Self-Regulatory Organizations; International Securities Exchange, Inc. (n/k/a the International Securities Exchange, LLC); Order Approving a Proposed Rule Change To Amend Exchange Rule Governing Directed Orders, 17466-17468 [2011-7285]
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17466
Federal Register / Vol. 76, No. 60 / Tuesday, March 29, 2011 / Notices
Comments may be submitted by any of
the following methods:
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an e-mail to rulecomments@sec.gov. Please include File
Number SR–CBOE–2011–024 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.
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–64115; File No. SR–ISE–
2006–01]
Self-Regulatory Organizations;
International Securities Exchange, Inc.
(n/k/a the International Securities
Exchange, LLC); Order Approving a
Proposed Rule Change To Amend
Exchange Rule Governing Directed
Orders
March 23, 2011.
I. Introduction
jlentini on DSKJ8SOYB1PROD with NOTICES
On January 5, 2006, the International
Securities Exchange, Inc. (n/k/a the
International Securities Exchange, LLC)
All submissions should refer to File
(‘‘ISE’’ or ‘‘Exchange’’) filed with the
Number SR–CBOE–2011–024. This file
Securities and Exchange Commission
number should be included on the
(‘‘Commission’’), pursuant to Section
subject line if e-mail is used. To help the 19(b)(1) of the Securities Exchange Act
Commission process and review your
of 1934 (‘‘Act’’) 1 and Rule 19b–4
comments more efficiently, please use
thereunder,2 a proposal to amend ISE
only one method. The Commission will Rule 811 to allow the identity of a firm
post all comments on the Commission’s entering a Directed Order to be
Internet Web site (https://www.sec.gov/
disclosed to a Directed Market Maker
rules/sro.shtml). Copies of the
(‘‘DMM’’). The proposed rule change was
submission, all subsequent
published for comment in the Federal
amendments, all written statements
Register on January 19, 2006.3 The
with respect to the proposed rule
Commission received comment letters
change that are filed with the
from the Interactive Brokers Group
Commission, and all written
supporting the proposal, and from
communications relating to the
Citadel opposing the proposal.4 This
proposed rule change between the
order approves the proposed rule
Commission and any person, other than change.
those that may be withheld from the
II. Description of the Proposal
public in accordance with the
The Exchange currently operates a
provisions of 5 U.S.C. 552, will be
Directed Order system in which
available for Web site viewing and
Electronic Access Members (‘‘EAMs’’)
printing in the Commission’s Public
can send an order to a DMM for possible
Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official
1 15 U.S.C. 78s(b)(1).
business days between the hours of 10
2 17 CFR 240.19b–4.
a.m. and 3 p.m. Copies of such filing
3 See Securities Exchange Act Release No. 53103
also will be available for inspection and
(January 11, 2006), 71 FR 3144.
copying at the principal office of the
4 See letters to Nancy M. Morris, Secretary,
Exchange. All comments received will
Commission, from Thomas Peterffy, Chairman, and
be posted without change; the
David M. Battan, Vice President, Interactive Brokers
Group, dated February 10, 2006 (‘‘IB Letter’’) and
Commission does not edit personal
Adam C. Cooper, Senior Managing Director &
identifying information from
General Counsel, Citadel, dated February 27, 2006
submissions. You should submit only
(‘‘Citadel Letter’’), incorporating by reference a letter
information that you wish to make
from Adam C. Cooper, Senior Managing Director &
General Counsel, Citadel, dated January 11, 2006
available publicly. All submissions
(‘‘Citadel Letter II’’).
should refer to File No. SR–CBOE–
In reviewing this proposed rule change, the
2011–024 and should be submitted on
Commission also considered a comment letter by
or before April 19, 2011.
the American Stock Exchange in response to a
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.21
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011–7264 Filed 3–28–11; 8:45 am]
BILLING CODE 8011–01–P
21 17
CFR 200.30–3(a)(12).
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proposed rule change submitted by the ISE to
amend ISE Rule 811 to allow the identity of a firm
entering a Directed Order to be disclosed to a DMM
on a temporary basis, which became immediately
effective upon filing with the Commission. See
Securities Exchange Act Release No. 53104 (January
11, 2006), 71 FR 3142 January 19, 2006 (SR–ISE–
2006–02). See also letter to Nancy M. Morris,
Secretary, Commission, from Neal L. Wolkoff,
Chairman & Chief Executive Officer, American
Stock Exchange, dated February 3, 2006 (‘‘Amex
Letter’’) and February 7, 2006 (‘‘Amex Letter II’’).
