, citing the financial
reporting requirements and stability of earnings of NYSE securities;
this commenter further stated that it generally performs ``an extra
level of scrutiny in view of the longevity of firms that have been
listed in the over the counter market'' because it presumes that those
securities are not NYSE-listed securities.\61\ NYSE also argued that
Nasdaq's attempt to use three-character symbols exacerbates the
existing supply problems without justification.\62\
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\58\ See FPL Letter, TCF Letter, Wolverine Letter, Getty Letter,
KCI Letter, AmeriCredit Letter, Entertainment Properties Letter, Big
Lots Letter, Allstate Letter, Cantel Letter, Webster Letter,
Strategic Technologies Letter, U.S. Steel Letter, Ward Letter,
Darwin Letter, Ethan Allen Letter, Cooper Letter, Chipotle Letter,
State Street Letter, and Jackson Hewitt Letter. See also NYSE Letter
at 2.
\59\ See Allstate Letter; see also, e.g., FPL Letter, TCF
Letter, Wolverine Letter, Getty Letter, KCI Letter, AmeriCredit
Letter, Entertainment Properties Letter, Big Lots Letter, Cantel
Letter, Webster Letter, Strategic Technologies Letter, U.S. Steel
Letter, Darwin Letter, Ethan Allen Letter, Cooper Letter, Chipotle
Letter, State Street Letter, and Jackson Hewitt Letter. See also
NYSE Letter at 4.
\60\ See TCF Letter, Wolverine Letter, Big Lots Letter, Ward
Letter. See also NYSE Letter at 3.
\61\ See Strategic Technologies Letter. The NYSE Letter also
argued that investors, securities issuers, and the public rely on
the different symbol lengths to distinguish NYSE and Nasdaq
securities. See NYSE Letter at 2.
\62\ See NYSE Letter at 5.
---------------------------------------------------------------------------
Many other commenters, however, challenged these assertions and
argued that Nasdaq should have the same rights to list one-, two-, or
three-character symbols as NYSE and any other exchange.\63\ One
commenter noted that one-, two-, and three-character ticker symbols
have previously been used by Amex and other regional exchanges and that
commenters implying that one-, two-, and three-character symbols are
associated only with NYSE ignore current practice and the historical
record.\64\ Another commenter stated that, due to the fact that markets
can no longer claim a majority share of the trading in their listed
securities, the correlation of the number of letters in a ticker symbol
and its listing on a particular exchange is an increasingly obsolete
consideration.\65\ One commenter also noted that NYSE and Amex issuers,
similarly, should have the flexibility to use longer ticker symbols
that may be more readily identifiable with their company.\66\
---------------------------------------------------------------------------
\63\ See G&K Letter, Amerigon Letter, United Stationers Letter,
Glu Letter, Electronic Arts Letter, Silicon Graphics Letter, E*Trade
Letter, Silicon Storage Letter, Innospec Letter, EFI Letter, and
Nasdaq Letter I. See also SVB Letter, Top Image Letter, and Double
Eagle Letter, which state that all exchanges and issuers should be
able to list three- or fewer character symbols.
\64\ This commenter stated that Amex, BSE, and other regional
exchanges have used one- or two-character ticker symbols in the
past. See Angel Letter I at 6, Angel Letter II at 2, and Angel
Letter III at 2. This commenter also argued that shorter ticker
symbols should go to the most actively-traded stocks, some of which
are Nasdaq-listed, because the reduced typing and remembering effort
required for such symbols would make it a more economically
efficient solution. See Angel Letter I at 5.
\65\ See Issuer Advisory Letter at 2. See also Angel Letter I at
4.
\66\ See Angel Letter II at 3.
---------------------------------------------------------------------------
The Commission believes that any SRO with the capacity to maintain
a market for the listing of securities that are identified by one-,
two-, three-, four-, or five-character symbols should be able to
reserve those symbols.\67\ As noted above, the Five-Characters Plan
would permit any SRO that maintains a market for the listing and
trading of plan securities to become a party to the plan.\68\ The
Commission believes that SROs that have listing standards for plan
securities, though they may not be actively listing such securities,
and that maintain a market for the trading of plan securities would
satisfy this requirement and would be permitted, though not required,
to become parties to the plan. Joining the plan would enable such SROs
to reserve symbols in anticipation of beginning a listings
business.\69\ In addition, the Commission is requiring any SRO that
chooses to list securities on its market or to designate securities for
quoting on a quotation medium to join the approved plan.\70\
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\67\ The Commission notes that Nasdaq is no longer a facility of
a national securities association and is now a national securities
exchange. See supra note 26.
\68\ See Section I(c) of the Five-Characters Plan.
\69\ Parties to the plan are entitled to place up to 20 symbols
on each of its perpetual reservation lists for one-, two-, or three-
character symbols and four- or five-character symbols, respectively.
