Self-Regulatory Organizations; NASDAQ OMX PHLX, Inc.; Notice of Filing and Immediate Effectiveness of Proposed Rule Change Relating to Fees for the PHOTO Historical Data Product, 73140-73144 [2010-29892]
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73140
Federal Register / Vol. 75, No. 228 / Monday, November 29, 2010 / Notices
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–63351; File No. SR–Phlx–
2010–154]
Self-Regulatory Organizations;
NASDAQ OMX PHLX, Inc.; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Relating to
Fees for the PHOTO Historical Data
Product
November 19, 2010.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on November
8, 2010, NASDAQ OMX PHLX, Inc.
(‘‘Phlx’’ or the ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(the ‘‘Commission’’) the proposed rule
change as described in Items I, II, and
III below, which Items have been
prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
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I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend its
fee schedule by establishing fees for a
new market data product, PHLX
Options Trade Outline (‘‘PHOTO’’)
Historical Data. PHOTO Historical Data
provides subscribers with historical
information about the past activity on
the Exchange during a particular
calendar month, broken down by each
option series traded on the Exchange.3
The proposed fees would become
effective on and after November 15,
2010. PHOTO Historical Data is
available only for internal use and
distribution by subscribers.
The text of the proposed rule change
is available on the Exchange’s Web site
at https://nasdaqtrader.com/
micro.aspx?id=PHLXfilings, at the
principal office of the Exchange, and at
the Commission’s Public Reference
Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 PHOTO Historical Data will be available for the
month of August 2010 and for each calendar month
dating back to January 2009. PHOTO Historical Data
will not be available for any calendar month prior
to January 2009.
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
Exchange 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 the
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The purpose of the proposed rule
change is to establish fees for the
PHOTO Historical Data market data
product.
PHOTO
In September 2010, the Exchange
established fees for its PHOTO market
data product.4 PHOTO is a market data
product offered by the Exchange that is
designed to provide proprietary
electronic trade data to subscribers.
PHOTO is available as either an ‘‘Endof-Day’’ data product or an ‘‘Intra-Day’’
data product, as described more fully
below. PHOTO Historical Data will
permit a subscriber to select a particular
prior calendar month or months and
receive the ‘‘End of Day’’ or ‘‘Intra-Day’’
data for each trading session conducted
during the calendar month(s) selected.
Like PHOTO, the PHOTO Historical
Data product is available to any person
who wishes to subscribe to it, regardless
of whether or not they are a member of
the Exchange. The fees for the PHOTO
Historical Data product are uniform for
all subscribers.
PHOTO Historical Data
PHOTO Historical Data provides
information about the past activity of all
option series for each trading session
conducted during a particular prior
calendar month, as selected by the
subscriber. PHOTO Historical Data
subscribers will receive the following
data:
• Aggregate number of buy and sell
transactions in the affected series for
each trading session conducted during
the specified calendar month(s);
• Aggregate volume traded
electronically on the Exchange in the
affected series for each trading session
conducted during the specified calendar
month(s);
• Aggregate number of trades effected
on the Exchange to open a position 5 for
2 17
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4 See Securities Exchange Act Release No. 62887
(September 10, 2010), 75 FR 57092 (September 17,
2010) (SR–Phlx–2010–121).
5 PHOTO Historical Data will provide subscribers
with the aggregate number of ‘‘opening purchase
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each trading session conducted during
the specified calendar month(s);
• Aggregate number of trades effected
on the Exchange to close a position 6 for
each trading session conducted during
the specified calendar month(s);
• Origin of the orders involved in
trades on the Exchange in the affected
series for each trading session
conducted during the specified calendar
month(s), specifically aggregated in the
following categories of participants:
Customers, broker-dealers, market
makers (including specialists,
Registered Options Traders (‘‘ROTs’’),
Streaming Quote Traders (‘‘SQTs’’) 7 and
Remote Streaming Quote Traders
(‘‘RSQTs’’) 8), and professionals.9
transactions’’ in the affected series for each trading
session conducted during the calendar month(s)
selected. An opening purchase transaction is an
Exchange options transaction in which the
purchaser’s intention is to create or increase a long
position in the series of options involved in such
transaction. See Exchange Rule 1000(b)(24). PHOTO
Historical Data will also provide subscribers with
the aggregate number of ‘‘opening writing
transactions’’ in the affected series for each trading
session conducted during the calendar month(s)
selected. An opening writing transaction is an
Exchange options transaction in which the seller’s
(writer’s) intention is to create or increase a short
position in the series of options involved in such
transaction. See Exchange Rule 1000(b)(25).
6 PHOTO Historical Data will provide subscribers
with the aggregate number of ‘‘closing purchase
transactions’’ in the affected series for each trading
session conducted during the calendar month(s)
selected. A closing purchase transaction is an
Exchange options transaction in which the
purchaser’s intention is to reduce or eliminate a
short position in the series of options involved in
such transaction. See Exchange Rule 1000(b)(27).
PHOTO Historical Data will also provide
subscribers with the aggregate number of ‘‘closing
sale transactions’’ in the affected series for each
trading session conducted during the calendar
month(s) selected. A closing sale transaction is an
Exchange options transaction in which the seller’s
intention is to reduce or eliminate a long position
in the series of options involved in such
transaction. See Exchange Rule 1000(b)(26).
7 An SQT is an Exchange Registered Options
Trader (‘‘ROT’’) who has received permission from
the Exchange to generate and submit option
quotations electronically in options to which such
SQT is assigned. See Exchange Rule 1014(b)(ii)(A).
8 An RSQT is an ROT that is a member or member
organization with no physical trading floor
presence who has received permission from the
Exchange to generate and submit option quotations
electronically in options to which such RSQT has
been assigned. An RSQT may only submit such
quotations electronically from off the floor of the
Exchange. See Exchange Rule 1014(b)(ii)(B).
9 The term ‘‘professional’’ means any person or
entity that (i) is not a broker or dealer in securities,
and (ii) places more than 390 orders in listed
options per day on average during a calendar month
for its own beneficial account(s). A professional
will be treated in the same manner as an off-floor
broker-dealer for purposes of Rules 1014(g) (except
with respect to all-or-none orders, which will be
treated like customer orders), 1033(e), 1064.02
(except professional orders will be considered
customer orders subject to facilitation), and 1080.08
as well as Options Floor Procedure Advices B–6,
B–11 and F–5. Member organizations must indicate
whether orders are for professionals. See Exchange
Rule 1000(b)(14).
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End of Day Product
The End-of-Day product includes the
aggregate data described above
representing the entire trading session.
It is calculated during an overnight
process after each trading session and is
available to subscribers for download
the following morning at approximately
7 a.m., ET. PHOTO Historical Data will
provide this data for each trading
session conducted during the calendar
month(s) selected by the subscriber.