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price improvement.5 If a DMM accepts
Directed Orders generally, that DMM
must accept all Directed Orders from all
EAMs. Once such a DMM receives a
Directed Order, it either (i) must enter
the order into the Exchange’s Price
Improvement Mechanism (‘‘PIM’’)
auction and guarantee its execution at a
price better than the ISE best bid or offer
(‘‘ISE BBO’’) by at least a penny and
equal to or better than the National Best
Bid and Offer (‘‘NBBO’’) 6 or (ii) must
release the order into the Exchange’s
limit order book, in which case there are
certain restrictions on the DMM
interacting with the order.
On January 5, 2006, ISE filed a
proposed rule change, which became
immediately effective upon filing with
the Commission, to alter its existing
Directed Order system on a temporary
basis so that the system would disclose
the identity of the firm entering a
Directed Order to a DMM.7 The rule
permitting the ISE system to identify to
DMMs the firm from which a Directed
Order originates continues to operate on
a pilot basis through May 31, 2011.8 ISE
proposes in this filing to amend ISE
Rule 811 to permit the identity of an
EAM that enters a Directed Order to be
made available to the DMM and thus to
make permanent its rule change that has
been operating on a pilot basis for the
past five years.
III. Discussion
After careful review of the proposal
and of the comment letters, the
Commission finds that the proposed
rule change is consistent with the
requirements of the Act and the rules
and regulations thereunder applicable to
a national securities exchange 9 and, in
5 See Securities Exchange Act Release No. 52331
(August 24, 2005), 70 FR 51856 (August 31, 2005)
(SR–ISE–2004–16).
6 See ISE Rule 723.
7 See Securities Exchange Act Release No. 53104
(January 11, 2006), 71 FR 3142 (January 19, 2006)
(rule change was effective until June 30, 2006). The
Commission received three comment letters
regarding the temporary system change. See IB
Letter, Amex Letter, and Amex Letter II, supra note
4.
8 See Securities Exchange Act Release Nos. 53104
(January 11, 2006), 71 FR 3142 January 19, 2006
(SR–ISE–2006–02); 54083 (June 30, 2006), 71 FR
38920 (July 10, 2006) (SR–ISE–2006–35); 54542
(September 29, 2006), 71 FR 59170 (October 6,
2006) (SR–ISE–2006–57); 55144 (January 22, 2007),
72 FR 3890 (January 26, 2007) (SR–ISE–2007–05);
56155 (July 27, 2007), 72 FR 43306 (August 3, 2007)
(SR–ISE–2007–67); 59176 (January 24, 2008), 73 FR
5615 (January 30, 2008) (SR–ISE–2008–08); 59276
(January 22, 2009), 74 FR 5007 (January 28, 2009)
(SR–ISE–2009–02); 59943 (May 20, 2009), 74 FR
25296 (May 27, 2009) (SR–ISE–2009–28); 60956
(November 6, 2009), 74 FR 58674 (November 13,
2009) (SR–ISE–2009–93); and 63357 (November 22,
2010), 75 FR 73144 (November 29, 2010) (SR–ISE–
2010–110).
9 Citadel argues that this proposal facilitates anticompetitive behavior and therefore violates Section
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particular, the requirements of Section 6
of the Act.10 Specifically, as discussed
below, the Commission finds that the
proposed rule change is consistent with
Section 6(b)(5) of the Act,11 which
requires, among other things, that the
rules of a national securities exchange
be designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, to foster cooperation and
coordination with persons engaged in
regulating, clearing, settling, and
processing information with respect to,
and facilitating transactions in
securities, to remove impediments to
and perfect the mechanism of a free and
open market and a national market
system, and, in general, to protect
investors and the public interest and are
not designed to permit unfair
discrimination among customers,
issuers, brokers, or dealers.
jlentini on DSKJ8SOYB1PROD with NOTICES
A. Proposal is Not Unfairly
Discriminatory
Under the proposal, the ISE system
would provide the identity of an EAM
that enters a Directed Order to the DMM
to whom the order is directed. Citadel
argues that the lack of anonymity of
Directed Orders allows the DMM
receiving such orders to discriminate in
its determination regarding for which
orders the DMM would provide an
opportunity for price improvement
through the ISE’s PIM auction.12 The
principal criticism of ISE’s proposal is
that it is inconsistent with the
requirement in Section 6(b)(5) of the Act
that the rules of an exchange not be
‘‘designed to permit unfair
discrimination between customers,
issuers, brokers, or dealers.’’ 13 Section
6(b)(5) of the Act prohibits an exchange
from establishing rules that treat these
market participants in an unfairly
discriminatory manner. Section 6(b)(5)
of the Act does not prohibit exchange
members or other broker-dealers from
discriminating, so long as their activities
are otherwise consistent with the
Federal securities laws. Nor does
Section 6(b)(5) of the Act require
3(f) of the Act. See Citadel Letter II, supra note 4,
at 6. Section 3(f) of the Act requires the Commission
to consider or determine whether this proposed rule
change is necessary or appropriate in the public
interest and, in addition to the protection of
investors, will promote efficiency, competition, and
capital formation. In approving this proposed rule
change, the Commission has considered the
proposed rule’s impact on efficiency, competition,
and capital formation. As discussed below, the
Commission does not believe the proposal is anticompetitive. 15 U.S.C. 78c(f).