See infra notes 90 and 93-95 and accompanying text. The Commission
notes that, for limited-time reservations, the plan requires a party
to have a reasonable basis for using a limited-time reservation
within a 24-month period. See infra notes 91-92 and accompanying
text.
\70\ See infra notes 192 and 197-198 and accompanying text.
---------------------------------------------------------------------------
The Commission does not agree with commenters who believe that the
use of one-, two-or three-character symbols by Nasdaq issuers will
``blur and diminish the financial and other significant achievements
commonly associated with NYSE listed companies'' \71\ or confuse
investors who today purportedly identify such symbols as associated
with NYSE. Many issuers not listed on NYSE utilize such symbols and
have for a significant period of time and, therefore, any automatic
association of such symbols with NYSE's listing standards or brand is
mistaken.\72\ Therefore, the Commission finds that the provision on
eligible parties in the proposed Five-Characters Plan is preferable and
is necessary and appropriate in the public interest, for the protection
of investors and the
[[Page 67224]]
maintenance of fair and orderly markets, and that it assures fair
competition among exchange markets, consistent with Section
11A(a)(1)(C)(ii) of the Act.\73\
---------------------------------------------------------------------------
\71\ See Big Lots Letter.
\72\ See supra note 64 and accompanying text.
\73\ See 15 U.S.C. 78k-1(a)(1)(C)(ii).
One commenter also argued that rights to ticker symbols should
be allocated directly to issuers, rather than to the SROs. See
Issuer Advisory Letter at 3. See also Angel Letter I at 3 and Angel
Letter III at 4, arguing that issuers have stronger claims to
symbols than their exchanges. The Commission believes, however, that
developing a symbol reservation plan directly among the issuers
would present significant challenges--including implementation and
administrative challenges, and believes that continuing to allow
listing markets to reserve and then allocate those symbols to
qualified issuers is more workable and efficient.
Because the Five-Characters Plan, as filed, listed the name of
all SROs, including those that were not signatories to the plan, the
Commission has deleted the names of SROs listed in Section I(a) of
the Five-Characters Plan who are not signatories to the plan at this
time.
---------------------------------------------------------------------------
The Commission also believes that the Five-Characters Plan will
further the purposes of the Act because it promotes competition among
listing markets, including potential new listing markets. As described
in further detail below, and unlike the Three-Characters Plan, the
Five-Characters Plan provides each party to the plan with an equal
allotment of perpetual and limited-time reservations.\74\ The Five-
Characters Plan also permits the portability of an issuer's symbol from
one SRO to another, allowing competing listing venues to attract
transferred listings without requiring issuers to change their ticker
symbol.\75\ In addition, the Five-Characters Plan would allocate to any
new party joining the plan a pro-rata portion of the initial
development costs based upon the number of symbols initially reserved
by such new party during its first twelve months as a party to the
plan.\76\
---------------------------------------------------------------------------
\74\ See discussion infra notes 77-104 and accompanying text.
\75\ See discussion infra notes 105-117 and accompanying text.
\76\ See discussion infra notes 118-124 and accompanying text.
---------------------------------------------------------------------------
3. Reservation and Use of Symbols
Both proposed plans have provisions allowing parties to the plan to
reserve symbols in perpetuity (``perpetual reservations'') and for a
limited time (``limited-time reservations''). Specifically, both
proposed plans provide that, within 30 days of Commission approval of
the plan (unless such time is extended by the Policy Committee),\77\
parties may submit to the Processor \78\ requests for initial
reservation of symbols.\79\ The proposed plans' differ as follows: (1)
How reservation rights are allocated among the individual parties; (2)
the number of symbols that may be reserved on the perpetual reservation
and limited-time reservation lists, respectively; and (3) how limited-
time reservations may be secured. These differences and the reasons the
Commission finds that the Five-Characters Plan's provisions on
reservation rights, as modified herein, are appropriate in the public
interest for the maintenance of fair and orderly markets and fair
competition between the markets, consistent with the Section
11A(a)(1)(C) of the Act,\80\ are discussed below.
---------------------------------------------------------------------------
\77\ ISRA will be administered by a Policy Committee, which will
consist of one voting member and one alternate voting member
representing each party. See Section II(a) and (c) of the Five-
Characters Plan. See also Section II(a) and (c) of the Three-
Characters Plan, which is identical to the corresponding provision
of the Five-Characters Plan.
\78\ The Processor will be an independent third party to which
ISRA will delegate the operation of the Symbol Reservation System.
See Section III of the Five-Characters Plan. See also Section III of
the Three-Characters Plan, which is identical to the Five-Characters
Plan.
\79\ The Commission is modifying the Five-Characters Plan's
provision on the timing for the initial reservation process. See
infra notes 77-104 and accompanying text for the discussion of this
modification.