The fee for the PHOTO Historical Data
End of Day product for subscribers is
$400.00 per calendar month selected.10
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Intra-Day Product
The Intra-Day product includes
periodic, cumulative data for a
particular trading session. The Intra-Day
product is produced and updated every
ten minutes during the trading day. Data
is captured in ‘‘snapshots’’ taken every
10 minutes throughout the trading day
and is available to subscribers within 5
minutes of the conclusion of each 10minute period. For example, subscribers
to the Intra-Day product will receive the
first calculation of intra-day data at 9:44
a.m. ET, which represents data captured
from 9:30 a.m. to 9:39 a.m. Subscribers
will receive the next update at 9:54 a.m.,
representing the data previously
provided together with data captured
from 9:40 a.m. through 9:49 a.m., and so
forth. Each update will represent the
aggregate data captured from the current
‘‘snapshot’’ and all previous ‘‘snapshots.’’
PHOTO Historical Data will provide
this regularly updated data for each
trading session conducted during the
specified calendar month(s) selected by
the subscriber. The fee for the PHOTO
Historical Data Intra-Day product
subscribers is $750.00 per calendar
month selected.11
PHOTO Historical Data provides
subscribers data that should enhance
their ability to analyze option trade and
volume data, to evaluate historical
trends in the trading activity of a
particular option series, and to create
and test trading models and analytical
10 For example, a subscriber who requests End of
Day PHOTO Historical Data for the month of March,
2009 would be charged $400.00. A subscriber who
requests End of Day PHOTO Historical Data for the
months of March, 2009 and April, 2009 would be
charged $400.00 for the March, 2009 End of Day
PHOTO Historical Data and $400.00 for the April,
2009 End of Day PHOTO Historical Data, for a total
of $800.00, etc.
11 For example, a subscriber who requests IntraDay PHOTO Historical Data for the Month of
March, 2009 would be charged $750.00. A
subscriber who requests Intra-Day PHOTO
Historical Data for the months of March, 2009 and
April, 2009 would be charged $750.00 for the
March, 2009 Intra-Day PHOTO Historical Data and
$750.00 for the April, 2009 Intra-Day PHOTO
Historical Data, for a total of $1,500.00, etc.
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strategies. The Exchange believes that
PHOTO Historical Data is a valuable
tool that subscribers can use to gain
comprehensive insight into the trading
activity in a particular series.
2. Statutory Basis
PHLX believes that the proposed rule
change is consistent with the provisions
of Section 6 of the Act,12 in general, and
with Section 6(b)(4) of the Act,13 in
particular, in that it provides an
equitable allocation of reasonable fees
among users and recipients of PHLX
data. In adopting Regulation NMS, the
Commission granted self-regulatory
organizations and broker-dealers
increased authority and flexibility to
offer new and unique market data to the
public. It was believed that this
authority would expand the amount of
data available to consumers, and also
spur innovation and competition for the
provision of market data.
The Commission concluded that
Regulation NMS—by deregulating the
market in proprietary data—would itself
further the Act’s goals of facilitating
efficiency and competition:
‘‘[E]fficiency is promoted when brokerdealers who do not need the data beyond the
prices, sizes, market center identifications of
the NBBO and consolidated last sale
information are not required to receive (and
pay for) such data. The Commission also
believes that efficiency is promoted when
broker-dealers may choose to receive (and
pay for) additional market data based on their
own internal analysis of the need for such
data.’’14
By removing ‘‘unnecessary regulatory
restrictions’’ on the ability of exchanges
to sell their own data, Regulation NMS
advanced the goals of the Act and the
principles reflected in its legislative
history. If the free market should
determine whether proprietary data is
sold to broker-dealers at all, it follows
that the price at which such data is sold
should be set by the market as well.
PHOTO is precisely the sort of market
data product that the Commission
envisioned when it adopted Regulation
NMS.
On July 21, 2010, President Barak
Obama signed into law H.R. 4173, the
Dodd-Frank Wall Street Reform and
Consumer Protection Act of 2010
(‘‘Dodd-Frank Act’’), which amended
Section 19 of the Act. Among other
things, Section 916 of the Dodd-Frank
Act amended paragraph (A) of Section
19(b)(3) of the Act by inserting the
phrase ‘‘on any person, whether or not
the person is a member of the self12 15
U.S.C. 78f.
U.S.C. 78f(b)(4).
14 See Securities Exchange Act Release No. 51808
(June 9, 2005), 70 FR 37496 (June 29, 2005).
13 15
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regulatory organization’’ after ‘‘due, fee
or other charge imposed by the selfregulatory organization.’’ As a result, all
SRO rule proposals establishing or
changing dues, fees, or other charges are
immediately effective upon filing
regardless of whether such dues, fees, or
other charges are imposed on members
of the SRO, non-members, or both.
Section 916 further amended paragraph
(C) of Section 19(b)(3) of the Exchange
Act to read, in pertinent part, ‘‘At any
time within the 60-day period beginning
on the date of filing of such a proposed
rule change in accordance with the
provisions of paragraph (1) [of Section
19(b)], the Commission summarily may
temporarily suspend the change in the
rules of the self-regulatory organization
made thereby, if it appears to the
Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of this title. If the Commission
takes such action, the Commission shall
institute proceedings under paragraph
(2)(B) [of Section 19(b)] to determine
whether the proposed rule should be
approved or disapproved.’’
PHLX believes that these amendments
to Section 19 of the Act reflect Congress’
intent to allow the Commission to rely
upon the forces of competition to ensure
that fees for market data are reasonable
and equitably allocated. Although
Section 19(b) had formerly authorized
immediate effectiveness for a ‘‘due, fee
or other charge imposed by the selfregulatory organization,’’ the
Commission adopted a policy and
subsequently a rule stipulating that fees
for data and other products available to
persons that are not members of the selfregulatory organization must be
approved by the Commission after first
being published for comment. At the
time, the Commission supported the
adoption of the policy and the rule by
pointing out that unlike members,
whose representation in self-regulatory
organization governance was mandated
by the Act, non-members should be
given the opportunity to comment on
fees before being required to pay them,
and that the Commission should
specifically approve all such fees.
PHLX believes that the amendment to
Section 19 reflects Congress’ conclusion
that the evolution of self-regulatory
organization governance and
competitive market structure have
rendered the Commission’s prior policy
on non-member fees obsolete.
Specifically, many exchanges have
evolved from member-owned not-forprofit corporations into for-profit
investor-owned corporations (or
subsidiaries of investor owned
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corporations). Accordingly, exchanges
no longer have narrow incentives to
manage their affairs for the exclusive
benefit of their members, but rather
have incentives to maximize the appeal
of their products to all customers,
whether members or nonmembers, so as
to broaden distribution and grow
revenues. Moreover, we believe that the
change also reflects an endorsement of
the Commission’s determinations that
reliance on competitive markets is an
appropriate means to ensure equitable
and reasonable prices. Simply put, the
change reflects a presumption that all
fee changes should be permitted to take
effect immediately, since the level of all
fees are constrained by competitive
forces.