10 15 U.S.C. 78f.
11 15 U.S.C. 78f(b)(5).
12 See Citadel Letter II, supra note 4, at 4–5.
13 15 U.S.C. 78f(b)(5). See Citadel Letter II, supra
note 4, at 5; and Amex Letter, supra note 4, at 2.
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exchanges to preclude discrimination by
broker-dealers. Broker-dealers
commonly differentiate between
customers based on the nature and
profitability of their business.
Currently under ISE’s rules, an EAM
may provide an opportunity for price
improvement to a customer order by
submitting it to the PIM. An EAM may
decide who to accept as its customers
and further choose to provide an
opportunity for price improvement to
some customer orders, but not others, by
exercising discretion as to whether it
chooses to send a particular order to the
PIM auction.14 An EAM would know
the identity of its customer in deciding
whether to provide this opportunity for
price improvement. A DMM may also
provide an opportunity for price
improvement to Directed Orders by
submitting them to the PIM. The
proposed rule change would enable a
DMM to consider the identity of the
EAM directing the order when deciding
whether to provide an opportunity for
price improvement.15 Thus, the
proposal will provide information to
DMMs that is the same information
available to other ISE members when
they decide whether to provide price
improvement to a particular order.
While customer anonymity may be
valuable in ensuring that broker-dealers
comply with legal obligations in a
variety of circumstances, such as market
makers’ firm quote obligations,
customer anonymity is not required of
exchanges, particularly when disclosure
of customer identity could provide
benefits to certain customers beyond
those required by the Federal securities
laws or exchange rules. In particular,
market makers may be willing to offer
better execution prices to certain
customers’ orders (e.g., retail customers’
orders). The Commission does not
believe that it would be inconsistent
with the Federal securities laws for the
Exchange to provide, under the
circumstances set forth in this proposal,
the means for DMMs to differentiate
between customers in providing price
improvement or other non-required
advantages to certain customers. The
14 See also Chapter V, Section 18 of the Boston
Options Exchange Rules (Price Improvement
Period) and Rule 6.74A of the Chicago Board
Options Exchange, Incorporated (Automated
Improvement Mechanism).
15 Specialists and other market makers may
establish payment for order flow relationships with
firms on a discretionary basis. A specialist or
market maker may pay varying amounts for order
flow received from different firms or different
customers within firms. Unlike payment for order
flow, which principally benefits intermediaries and,
indirectly, their customers through possibly lower
fees and better services, customers’ orders executed
through the PIM auction directly benefit customers
with the opportunity for an improved price.
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17467
Exchange’s proposal treats all DMMs the
same and establishes no requirements
for which orders a DMM chooses to
provide an opportunity for price
improvement. The Commission does not
believe that the absence of Exchange
rules specifying which orders a DMM
may execute at prices better that its
public quote is unfairly discriminatory.
Accordingly, while the proposal
would permit a DMM to discriminate
among customers in providing prices
better than its quote, the Commission
does not believe that this discrimination
is inconsistent with Section 6(b)(5) of
the Act.
B. Impact of Proposal on Market Quality
and Competition
Citadel argues that the proposal
would discourage aggressive quoting
and would be detrimental to price
improvement.16 The Commission has
considered this comment and does not
believe that the rule change proposed by
ISE would discourage DMMs from
quoting aggressively. The Commission
believes that a DMM has an incentive to
quote aggressively to gain priority with
respect to orders entered on the limit
order book. Further, the Commission
believes that the commenter’s argument
that the proposal will harm market
quality rests on a number of premises
that are unlikely to occur. The
commenter assumes that ISE’s proposal
will lead to less aggressive quoting
across all options exchanges and a
widening of the NBBO. The
Commission does not believe that this
will occur because there is rigorous
competition for order flow across
options exchanges so any widening of
quotes on one market is an opportunity
for another option market to capture
order flow.17 In fact, the Options Order
Protection and Locked/Crossed Market
Plan provides protection from one
exchange ignoring better quoted prices
on another market and will continue to
promote quote competition across
options exchanges.18
In addition, allowing a DMM to know
the identity of firms sending Directed
Orders may provide further incentive to
that DMM to provide price
improvement. A DMM that receives a
Directed Order would be required to
decide whether to send the order to the
16 See
Citadel Letter II, supra note 4, at 8–9.