\80\ 15 U.S.C. 78k-1(a)(1)(C).
---------------------------------------------------------------------------
a. Allocation of Reservation Rights Among Parties
The proposed Three-Characters Plan awards greater reservation
rights to NYSE and Amex than to the other parties to the plan.
Specifically, the proposed Three-Characters Plan would allow NYSE and
Amex each to reserve 200 symbols as perpetual reservations and 1,500
symbols as limited-time reservations, while other parties to the plan
could only reserve 40 symbols as perpetual reservations and up to 500
limited-time reservations.\81\ The Five-Characters Plan, on the other
hand, awards equal reservation rights among all the parties--any
eligible party to the plan could reserve 20 perpetual reservations and
1,500 limited-time reservations of one-, two-, and three-character
symbols and 20 perpetual reservations and 1,500 limited-time
reservations of four- and five-character symbols.\82\ The Five-
Characters Plan also requires a party intending to include a symbol on
its limited-time reservations lists to have a reasonable basis for
using such symbol within 24 months.
---------------------------------------------------------------------------
\81\ The proposed Three-Characters Plan, as amended, provided
that NYSE Arca and CBOE each may have 500 limited-time reservations
and that ISE may have 200 limited-time reservations. The plan would
leave the precise number of limited-time reservations for other SROs
to be decided when such SROs join the proposed plan.
\82\ See Section IV(b)(1)(A) and (B) of the Five-Characters
Plan. The Commission notes that the reservation lists do not apply
to securities symbols already in use, but rather relate to unused
ticker symbols.
---------------------------------------------------------------------------
With respect to these provisions on reservation rights, the
Commission finds that the Five-Characters Plan will further the
purposes of the Act. The Five-Characters Plan allocates all reservation
rights equally among all parties to the plan, consistent with fair
competition principles. NYSE argued that the proposed Three-Characters
Plan reservation provisions reflect the reality of its own likelihood
to list a greater number of securities than the other markets.\83\
Nasdaq, however, disputed this assertion and stated that the allocation
of reservations in this provision of the Three-Characters Plan is out
of proportion to historic symbol usage.\84\ Nasdaq also argued that
this provision would be discriminatory and that such discrimination is
not compelled by market needs and is inconsistent with the equal
regulation and pro-competition mandates of the Act. While the
Commission recognizes that currently NYSE and Amex markets encompass
the overwhelming majority of primary listings for issuers with one-,
two-, and three-character symbols, the Commission does not believe that
the dominance of any particular market should be enshrined in a
national market system plan. Moreover, the Commission believes that the
Five-Characters Plan's proposed allotments would permit active listing
markets to reserve more than enough securities symbols for their
listing business. The Five-Characters Plan, in contrast to the proposed
Three-Characters Plan, would promote fair competition among the markets
by providing all participants with the same number of reservations.
Such equal reservation rights make it easier for an existing SRO or new
entrant to compete on an equal basis with primary listing markets.
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\83\ See NYSE Letter at 6.
\84\ See Nasdaq Letter II at 2.
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One commenter stated that OTC Bulletin Board (``OTCBB'')\85\ and
Pink Sheet \86\ issuers should not have the same rights to use
securities symbols as issuers listed on national securities
exchanges.\87\ The commenter noted that,
[[Page 67225]]
in the past, if a Nasdaq-listed firm desired to use a ticker symbol
that was in use by an OTCBB or Pink Sheet issuer, it could usually get
such a symbol. In addition, the commenter noted that such issuers have
not paid any listing fees to be traded on those markets and that many
of them are shell companies with no operations or defunct companies.
The commenter believed that only ``legitimate'' SEC registrants that
meet the listing standards of the exchanges should be able to establish
rights to ticker symbols.
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\85\ The OTCBB is a quotation service for over-the-counter
equity securities run by FINRA, a national securities association.
\86\ Pink Sheets is an interdealer electronic quotation system
that displays quotes from market makers for many over-the-counter
securities. To be quoted on the Pink Sheets, an issuer need only
find one market maker to quote its shares, and Pink Sheets-traded
issuers need not have audited financial statements. See https://
www.pinksheets.com.
\87\ See Angel Letter I at 10.
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The Commission agrees and believes that significant investor
confusion and harm could occur if such securities, which currently
trade using four-or five-character symbols, were to begin trading with
one-, two-, or three-character symbols. The Commission believes that it
is important to distinguish between securities trading only on over-
the-counter trading venues and those listed on national securities
exchanges. Exchange listing standards are approved by the Commission
and must include corporate governance requirements that comply with
Rule 10A-3 under the Act.\88\ Issuers traded on over-the-counter equity
venues (including the OTCBB and Pink Sheets) are n