The recent decision of the United
States Court of Appeals for the District
of Columbia Circuit in NetCoaliton [sic]
v. SEC, No. 09–1042 (DC Cir. 2010),
although reviewing a Commission
decision made prior to the effective date
of the Dodd-Frank Act, upheld the
Commission’s reliance upon
competitive markets to set reasonable
and equitably allocated fees for market
data. ‘‘In fact, the legislative history
indicates that the Congress intended
that the market system ‘evolve through
the interplay of competitive forces as
unnecessary regulatory restrictions are
removed’ and that the SEC wield its
regulatory power ‘in those situations
where competition may not be
sufficient,’ such as in the creation of a
‘consolidated transactional reporting
system.’ ’’ 15
The court’s conclusions about
Congressional intent are therefore
reinforced by the Dodd-Frank Act
amendments, which create a
presumption that exchange fees,
including market data fees, may take
effect immediately, without prior
Commission approval, and that the
Commission should take action to
suspend a fee change and institute a
proceeding to determine whether the fee
change should be approved or
disapproved only where the
Commission has concerns that the
change may not be consistent with the
Act.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
PHLX does not believe that the
proposed rule change will result in any
burden on competition that is not
necessary or appropriate in furtherance
of the purposes of the Act, as amended.
Notwithstanding its determination that
15 NetCoaltion [sic], at 15 (quoting H.R. Rep. No.
94–229, at 92 (1975), as reprinted in 1975
U.S.C.C.A.N. 321, 323).
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the Commission may rely upon
competition to establish fair and
equitably allocated fees for market data,
the NetCoaltion [sic] court found that
the Commission had not, in that case,
compiled a record that adequately
supported its conclusion that the market
for the data at issue in the case was
competitive.
For the reasons discussed above,
PHLX believes that the Dodd-Frank Act
amendments to Section 19 materially
alter the scope of the Commission’s
review of future market data filings, by
creating a presumption that all fees may
take effect immediately, without prior
analysis by the Commission of the
competitive environment.
Even in the absence of this important
statutory change, however, PHLX
believes that a record may readily be
established to demonstrate the
competitive nature of the market in
question.
There is intense competition between
trading platforms that provide
transaction execution and routing
services and proprietary data products.
Transaction execution and proprietary
data products are complementary in that
market data is both an input and a byproduct of the execution service. In fact,
market data and trade execution are a
paradigmatic example of joint products
with joint costs. The decision whether
and on which platform to post an order
will depend on the attributes of the
platform where the order can be posted,
including the execution fees, data
quality and price and distribution of its
data products. Without the prospect of
a taking order seeing and reacting to a
posted order on a particular platform,
the posting of the order would
accomplish little.
Without trade executions, exchange
data products cannot exist. Data
products are valuable to many end users
only insofar as they provide information
that end users expect will assist them or
their customers in making trading
decisions.
The costs of producing market data
include not only the costs of the data
distribution infrastructure, but also the
costs of designing, maintaining, and
operating the exchange’s transaction
execution platform and the cost of
regulating the exchange to ensure its fair
operation and maintain investor
confidence. The total return that a
trading platform earns reflects the
revenues it receives from both products
and the joint costs it incurs. Moreover,
an exchange’s customers view the costs
of transaction executions and of data as
a unified cost of doing business with the
exchange. A broker-dealer will direct
orders to a particular exchange only if
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the expected revenues from executing
trades on the exchange exceed net
transaction execution costs and the cost
of data that the broker-dealer chooses to
buy to support its trading decisions (or
those of its customers). The choice of
data products is, in turn, a product of
the value of the products in making
profitable trading decisions. If the cost
of the product exceeds its expected
value, the broker-dealer will choose not
to buy it. Moreover, as a broker-dealer
chooses to direct fewer orders to a
particular exchange, the value of the
product to that broker-dealer decreases,
for two reasons. First, the product will
contain less information, because
executions of the broker-dealer’s orders
will not be reflected in it. Second, and
perhaps more important, the product
will be less valuable to that brokerdealer because it does not provide
information about the venue to which it
is directing its orders. Data from the
competing venue to which the brokerdealer is directing orders will become
correspondingly more valuable.
Thus, a super-competitive increase in
the fees charged for either transactions
or data has the potential to impair
revenues from both products. ‘‘No one
disputes that competition for order flow
is ‘fierce’.’’ 16 However, the existence of
fierce competition for order flow
implies a high degree of price sensitivity
on the part of broker-dealers with order
flow, since they may readily reduce
costs by directing orders toward the
lowest-cost trading venues. A brokerdealer that shifted its order flow from
one platform to another in response to
order execution price differentials
would both reduce the value of that
platform’s market data and reduce its
own need to consume data from the
disfavored platform. Similarly, if a
platform increases its market data fees,
the change will affect the overall cost of
doing business with the platform, and
affected broker-dealers will assess
whether they can lower their trading
costs by directing orders elsewhere and
thereby lessening the need for the more
expensive data.
Analyzing the cost of market data
distribution in isolation from the cost of
all of the inputs supporting the creation
of market data will inevitably
underestimate the cost of the data. Thus,
because it is impossible to create data
without a fast, technologically robust,
and well-regulated execution system,
system costs and regulatory costs affect
the price of market data. It would be
equally misleading, however, to
attribute all of the exchange’s costs to
the market data portion of an exchange’s
16 NetCoalition
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joint product. Rather, all of the
exchange’s costs are incurred for the
unified purposes of attracting order
flow, executing and/or routing orders,
and generating and selling data about
market activity. The total return that an
exchange earns reflects the revenues it
receives from the joint products and the
total costs of the joint products.
Competition among trading platforms
can be expected to constrain the
aggregate return each platform earns
from the sale of its joint products, but
different platforms may choose from a
range of possible, and equally
reasonable, pricing strategies as the
means of recovering total costs. For
example, some platforms may choose to
pay rebates to attract orders, charge
relatively low prices for market
information (or provide information free
of charge) and charge relatively high
prices for accessing posted liquidity.
Other platforms may choose a strategy
of paying lower rebates (or no rebates)
to attract orders, setting relatively high
prices for market information, and
setting relatively low prices for
accessing posted liquidity. In this
environment, there is no economic basis
for regulating maximum prices for one
of the joint products in an industry in
which suppliers face competitive
constraints with regard to the joint
offering. This would be akin to strictly
regulating the price that an automobile
manufacturer can charge for car sound
systems despite the existence of a highly
competitive market for cars and the
availability of aftermarket alternatives to
the manufacturer-supplied system.
The market for market data products
is competitive and inherently
contestable because there is fierce
competition for the inputs necessary to
the creation of proprietary data and
strict pricing discipline for the
proprietary products themselves.
Numerous exchanges compete with
each other for listings, trades, and
market data itself, providing virtually
limitless opportunities for entrepreneurs
who wish to produce and distribute
their own market data. This proprietary
data is produced by each individual
exchange, as well as other entities, in a
vigorously competitive market. Brokerdealers currently have numerous
alternative venues for their order flow,
including ten self-regulatory
organization (‘‘SRO’’) markets, as well as
internalizing broker-dealers (‘‘BDs’’) and
various forms of alternative trading
systems (‘‘ATSs’’), including dark pools
and electronic communication networks
(‘‘ECNs’’). Each SRO market competes to
produce transaction reports via trade
executions, and two FINRA regulated
Trade Reporting Facilities (‘‘TRFs’’)
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compete to attract internalized
transaction reports. Competitive markets
for order flow, executions, and
transaction reports provide pricing
discipline for the inputs of proprietary
data products. For example, the
Exchange notes that at least one other
U.S. options exchange offers a market
data product that is substantially similar
to the PHOTO Historical Data product,
which the PHLX must consider in its
pricing discipline in order to compete
for listings, trades, and the market data
itself.17
The large number of SROs, TRFs, BDs,
and ATSs that currently produce
proprietary data or are currently capable
of producing it provides further pricing
discipline for proprietary data products.