Robert Battalio, ‘‘Third Market BrokerDealers: Cost Competitors or Cream Skimmers?’’
Journal of Finance, 1997; and Robert Battalio,
Robert Jason Greene, and Robert Jennings, ‘‘How Do
Competing Specialists and Preferencing Dealers
Affect Market Quality?’’ Review of Financial
Studies, 1997.
18 See Securities Exchange Act Release No. 60405
(July 30, 2009), 74 FR 39362 (August 6, 2009).
17 See
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Federal Register / Vol. 76, No. 60 / Tuesday, March 29, 2011 / Notices
PIM and guarantee a price better than
the ISE BBO and equal to or better than
the NBBO to such order, or to release
the order to the book. The DMM’s
decision about whether to choose to
guarantee a particular order at a price
better than the ISE BBO and equal to or
better than the NBBO may be affected by
this proposal because it provides DMMs
with information to differentiate
between orders from informed traders
(i.e., their competitors) and orders from
uninformed traders. It is well known in
academic literature and industry
practice that prices tend to move against
market makers after trades with
informed traders, often resulting in
losses for market makers.19 Thus, there
is a strong economic rationale for
market makers not providing informed
traders price improvement. Uninformed
investors end up bearing the cost of
these market maker losses through
wider spreads that market makers need
to quote to uninformed investors due to
informed order flow.20
Citadel also argues that the
Commission has previously sought to
eliminate similar anti-competitive
practices allowed by self-regulatory
organizations (‘‘SROs’’) involving lack of
order anonymity.21 In particular, Citadel
cites a 1996 investigation of NASD and
Nasdaq Stock Market in which ‘‘[s]ome
market makers, without disclosure to
their customers, shared information
with each other about their customers’
orders, including the size of the order
and, on occasion, the identity of the
customer.’’ 22 Citadel asserts that the
‘‘Commission concluded that this anticompetitive behavior violated the
antifraud provisions of the Exchange
Act, among other provisions.’’ 23
The Commission does not believe that
the proposal will result in market maker
conduct like that in the NASD case,
which found that market makers were
collaborating with other market
participants against the interests of their
customers contrary to the fair dealing
obligations of market makers.24 Unlike
the NASD case, the interests of the
DMM’s customers are not harmed by
this proposal because information
pertaining to a DMM’s Directed Orders
is not shared among competing DMMs
and all orders sent to ISE must be
executed at a price no worse than the
NBBO.25
Finally, Amex contends that the
proposal is anti-competitive because
providing the identity of an EAM to
DMMs provides them with the ability to
enter into anti-competitive customer
allocation arrangements.26 Amex argues
that if ISE Market Makers know the
identities of order flow providers, they
could agree to allocate those order flow
providers among themselves and
provide price improvement to only
those that each has been allocated.27
There is, however, no evidence that
customer allocation arrangements exist
between Market Makers. The
Commission is today approving only the
proposed rule change, which permits a
DMM to determine from which EAM it
will accept Directed Orders. The
Commission is not approving any
customer allocation arrangements
among Market Makers.
For the foregoing reasons, the
Commission finds that the proposed
rule change is consistent with the Act
and the rules and regulations
thereunder applicable to a national
securities exchange, and, in particular
with Section 6(b)(5) of the Act.28
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,29 that the
proposed rule change (SR–ISE–2006–01)
is approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.30
Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011–7285 Filed 3–28–11; 8:45 am]
jlentini on DSKJ8SOYB1PROD with NOTICES
19 See
Stoll, H. R., ‘‘The supply of dealer services
in securities of markets,’’ Journal of Finance 33
(1978), at 1133–51; Glosten, L. and P. Milgrom, ‘‘Bid
ask and transaction prices in a specialist market
with heterogeneously informed agents,’’ Journal of
Financial Economics 14 (1985), at 71–100; and
Copeland, T., and D. Galai, ‘‘Information effects on
the bid-ask spread,’’ Journal of Finance 38 (1983),
at 1457–69.
20 Id.
21 See Citadel Letter II, supra note 4, at 6.
22 See Securities Exchange Act Release No. 37542
(August 8, 1996) (File No. 3–8919) (Report Pursuant
to Section 21(a) of the Securities Exchange Act of
1934 Regarding the NASD and the Nasdaq Market),
at 5.