Each SRO, TRF, ATS, and BD is
currently permitted to produce
proprietary data products, and many
currently do or have announced plans to
do so, including PHLX, NASDAQ,
NYSE, NYSE Amex, NYSEArca, and
BATS.
Any ATS or BD can combine with any
other ATS, BD, or multiple ATSs or BDs
to produce joint proprietary data
products. Additionally, order routers
and market data vendors can facilitate
single or multiple broker-dealers’
production of proprietary data products.
The potential sources of proprietary
products are virtually limitless.
The fact that proprietary data from
ATSs, BDs, and vendors can by-pass
SROs is significant in two respects.
First, non-SROs can compete directly
with SROs for the production and sale
of proprietary data products, as BATS
and Arca did before registering as
exchanges by publishing proprietary
book data on the Internet. Second,
because a single order or transaction
report can appear in an SRO proprietary
product, a non-SRO proprietary
product, or both, the data available in
proprietary products is exponentially
greater than the actual number of orders
and transaction reports that exist in the
marketplace.
Market data vendors provide another
form of price discipline for proprietary
data products because they control the
primary means of access to end users.
17 The International Securities Exchange, Inc.
(‘‘ISE’’) Open/Close Trade Profile and the ISE Open/
Close Trade Profile Intra-Day contain substantially
similar data to that included in PHOTO End of Day
and PHOTO Intra-Day. See Securities Exchange Act
Release No. 56254 (August 15, 2007), 72 FR 47104
(August 22, 2007) (SR–ISE–2007–70). ISE currently
sells the ISE Open/Close Trade Profile with
historical data available back to May 2005, and sells
the ISE Open/Close Trade Profile Intraday with
historical data available separately back to October
2009. See Securities Exchange act Release No.
61317 (January 8, 2010), 75 FR 2915 (January 19,
2010) (SR–ISE–2009–103).
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73143
Vendors impose price restraints based
upon their business models. For
example, vendors such as Bloomberg
and Reuters that assess a surcharge on
data they sell may refuse to offer
proprietary products that end users will
not purchase in sufficient numbers.
Internet portals, such as Yahoo, impose
a discipline by providing only data that
will enable them to attract ‘‘eyeballs’’
that contribute to their advertising
revenue. Retail broker-dealers, such as
Schwab and Fidelity, offer their
customers proprietary data only if it
promotes trading and generates
sufficient commission revenue.
Although the business models may
differ, these vendors’ pricing discipline
is the same: They can simply refuse to
purchase any proprietary data product
that fails to provide sufficient value.
PHLX and other producers of
proprietary data products must
understand and respond to these
varying business models and pricing
disciplines in order to market
proprietary data products successfully.
In addition to the competition and
price discipline described above, the
market for proprietary data products is
also highly contestable because market
entry is rapid, inexpensive, and
profitable. The history of electronic
trading is replete with examples of
entrants that swiftly grew into some of
the largest electronic trading platforms
and proprietary data producers:
Archipelago, Bloomberg Tradebook,
Island, RediBook, Attain, TracECN,
BATS Trading and Direct Edge. A
proliferation of dark pools and other
ATSs operate profitably with
fragmentary shares of consolidated
market volume.
Regulation NMS, by deregulating the
market for proprietary data, has
increased the contestability of that
market. While broker-dealers have
previously published their proprietary
data individually, Regulation NMS
encourages market data vendors and
broker-dealers to produce proprietary
products cooperatively in a manner
never before possible. Multiple market
data vendors already have the capability
to aggregate data and disseminate it on
a profitable scale, including Bloomberg,
and Thomson-Reuters.
The court in NetCoalition concluded
that the Commission had failed to
demonstrate that the market for market
data was competitive based on the
reasoning of the Commission’s
NetCoalition order because, in the
court’s view, the Commission had not
adequately demonstrated that the depthof-book data at issue in the case is used
to attract order flow. PHLX believes,
however, that evidence not before the
E:\FR\FM\29NON1.SGM
29NON1
73144
Federal Register / Vol. 75, No. 228 / Monday, November 29, 2010 / Notices
court clearly demonstrates that
availability of depth data attracts order
flow.
Competition among platforms has
driven PHLX continually to improve its
platform data offerings and to cater to
customers’ data needs. For example,
PHLX offers front end applications such
as its Top of PHLX Options (‘‘TOPO’’)
and TOPO Plus Orders data products to
help customers utilize data.
For the foregoing reasons, PHLX does
not believe that the proposed rule
change will result in any burden on
competition that is not necessary or
appropriate in furtherance of the
purpose of the Act.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were either
solicited or received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become
effective pursuant to Section
19(b)(3)(A)(ii) of the Act.18 At any time
within 60 days of the filing of the
proposed rule change, the Commission
summarily may temporarily suspend
such rule change if it appears to the
Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of the Act. If the Commission
takes such action, the Commission shall
institute proceedings to determine
whether the proposed rule should be
approved or disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
mstockstill on DSKH9S0YB1PROD with NOTICES
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–Phlx–2010–154 on the
subject line.
100 F Street, NE., Washington, DC
20549–1090.
All submissions should refer to File
Number SR–Phlx–2010–154. This file
number should be included on the
subject line if e-mail is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, on official business
days between the hours of 10 a.m. and
3 p.m. Copies of the filing also will be
available for inspection and copying at
the principal office of the Exchange. All
comments received will be posted
without change; the Commission does
not edit personal identifying
information from submissions. You
should submit only information that
you wish to make available publicly. All
submissions should refer to File
Number SR–Phlx–2010–154 and should
be submitted on or before December 20,
2010.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.19
Elizabeth M. Murphy,
Secretary.
[FR Doc. 2010–29892 Filed 11–26–10; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–63357; File No. SR–ISE–
2010–110]
Self-Regulatory Organizations;
International Securities Exchange,
LLC; Notice of Filing and Immediate
Effectiveness of Proposed Rule
Change Relating to the Extension of a
Pilot Program for Directed Orders
November 22, 2010.
Paper Comments
• Send paper comments in triplicate
to Elizabeth M. Murphy, Secretary,
Securities and Exchange Commission,
U.S.C. 78s(b)(3)(A)(ii).
VerDate Mar<15>2010
17:57 Nov 26, 2010
1 15
Jkt 223001
PO 00000
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
Frm 00118
Fmt 4703
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The ISE is proposing to extend the
pilot period for the system change that
identifies to a Directed Market Maker
(‘‘DMM’’) the identity of the firm
entering a Directed Order until May 31,
2011.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization 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 self-regulatory organization 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
On January 5, 2006, the ISE initiated
a system change to identify to a DMM
the identity of the firm entering a
Directed Order. The ISE filed this
system change on a pilot basis under
Section 19(b)(3)(A) of the Exchange Act
of 1934 (the ‘‘Exchange Act’’) and Rule
19b–4(f)(5) thereunder 3 so that it would
be effective while the Commission
considered a separate proposed rule
change filed under Section 19(b)(2) of
the Exchange Act to amend the ISE’s
rules to reflect the system change on a
permanent basis (the ‘‘Permanent Rule
Change’’).4 The current pilot expires on
2 17
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Exchange Act’’),1 and Rule 19b–4
19 17
18 15
thereunder,2 notice is hereby given that
on November 16, 2010, the International
Securities Exchange, LLC (the
‘‘Exchange’’ or the ‘‘ISE’’) filed with the
Securities and Exchange Commission
the proposed rule change, as described
in Items I and II below, which items
have been prepared by the selfregulatory organization. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
Sfmt 4703
CFR 240.19b–4.
Securities Exchange Act Release No. 53104
(Jan. 11, 2006), 71 FR 2142 (Jan. 19, 2006) (Notice
of Filing and Immediate Effectiveness of SR–ISE–
2006–02).
4 See Securities Exchange Act Release No. 53103
(Jan. 11, 2006), 71 FR 3144 (Jan. 19, 2006) (Notice
of Filing of SR–ISE–2006–01).
3 See
E:\FR\FM\29NON1.SGM
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Agencies
[Federal Register Volume 75, Number 228 (Monday, November 29, 2010)]
[Notices]
[Pages 73140-73144]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2010-29892]
[[Page 73140]]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-63351; File No. SR-Phlx-2010-154]
Self-Regulatory Organizations; NASDAQ OMX PHLX, Inc.; Notice of
Filing and Immediate Effectiveness of Proposed Rule Change Relating to
Fees for the PHOTO Historical Data Product
November 19, 2010.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(the ``Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is hereby given
that on November 8, 2010, NASDAQ OMX PHLX, Inc. (``Phlx'' or the
``Exchange'') filed with the Securities and Exchange Commission (the
``Commission'') the proposed rule change as described in Items I, II,
and III below, which Items have been prepared by the Exchange. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
The Exchange proposes to amend its fee schedule by establishing
fees for a new market data product, PHLX Options Trade Outline
(``PHOTO'') Historical Data. PHOTO Historical Data provides subscribers
with historical information about the past activity on the Exchange
during a particular calendar month, broken down by each option series
traded on the Exchange.\3\ The proposed fees would become effective on
and after November 15, 2010. PHOTO Historical Data is available only
for internal use and distribution by subscribers.
---------------------------------------------------------------------------
\3\ PHOTO Historical Data will be available for the month of
August 2010 and for each calendar month dating back to January 2009.
PHOTO Historical Data will not be available for any calendar month
prior to January 2009.
---------------------------------------------------------------------------
The text of the proposed rule change is available on the Exchange's
Web site at https://nasdaqtrader.com/micro.aspx?id=PHLXfilings, at the
principal office of the Exchange, and at the Commission's Public
Reference Room.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, the Exchange 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 Exchange 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 the
Statutory Basis for, the Proposed Rule Change
1. Purpose
The purpose of the proposed rule change is to establish fees for
the PHOTO Historical Data market data product.
PHOTO
In September 2010, the Exchange established fees for its PHOTO
market data product.\4\ PHOTO is a market data product offered by the
Exchange that is designed to provide proprietary electronic trade data
to subscribers. PHOTO is available as either an ``End-of-Day'' data
product or an ``Intra-Day'' data product, as described more fully
below. PHOTO Historical Data will permit a subscriber to select a
particular prior calendar month or months and receive the ``End of
Day'' or ``Intra-Day'' data for each trading session conducted during
the calendar month(s) selected. Like PHOTO, the PHOTO Historical Data
product is available to any person who wishes to subscribe to it,
regardless of whether or not they are a member of the Exchange. The
fees for the PHOTO Historical Data product are uniform for all
subscribers.
---------------------------------------------------------------------------
\4\ See Securities Exchange Act Release No. 62887 (September 10,
2010), 75 FR 57092 (September 17, 2010) (SR-Phlx-2010-121).
---------------------------------------------------------------------------
PHOTO Historical Data
PHOTO Historical Data provides information about the past activity
of all option series for each trading session conducted during a
particular prior calendar month, as selected by the subscriber. PHOTO
Historical Data subscribers will receive the following data:
Aggregate number of buy and sell transactions in the
affected series for each trading session conducted during the specified
calendar month(s);
Aggregate volume traded electronically on the Exchange in
the affected series for each trading session conducted during the
specified calendar month(s);
Aggregate number of trades effected on the Exchange to
open a position \5\ for each trading session conducted during the
specified calendar month(s);
---------------------------------------------------------------------------
\5\ PHOTO Historical Data will provide subscribers with the
aggregate number of ``opening purchase transactions'' in the
affected series for each trading session conducted during the
calendar month(s) selected. An opening purchase transaction is an
Exchange options transaction in which the purchaser's intention is
to create or increase a long position in the series of options
involved in such transaction. See Exchange Rule 1000(b)(24). PHOTO
Historical Data will also provide subscribers with the aggregate
number of ``opening writing transactions'' in the affected series
for each trading session conducted during the calendar month(s)
selected. An opening writing transaction is an Exchange options
transaction in which the seller's (writer's) intention is to create
or increase a short position in the series of options involved in
such transaction. See Exchange Rule 1000(b)(25).
---------------------------------------------------------------------------
Aggregate number of trades effected on the Exchange to
close a position \6\ for each trading session conducted during the
specified calendar month(s);
---------------------------------------------------------------------------
\6\ PHOTO Historical Data will provide subscribers with the
aggregate number of ``closing purchase transactions'' in the
affected series for each trading session conducted during the
calendar month(s) selected. A closing purchase transaction is an
Exchange options transaction in which the purchaser's intention is
to reduce or eliminate a short position in the series of options
involved in such transaction. See Exchange Rule 1000(b)(27). PHOTO
Historical Data will also provide subscribers with the aggregate
number of ``closing sale transactions'' in the affected series for
each trading session conducted during the calendar month(s)
selected. A closing sale transaction is an Exchange options
transaction in which the seller's intention is to reduce or
eliminate a long position in the series of options involved in such
transaction. See Exchange Rule 1000(b)(26).
---------------------------------------------------------------------------
Origin of the orders involved in trades on the Exchange in
the affected series for each trading session conducted during the
specified calendar month(s), specifically aggregated in the following
categories of participants: Customers, broker-dealers, market makers
(including specialists, Registered Options Traders (``ROTs''),
Streaming Quote Traders (``SQTs'') \7\ and Remote Streaming Quote
Traders (``RSQTs'') \8\), and professionals.\9\
---------------------------------------------------------------------------
\7\ An SQT is an Exchange Registered Options Trader (``ROT'')
who has received permission from the Exchange to generate and submit
option quotations electronically in options to which such SQT is
assigned. See Exchange Rule 1014(b)(ii)(A).
\8\ An RSQT is an ROT that is a member or member organization
with no physical trading floor presence who has received permission
from the Exchange to generate and submit option quotations
electronically in options to which such RSQT has been assigned. An
RSQT may only submit such quotations electronically from off the
floor of the Exchange. See Exchange Rule 1014(b)(ii)(B).