23 See Citadel Letter II, supra note 4, at 6.
24 See Securities Exchange Act Release No. 37542,
supra note 22, at 59.
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BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–64113; File No. SR–Phlx–
2011–36]
Self-Regulatory Organizations; Notice
of Filing and Immediate Effectiveness
of Proposed Rule Change by NASDAQ
OMX PHLX LLC Relating to the Equity
Options Monthly Cap
March 23, 2011.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that on March 17,
2011, NASDAQ OMX PHLX LLC (‘‘Phlx’’
or ‘‘Exchange’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘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.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend the
Exchange’s Fee Schedule to lower the
monthly cap applicable to Registered
Options Traders (‘‘ROTs’’) 3 and
Specialists 4 for equity options
transactions. The Exchange also
proposes to assess a $0.05 per contract
fee on ROTs and Specialists in certain
circumstances when they have reached
the monthly cap.
While changes to the Fee Schedule
pursuant to this proposal are effective
upon filing, the Exchange has
designated these changes to be operative
on April 1, 2011.
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.
1 15
U.S.C. 78s(b)(1).
CFR 240.19b–4.
3 A Registered Options Trader (‘‘ROT’’) includes a
Streaming Quote Trader (‘‘SQT’’), a Remote
Streaming Quote Trader (‘‘RSQT’’) and a Non-SQT
ROT, which by definition is neither a SQT or a
RSQT. A ROT is defined in Exchange Rule 1014(b)
as a regular member or a foreign currency options
participant of the Exchange located on the trading
floor who has received permission from the
Exchange to trade in options for his own account.
See Exchange Rule 1014(b)(i) and (ii).
4 A Specialist is an Exchange member who is
registered as an options specialist pursuant to Rule
1020(a).
2 17
25 See
26 See
ISE Rule 811(e).
Amex Letter, supra note 4, at 2.
27 Id.
28 15
U.S.C. 78f(b)(5).
U.S.C. 78s(b)(2).
30 17 CFR 200.30–3(a)(12).
29 15
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Agencies
[Federal Register Volume 76, Number 60 (Tuesday, March 29, 2011)]
[Notices]
[Pages 17466-17468]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-7285]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-64115; File No. SR-ISE-2006-01]
Self-Regulatory Organizations; International Securities Exchange,
Inc. (n/k/a the International Securities Exchange, LLC); Order
Approving a Proposed Rule Change To Amend Exchange Rule Governing
Directed Orders
March 23, 2011.
I. Introduction
On January 5, 2006, the International Securities Exchange, Inc. (n/
k/a the International Securities Exchange, LLC) (``ISE'' or
``Exchange'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4 thereunder,\2\ a
proposal to amend ISE Rule 811 to allow the identity of a firm entering
a Directed Order to be disclosed to a Directed Market Maker (``DMM'').
The proposed rule change was published for comment in the Federal
Register on January 19, 2006.\3\ The Commission received comment
letters from the Interactive Brokers Group supporting the proposal, and
from Citadel opposing the proposal.\4\ This order approves the proposed
rule change.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 53103 (January 11,
2006), 71 FR 3144.
\4\ See letters to Nancy M. Morris, Secretary, Commission, from
Thomas Peterffy, Chairman, and David M. Battan, Vice President,
Interactive Brokers Group, dated February 10, 2006 (``IB Letter'')
and Adam C. Cooper, Senior Managing Director & General Counsel,
Citadel, dated February 27, 2006 (``Citadel Letter''), incorporating
by reference a letter from Adam C. Cooper, Senior Managing Director
& General Counsel, Citadel, dated January 11, 2006 (``Citadel Letter
II'').
In reviewing this proposed rule change, the Commission also
considered a comment letter by the American Stock Exchange in
response to a proposed rule change submitted by the ISE to amend ISE
Rule 811 to allow the identity of a firm entering a Directed Order
to be disclosed to a DMM on a temporary basis, which became
immediately effective upon filing with the Commission. See
Securities Exchange Act Release No. 53104 (January 11, 2006), 71 FR
3142 January 19, 2006 (SR-ISE-2006-02). See also letter to Nancy M.
Morris, Secretary, Commission, from Neal L. Wolkoff, Chairman &
Chief Executive Officer, American Stock Exchange, dated February 3,
2006 (``Amex Letter'') and February 7, 2006 (``Amex Letter II'').