\9\ The term ``professional'' means any person or entity that
(i) is not a broker or dealer in securities, and (ii) places more
than 390 orders in listed options per day on average during a
calendar month for its own beneficial account(s). A professional
will be treated in the same manner as an off-floor broker-dealer for
purposes of Rules 1014(g) (except with respect to all-or-none
orders, which will be treated like customer orders), 1033(e),
1064.02 (except professional orders will be considered customer
orders subject to facilitation), and 1080.08 as well as Options
Floor Procedure Advices B-6, B-11 and F-5. Member organizations must
indicate whether orders are for professionals. See Exchange Rule
1000(b)(14).
---------------------------------------------------------------------------
[[Page 73141]]
End of Day Product
The End-of-Day product includes the aggregate data described above
representing the entire trading session. It is calculated during an
overnight process after each trading session and is available to
subscribers for download the following morning at approximately 7 a.m.,
ET. PHOTO Historical Data will provide this data for each trading
session conducted during the calendar month(s) selected by the
subscriber.
The fee for the PHOTO Historical Data End of Day product for
subscribers is $400.00 per calendar month selected.\10\
---------------------------------------------------------------------------
\10\ For example, a subscriber who requests End of Day PHOTO
Historical Data for the month of March, 2009 would be charged
$400.00. A subscriber who requests End of Day PHOTO Historical Data
for the months of March, 2009 and April, 2009 would be charged
$400.00 for the March, 2009 End of Day PHOTO Historical Data and
$400.00 for the April, 2009 End of Day PHOTO Historical Data, for a
total of $800.00, etc.
---------------------------------------------------------------------------
Intra-Day Product
The Intra-Day product includes periodic, cumulative data for a
particular trading session. The Intra-Day product is produced and
updated every ten minutes during the trading day. Data is captured in
``snapshots'' taken every 10 minutes throughout the trading day and is
available to subscribers within 5 minutes of the conclusion of each 10-
minute period. For example, subscribers to the Intra-Day product will
receive the first calculation of intra-day data at 9:44 a.m. ET, which
represents data captured from 9:30 a.m. to 9:39 a.m. Subscribers will
receive the next update at 9:54 a.m., representing the data previously
provided together with data captured from 9:40 a.m. through 9:49 a.m.,
and so forth. Each update will represent the aggregate data captured
from the current ``snapshot'' and all previous ``snapshots.''
PHOTO Historical Data will provide this regularly updated data for
each trading session conducted during the specified calendar month(s)
selected by the subscriber. The fee for the PHOTO Historical Data
Intra-Day product subscribers is $750.00 per calendar month
selected.\11\
---------------------------------------------------------------------------
\11\ For example, a subscriber who requests Intra-Day PHOTO
Historical Data for the Month of March, 2009 would be charged
$750.00. A subscriber who requests Intra-Day PHOTO Historical Data
for the months of March, 2009 and April, 2009 would be charged
$750.00 for the March, 2009 Intra-Day PHOTO Historical Data and
$750.00 for the April, 2009 Intra-Day PHOTO Historical Data, for a
total of $1,500.00, etc.
---------------------------------------------------------------------------
PHOTO Historical Data provides subscribers data that should enhance
their ability to analyze option trade and volume data, to evaluate
historical trends in the trading activity of a particular option
series, and to create and test trading models and analytical
strategies. The Exchange believes that PHOTO Historical Data is a
valuable tool that subscribers can use to gain comprehensive insight
into the trading activity in a particular series.
2. Statutory Basis
PHLX believes that the proposed rule change is consistent with the
provisions of Section 6 of the Act,\12\ in general, and with Section
6(b)(4) of the Act,\13\ in particular, in that it provides an equitable
allocation of reasonable fees among users and recipients of PHLX data.
In adopting Regulation NMS, the Commission granted self-regulatory
organizations and broker-dealers increased authority and flexibility to
offer new and unique market data to the public. It was believed that
this authority would expand the amount of data available to consumers,
and also spur innovation and competition for the provision of market
data.
---------------------------------------------------------------------------
\12\ 15 U.S.C. 78f.
\13\ 15 U.S.C. 78f(b)(4).
---------------------------------------------------------------------------
The Commission concluded that Regulation NMS--by deregulating the
market in proprietary data--would itself further the Act's goals of
facilitating efficiency and competition:
``[E]fficiency is promoted when broker-dealers who do not need
the data beyond the prices, sizes, market center identifications of
the NBBO and consolidated last sale information are not required to
receive (and pay for) such data. The Commission also believes that
efficiency is promoted when broker-dealers may choose to receive
(and pay for) additional market data based on their own internal
analysis of the need for such data.''\14\
---------------------------------------------------------------------------
\14\ See Securities Exchange Act Release No. 51808 (June 9,
2005), 70 FR 37496 (June 29, 2005).
By removing ``unnecessary regulatory restrictions'' on the ability
of exchanges to sell their own data, Regulation NMS advanced the goals
of the Act and the principles reflected in its legislative history. If
the free market should determine whether proprietary data is sold to
broker-dealers at all, it follows that the price at which such data is
sold should be set by the market as well. PHOTO is precisely the sort
of market data product that the Commission envisioned when it adopted
Regulation NMS.
On July 21, 2010, President Barak Obama signed into law H.R. 4173,
the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010
(``Dodd-Frank Act''), which amended Section 19 of the Act. Among other
things, Section 916 of the Dodd-Frank Act amended paragraph (A) of
Section 19(b)(3) of the Act by inserting the phrase ``on any person,
whether or not the person is a member of the self-regulatory
organization'' after ``due, fee or other charge imposed by the self-
regulatory organization.'' As a result, all SRO rule proposals
establishing or changing dues, fees, or other charges are immediately
effective upon filing regardless of whether such dues, fees, or other
charges are imposed on members of the SRO, non-members, or both.
Section 916 further amended paragraph (C) of Section 19(b)(3) of the
Exchange Act to read, in pertinent part, ``At any time within the 60-
day period beginning on the date of filing of such a proposed rule
change in accordance with the provisions of paragraph (1) [of Section
19(b)], the Commission summarily may temporarily suspend the change in
the rules of the self-regulatory organization made thereby, if it
appears to the Commission that such action is necessary or appropriate
in the public interest, for the protection of investors, or otherwise
in furtherance of the purposes of this title. If the Commission takes
such action, the Commission shall institute proceedings under paragraph
(2)(B) [of Section 19(b)] to determine whether the proposed rule should
be approved or disapproved.''
PHLX believes that these amendments to Section 19 of the Act
reflect Congress' intent to allow the Commission to rely upon the
forces of competition to ensure that fees for market data are
reasonable and equitably allocated. Although Section 19(b) had formerly
authorized immediate effectiveness for a ``due, fee or other charge
imposed by the self-regulatory organization,'' the Commission adopted a
policy and subsequently a rule stipulating that fees for data and other
products available to persons that are not members of the self-
regulatory organization must be approved by the Commission after first
being published for comment. At the time, the Commission supported the
adoption of the policy and the rule by pointing out that unlike
members, whose representation in self-regulatory organization
governance was mandated by the Act, non-members should be given the
opportunity to comment on fees before being required to pay them, and
that the Commission should specifically approve all such fees.
PHLX believes that the amendment to Section 19 reflects Congress'
conclusion that the evolution of self-regulatory organization
governance and competitive market structure have rendered the
Commission's prior policy on non-member fees obsolete.
Specifically, many exchanges have evolved from member-owned not-
for-profit corporations into for-profit investor-owned corporations (or
subsidiaries of investor owned
[[Page 73142]]
corporations). Accordingly, exchanges no longer have narrow incentives
to manage their affairs for the exclusive benefit of their members, but
rather have incentives to maximize the appeal of their products to all
customers, whether members or nonmembers, so as to broaden distribution
and grow revenues. Moreover, we believe that the change also reflects
an endorsement of the Commission's determinations that reliance on
competitive markets is an appropriate means to ensure equitable and
reasonable prices. Simply put, the change reflects a presumption that
all fee changes should be permitted to take effect immediately, since
the level of all fees are constrained by competitive forces.
The recent decision of the United States Court of Appeals for the
District of Columbia Circuit in NetCoaliton [sic] v. SEC, No. 09-1042
(DC Cir. 2010), although reviewing a Commission decision made prior to
the effective date of the Dodd-Frank Act, upheld the Commission's
reliance upon competitive markets to set reasonable and equitably
allocated fees for market data. ``In fact, the legislative history
indicates that the Congress intended that the market system `evolve
through the interplay of competitive forces as unnecessary regulatory
restrictions are removed' and that the SEC wield its regulatory power
`in those situations where competition may not be sufficient,' such as
in the creation of a `consolidated transactional reporting system.' ''
\15\
---------------------------------------------------------------------------
\15\ NetCoaltion [sic], at 15 (quoting H.R. Rep. No. 94-229, at
92 (1975), as reprinted in 1975 U.S.C.C.A.N. 321, 323).
---------------------------------------------------------------------------
The court's conclusions about Congressional intent are therefore
reinforced by the Dodd-Frank Act amendments, which create a presumption
that exchange fees, including market data fees, may take effect
immediately, without prior Commission approval, and that the Commission
should take action to suspend a fee change and institute a proceeding
to determine whether the fee change should be approved or disapproved
only where the Commission has concerns that the change may not be
consistent with the Act.
B. Self-Regulatory Organization's Statement on Burden on Competition
PHLX does not believe that the proposed rule change will result in
any burden on competition that is not necessary or appropriate in
furtherance of the purposes of the Act, as amended. Notwithstanding its
determination that the Commission may rely upon competition to
establish fair and equitably allocated fees for market data, the
NetCoaltion [sic] court found that the Commission had not, in that
case, compiled a record that adequately supported its conclusion that
the market for the data at issue in the case was competitive.
For the reasons discussed above, PHLX believes that the Dodd-Frank
Act amendments to Section 19 materially alter the scope of the
Commission's review of future market data filings, by creating a
presumption that all fees may take effect immediately, without prior
analysis by the Commission of the competitive environment.
Even in the absence of this important statutory change, however,
PHLX believes that a record may readily be established to demonstrate
the competitive nature of the market in question.
There is intense competition between trading platforms that provide
transaction execution and routing services and proprietary data
products. Transaction execution and proprietary data products are
complementary in that market data is both an input and a by-product of
the execution service. In fact, market data and trade execution are a
paradigmatic example of joint products with joint costs. The decision
whether and on which platform to post an order will depend on the
attributes of the platform where the order can be posted, including the
execution fees, data quality and price and distribution of its data
products. Without the prospect of a taking order seeing and reacting to
a posted order on a particular platform, the posting of the order would
accomplish little.
Without trade executions, exchange data products cannot exist. Data
products are valuable to many end users only insofar as they provide
information that end users expect will assist them or their customers
in making trading decisions.
The costs of producing market data include not only the costs of
the data distribution infrastructure, but also the costs of designing,
maintaining, and operating the exchange's transaction execution
platform and the cost of regulating the exchange to ensure its fair
operation and maintain investor confidence. The total return that a
trading platform earns reflects the revenues it receives from both
products and the joint costs it incurs. Moreover, an exchange's
customers view the costs of transaction executions and of data as a
unified cost of doing business with the exchange. A broker-dealer will
direct orders to a particular exchange only if the expected revenues
from executing trades on the exchange exceed net transaction execution
costs and the cost of data that the broker-dealer chooses to buy to
support its trading decisions (or those of its customers). The choice
of data products is, in turn, a product of the value of the products in
making profitable trading decisions. If the cost of the product exceeds
its expected value, the broker-dealer will choose not to buy it.
Moreover, as a broker-dealer chooses to direct fewer orders to a
particular exchange, the value of the product to that broker-dealer
decreases, for two reasons. First, the product will contain less
information, because executions of the broker-dealer's orders will not
be reflected in it. Second, and perhaps more important, the product
will be less valuable to that broker-dealer because it does not provide
information about the venue to which it is directing its orders. Data
from the competing venue to which the broker-dealer is directing orders
will become correspondingly more valuable.
Thus, a super-competitive increase in the fees charged for either
transactions or data has the potential to impair revenues from both
products. ``No one disputes that competition for order flow is
`fierce'.'' \16\ However, the existence of fierce competition for order
flow implies a high degree of price sensitivity on the part of broker-
dealers with order flow, since they may readily reduce costs by
directing orders toward the lowest-cost trading venues. A broker-dealer
that shifted its order flow from one platform to another in response to
order execution price differentials would both reduce the value of that
platform's market data and reduce its own need to consume data from the
disfavored platform. Similarly, if a platform increases its market data
fees, the change will affect the overall cost of doing business with
the platform, and affected broker-dealers will assess whether they can
lower their trading costs by directing orders elsewhere and thereby
lessening the need for the more expensive data.
---------------------------------------------------------------------------
\16\ NetCoalition at 24.
---------------------------------------------------------------------------
Analyzing the cost of market data distribution in isolation from
the cost of all of the inputs supporting the creation of market data
will inevitably underestimate the cost of the data. Thus, because it is
impossible to create data without a fast, technologically robust, and
well-regulated execution system, system costs and regulatory costs
affect the price of market data. It would be equally misleading,
however, to attribute all of the exchange's costs to the market data
portion of an exchange's
[[Page 73143]]
joint product. Rather, all of the exchange's costs are incurred for the
unified purposes of attracting order flow, executing and/or routing
orders, and generating and selling data about market activity. The
total return that an exchange earns reflects the revenues it receives
from the joint products and the total costs of the joint products.
Competition among trading platforms can be expected to constrain
the aggregate return each platform earns from the sale of its joint
products, but different platforms may choose from a range of possible,
and equally reasonable, pricing strategies as the means of recovering
total costs. For example, some platforms may choose to pay rebates to
attract orders, charge relatively low prices for market information (or
provide information free of charge) and charge relatively high prices
for accessing posted liquidity. Other platforms may choose a strategy
of paying lower rebates (or no rebates) to attract orders, setting
relatively high prices for market information, and setting relatively
low prices for accessing posted liquidity. In this environment, there
is no economic basis for regulating maximum prices for one of the joint
products in an industry in which suppliers face competitive constraints
with regard to the joint offering. This would be akin to strictly
regulating the price that an automobile manufacturer can charge for car
sound systems despite the existence of a highly competitive market for
cars and the availability of aftermarket alternatives to the
manufacturer-supplied system.