---------------------------------------------------------------------------
II. Description of the Proposal
The Exchange currently operates a Directed Order system in which
Electronic Access Members (``EAMs'') can send an order to a DMM for
possible price improvement.\5\ If a DMM accepts Directed Orders
generally, that DMM must accept all Directed Orders from all EAMs. Once
such a DMM receives a Directed Order, it either (i) must enter the
order into the Exchange's Price Improvement Mechanism (``PIM'') auction
and guarantee its execution at a price better than the ISE best bid or
offer (``ISE BBO'') by at least a penny and equal to or better than the
National Best Bid and Offer (``NBBO'') \6\ or (ii) must release the
order into the Exchange's limit order book, in which case there are
certain restrictions on the DMM interacting with the order.
---------------------------------------------------------------------------
\5\ See Securities Exchange Act Release No. 52331 (August 24,
2005), 70 FR 51856 (August 31, 2005) (SR-ISE-2004-16).
\6\ See ISE Rule 723.
---------------------------------------------------------------------------
On January 5, 2006, ISE filed a proposed rule change, which became
immediately effective upon filing with the Commission, to alter its
existing Directed Order system on a temporary basis so that the system
would disclose the identity of the firm entering a Directed Order to a
DMM.\7\ The rule permitting the ISE system to identify to DMMs the firm
from which a Directed Order originates continues to operate on a pilot
basis through May 31, 2011.\8\ ISE proposes in this filing to amend ISE
Rule 811 to permit the identity of an EAM that enters a Directed Order
to be made available to the DMM and thus to make permanent its rule
change that has been operating on a pilot basis for the past five
years.
---------------------------------------------------------------------------
\7\ See Securities Exchange Act Release No. 53104 (January 11,
2006), 71 FR 3142 (January 19, 2006) (rule change was effective
until June 30, 2006). The Commission received three comment letters
regarding the temporary system change. See IB Letter, Amex Letter,
and Amex Letter II, supra note 4.
\8\ See Securities Exchange Act Release Nos. 53104 (January 11,
2006), 71 FR 3142 January 19, 2006 (SR-ISE-2006-02); 54083 (June 30,
2006), 71 FR 38920 (July 10, 2006) (SR-ISE-2006-35); 54542
(September 29, 2006), 71 FR 59170 (October 6, 2006) (SR-ISE-2006-
57); 55144 (January 22, 2007), 72 FR 3890 (January 26, 2007) (SR-
ISE-2007-05); 56155 (July 27, 2007), 72 FR 43306 (August 3, 2007)
(SR-ISE-2007-67); 59176 (January 24, 2008), 73 FR 5615 (January 30,
2008) (SR-ISE-2008-08); 59276 (January 22, 2009), 74 FR 5007
(January 28, 2009) (SR-ISE-2009-02); 59943 (May 20, 2009), 74 FR
25296 (May 27, 2009) (SR-ISE-2009-28); 60956 (November 6, 2009), 74
FR 58674 (November 13, 2009) (SR-ISE-2009-93); and 63357 (November
22, 2010), 75 FR 73144 (November 29, 2010) (SR-ISE-2010-110).
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III. Discussion
After careful review of the proposal and of the comment letters,
the Commission finds that the proposed rule change is consistent with
the requirements of the Act and the rules and regulations thereunder
applicable to a national securities exchange \9\ and, in
[[Page 17467]]
particular, the requirements of Section 6 of the Act.\10\ Specifically,
as discussed below, the Commission finds that the proposed rule change
is consistent with Section 6(b)(5) of the Act,\11\ which requires,
among other things, that the rules of a national securities exchange be
designed to prevent fraudulent and manipulative acts and practices, to
promote just and equitable principles of trade, to foster cooperation
and coordination with persons engaged in regulating, clearing,
settling, and processing information with respect to, and facilitating
transactions in securities, to remove impediments to and perfect the
mechanism of a free and open market and a national market system, and,
in general, to protect investors and the public interest and are not
designed to permit unfair discrimination among customers, issuers,
brokers, or dealers.
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\9\ Citadel argues that this proposal facilitates anti-
competitive behavior and therefore violates Section 3(f) of the Act.
See Citadel Letter II, supra note 4, at 6. Section 3(f) of the Act
requires the Commission to consider or determine whether this
proposed rule change is necessary or appropriate in the public
interest and, in addition to the protection of investors, will
promote efficiency, competition, and capital formation. In approving
this proposed rule change, the Commission has considered the
proposed rule's impact on efficiency, competition, and capital
formation. As discussed below, the Commission does not believe the
proposal is anti-competitive. 15 U.S.C. 78c(f).
\10\ 15 U.S.C. 78f.
\11\ 15 U.S.C. 78f(b)(5).