The market for market data products is competitive and inherently
contestable because there is fierce competition for the inputs
necessary to the creation of proprietary data and strict pricing
discipline for the proprietary products themselves. Numerous exchanges
compete with each other for listings, trades, and market data itself,
providing virtually limitless opportunities for entrepreneurs who wish
to produce and distribute their own market data. This proprietary data
is produced by each individual exchange, as well as other entities, in
a vigorously competitive market. Broker-dealers currently have numerous
alternative venues for their order flow, including ten self-regulatory
organization (``SRO'') markets, as well as internalizing broker-dealers
(``BDs'') and various forms of alternative trading systems (``ATSs''),
including dark pools and electronic communication networks (``ECNs'').
Each SRO market competes to produce transaction reports via trade
executions, and two FINRA regulated Trade Reporting Facilities
(``TRFs'') compete to attract internalized transaction reports.
Competitive markets for order flow, executions, and transaction reports
provide pricing discipline for the inputs of proprietary data products.
For example, the Exchange notes that at least one other U.S. options
exchange offers a market data product that is substantially similar to
the PHOTO Historical Data product, which the PHLX must consider in its
pricing discipline in order to compete for listings, trades, and the
market data itself.\17\
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\17\ The International Securities Exchange, Inc. (``ISE'') Open/
Close Trade Profile and the ISE Open/Close Trade Profile Intra-Day
contain substantially similar data to that included in PHOTO End of
Day and PHOTO Intra-Day. See Securities Exchange Act Release No.
56254 (August 15, 2007), 72 FR 47104 (August 22, 2007) (SR-ISE-2007-
70). ISE currently sells the ISE Open/Close Trade Profile with
historical data available back to May 2005, and sells the ISE Open/
Close Trade Profile Intraday with historical data available
separately back to October 2009. See Securities Exchange act Release
No. 61317 (January 8, 2010), 75 FR 2915 (January 19, 2010) (SR-ISE-
2009-103).
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The large number of SROs, TRFs, BDs, and ATSs that currently
produce proprietary data or are currently capable of producing it
provides further pricing discipline for proprietary data products. Each
SRO, TRF, ATS, and BD is currently permitted to produce proprietary
data products, and many currently do or have announced plans to do so,
including PHLX, NASDAQ, NYSE, NYSE Amex, NYSEArca, and BATS.
Any ATS or BD can combine with any other ATS, BD, or multiple ATSs
or BDs to produce joint proprietary data products. Additionally, order
routers and market data vendors can facilitate single or multiple
broker-dealers' production of proprietary data products. The potential
sources of proprietary products are virtually limitless.
The fact that proprietary data from ATSs, BDs, and vendors can by-
pass SROs is significant in two respects. First, non-SROs can compete
directly with SROs for the production and sale of proprietary data
products, as BATS and Arca did before registering as exchanges by
publishing proprietary book data on the Internet. Second, because a
single order or transaction report can appear in an SRO proprietary
product, a non-SRO proprietary product, or both, the data available in
proprietary products is exponentially greater than the actual number of
orders and transaction reports that exist in the marketplace.
Market data vendors provide another form of price discipline for
proprietary data products because they control the primary means of
access to end users. Vendors impose price restraints based upon their
business models. For example, vendors such as Bloomberg and Reuters
that assess a surcharge on data they sell may refuse to offer
proprietary products that end users will not purchase in sufficient
numbers. Internet portals, such as Yahoo, impose a discipline by
providing only data that will enable them to attract ``eyeballs'' that
contribute to their advertising revenue. Retail broker-dealers, such as
Schwab and Fidelity, offer their customers proprietary data only if it
promotes trading and generates sufficient commission revenue. Although
the business models may differ, these vendors' pricing discipline is
the same: They can simply refuse to purchase any proprietary data
product that fails to provide sufficient value. PHLX and other
producers of proprietary data products must understand and respond to
these varying business models and pricing disciplines in order to
market proprietary data products successfully.
In addition to the competition and price discipline described
above, the market for proprietary data products is also highly
contestable because market entry is rapid, inexpensive, and profitable.
The history of electronic trading is replete with examples of entrants
that swiftly grew into some of the largest electronic trading platforms
and proprietary data producers: Archipelago, Bloomberg Tradebook,
Island, RediBook, Attain, TracECN, BATS Trading and Direct Edge. A
proliferation of dark pools and other ATSs operate profitably with
fragmentary shares of consolidated market volume.
Regulation NMS, by deregulating the market for proprietary data,
has increased the contestability of that market. While broker-dealers
have previously published their proprietary data individually,
Regulation NMS encourages market data vendors and broker-dealers to
produce proprietary products cooperatively in a manner never before
possible. Multiple market data vendors already have the capability to
aggregate data and disseminate it on a profitable scale, including
Bloomberg, and Thomson-Reuters.
The court in NetCoalition concluded that the Commission had failed
to demonstrate that the market for market data was competitive based on
the reasoning of the Commission's NetCoalition order because, in the
court's view, the Commission had not adequately demonstrated that the
depth-of-book data at issue in the case is used to attract order flow.
PHLX believes, however, that evidence not before the
[[Page 73144]]
court clearly demonstrates that availability of depth data attracts
order flow.
Competition among platforms has driven PHLX continually to improve
its platform data offerings and to cater to customers' data needs. For
example, PHLX offers front end applications such as its Top of PHLX
Options (``TOPO'') and TOPO Plus Orders data products to help customers
utilize data.
For the foregoing reasons, PHLX does not believe that the proposed
rule change will result in any burden on competition that is not
necessary or appropriate in furtherance of the purpose of the Act.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
No written comments were either solicited or received.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become effective pursuant to Section
19(b)(3)(A)(ii) of the Act.\18\ At any time within 60 days of the
filing of the proposed rule change, the Commission summarily may
temporarily suspend such rule change if it appears to the Commission
that such action is necessary or appropriate in the public interest,
for the protection of investors, or otherwise in furtherance of the
purposes of the Act. If the Commission takes such action, the
Commission shall institute proceedings to determine whether the
proposed rule should be approved or disapproved.
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\18\ 15 U.S.C. 78s(b)(3)(A)(ii).
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IV. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an e-mail to rule-comments@sec.gov. Please include
File Number SR-Phlx-2010-154 on the subject line.
Paper Comments
Send paper comments in triplicate to Elizabeth M. Murphy,
Secretary, Securities and Exchange Commission, 100 F Street, NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number SR-Phlx-2010-154. This file
number should be included on the subject line if e-mail is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for Web site viewing and
printing in the Commission's Public Reference Room, on official
business days between the hours of 10 a.m. and 3 p.m. Copies of the
filing also will be available for inspection and copying at the
principal office of the Exchange. All comments received will be posted
without change; the Commission does not edit personal identifying
information from submissions. You should submit only information that
you wish to make available publicly. All submissions should refer to
File Number SR-Phlx-2010-154 and should be submitted on or before
December 20, 2010.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\19\
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\19\ 17 CFR 200.30-3(a)(12).
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Elizabeth M. Murphy,
Secretary.
[FR Doc. 2010-29892 Filed 11-26-10; 8:45 am]
BILLING CODE 8011-01-P