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A. Proposal is Not Unfairly Discriminatory
Under the proposal, the ISE system would provide the identity of an
EAM that enters a Directed Order to the DMM to whom the order is
directed. Citadel argues that the lack of anonymity of Directed Orders
allows the DMM receiving such orders to discriminate in its
determination regarding for which orders the DMM would provide an
opportunity for price improvement through the ISE's PIM auction.\12\
The principal criticism of ISE's proposal is that it is inconsistent
with the requirement in Section 6(b)(5) of the Act that the rules of an
exchange not be ``designed to permit unfair discrimination between
customers, issuers, brokers, or dealers.'' \13\ Section 6(b)(5) of the
Act prohibits an exchange from establishing rules that treat these
market participants in an unfairly discriminatory manner. Section
6(b)(5) of the Act does not prohibit exchange members or other broker-
dealers from discriminating, so long as their activities are otherwise
consistent with the Federal securities laws. Nor does Section 6(b)(5)
of the Act require exchanges to preclude discrimination by broker-
dealers. Broker-dealers commonly differentiate between customers based
on the nature and profitability of their business.
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\12\ See Citadel Letter II, supra note 4, at 4-5.
\13\ 15 U.S.C. 78f(b)(5). See Citadel Letter II, supra note 4,
at 5; and Amex Letter, supra note 4, at 2.
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Currently under ISE's rules, an EAM may provide an opportunity for
price improvement to a customer order by submitting it to the PIM. An
EAM may decide who to accept as its customers and further choose to
provide an opportunity for price improvement to some customer orders,
but not others, by exercising discretion as to whether it chooses to
send a particular order to the PIM auction.\14\ An EAM would know the
identity of its customer in deciding whether to provide this
opportunity for price improvement. A DMM may also provide an
opportunity for price improvement to Directed Orders by submitting them
to the PIM. The proposed rule change would enable a DMM to consider the
identity of the EAM directing the order when deciding whether to
provide an opportunity for price improvement.\15\ Thus, the proposal
will provide information to DMMs that is the same information available
to other ISE members when they decide whether to provide price
improvement to a particular order.
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\14\ See also Chapter V, Section 18 of the Boston Options
Exchange Rules (Price Improvement Period) and Rule 6.74A of the
Chicago Board Options Exchange, Incorporated (Automated Improvement
Mechanism).
\15\ Specialists and other market makers may establish payment
for order flow relationships with firms on a discretionary basis. A
specialist or market maker may pay varying amounts for order flow
received from different firms or different customers within firms.
Unlike payment for order flow, which principally benefits
intermediaries and, indirectly, their customers through possibly
lower fees and better services, customers' orders executed through
the PIM auction directly benefit customers with the opportunity for
an improved price.
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While customer anonymity may be valuable in ensuring that broker-
dealers comply with legal obligations in a variety of circumstances,
such as market makers' firm quote obligations, customer anonymity is
not required of exchanges, particularly when disclosure of customer
identity could provide benefits to certain customers beyond those
required by the Federal securities laws or exchange rules. In
particular, market makers may be willing to offer better execution
prices to certain customers' orders (e.g., retail customers' orders).
The Commission does not believe that it would be inconsistent with the
Federal securities laws for the Exchange to provide, under the
circumstances set forth in this proposal, the means for DMMs to
differentiate between customers in providing price improvement or other
non-required advantages to certain customers. The Exchange's proposal
treats all DMMs the same and establishes no requirements for which
orders a DMM chooses to provide an opportunity for price improvement.
The Commission does not believe that the absence of Exchange rules
specifying which orders a DMM may execute at prices better that its
public quote is unfairly discriminatory.
Accordingly, while the proposal would permit a DMM to discriminate
among customers in providing prices better than its quote, the
Commission does not believe that this discrimination is inconsistent
with Section 6(b)(5) of the Act.
B. Impact of Proposal on Market Quality and Competition
Citadel argues that the proposal would discourage aggressive
quoting and would be detrimental to price improvement.\16\ The
Commission has considered this comment and does not believe that the
rule change proposed by ISE would discourage DMMs from quoting
aggressively. The Commission believes that a DMM has an incentive to
quote aggressively to gain priority with respect to orders entered on
the limit order book. Further, the Commission believes that the
commenter's argument that the proposal will harm market quality rests
on a number of premises that are unlikely to occur. The commenter
assumes that ISE's proposal will lead to less aggressive quoting across
all options exchanges and a widening of the NBBO. The Commission does
not believe that this will occur because there is rigorous competition
for order flow across options exchanges so any widening of quotes on
one market is an opportunity for another option market to capture order
flow.\17\ In fact, the Options Order Protection and Locked/Crossed
Market Plan provides protection from one exchange ignoring better
quoted prices on another market and will continue to promote quote
competition across options exchanges.\18\
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\16\ See Citadel Letter II, supra note 4, at 8-9.
\17\ See Robert Battalio, ``Third Market Broker-Dealers: Cost
Competitors or Cream Skimmers?'' Journal of Finance, 1997; and
Robert Battalio, Robert Jason Greene, and Robert Jennings, ``How Do
Competing Specialists and Preferencing Dealers Affect Market
Quality?'' Review of Financial Studies, 1997.
\18\ See Securities Exchange Act Release No. 60405 (July 30,
2009), 74 FR 39362 (August 6, 2009).
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In addition, allowing a DMM to know the identity of firms sending
Directed Orders may provide further incentive to that DMM to provide
price improvement. A DMM that receives a Directed Order would be
required to decide whether to send the order to the
[[Page 17468]]
PIM and guarantee a price better than the ISE BBO and equal to or
better than the NBBO to such order, or to release the order to the
book. The DMM's decision about whether to choose to guarantee a
particular order at a price better than the ISE BBO and equal to or
better than the NBBO may be affected by this proposal because it
provides DMMs with information to differentiate between orders from
informed traders (i.e., their competitors) and orders from uninformed
traders. It is well known in academic literature and industry practice
that prices tend to move against market makers after trades with
informed traders, often resulting in losses for market makers.\19\
Thus, there is a strong economic rationale for market makers not
providing informed traders price improvement. Uninformed investors end
up bearing the cost of these market maker losses through wider spreads
that market makers need to quote to uninformed investors due to
informed order flow.\20\
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\19\ See Stoll, H. R., ``The supply of dealer services in
securities of markets,'' Journal of Finance 33 (1978), at 1133-51;
Glosten, L. and P. Milgrom, ``Bid ask and transaction prices in a
specialist market with heterogeneously informed agents,'' Journal of
Financial Economics 14 (1985), at 71-100; and Copeland, T., and D.
Galai, ``Information effects on the bid-ask spread,'' Journal of
Finance 38 (1983), at 1457-69.
\20\ Id.
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Citadel also argues that the Commission has previously sought to
eliminate similar anti-competitive practices allowed by self-regulatory
organizations (``SROs'') involving lack of order anonymity.\21\ In
particular, Citadel cites a 1996 investigation of NASD and Nasdaq Stock
Market in which ``[s]ome market makers, without disclosure to their
customers, shared information with each other about their customers'
orders, including the size of the order and, on occasion, the identity
of the customer.'' \22\ Citadel asserts that the ``Commission concluded
that this anti-competitive behavior violated the antifraud provisions
of the Exchange Act, among other provisions.'' \23\
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\21\ See Citadel Letter II, supra note 4, at 6.
\22\ See Securities Exchange Act Release No. 37542 (August 8,
1996) (File No. 3-8919) (Report Pursuant to Section 21(a) of the
Securities Exchange Act of 1934 Regarding the NASD and the Nasdaq
Market), at 5.
\23\ See Citadel Letter II, supra note 4, at 6.
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The Commission does not believe that the proposal will result in
market maker conduct like that in the NASD case, which found that
market makers were collaborating with other market participants against
the interests of their customers contrary to the fair dealing
obligations of market makers.\24\ Unlike the NASD case, the interests
of the DMM's customers are not harmed by this proposal because
information pertaining to a DMM's Directed Orders is not shared among
competing DMMs and all orders sent to ISE must be executed at a price
no worse than the NBBO.\25\
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\24\ See Securities Exchange Act Release No. 37542, supra note
22, at 59.
\25\ See ISE Rule 811(e).
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Finally, Amex contends that the proposal is anti-competitive
because providing the identity of an EAM to DMMs provides them with the
ability to enter into anti-competitive customer allocation
arrangements.\26\ Amex argues that if ISE Market Makers know the
identities of order flow providers, they could agree to allocate those
order flow providers among themselves and provide price improvement to
only those that each has been allocated.\27\ There is, however, no
evidence that customer allocation arrangements exist between Market
Makers. The Commission is today approving only the proposed rule
change, which permits a DMM to determine from which EAM it will accept
Directed Orders. The Commission is not approving any customer
allocation arrangements among Market Makers.
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\26\ See Amex Letter, supra note 4, at 2.
\27\ Id.
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For the foregoing reasons, the Commission finds that the proposed
rule change is consistent with the Act and the rules and regulations
thereunder applicable to a national securities exchange, and, in
particular with Section 6(b)(5) of the Act.\28\
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\28\ 15 U.S.C. 78f(b)(5).
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IV. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\29\ that the proposed rule change (SR-ISE-2006-01) is approved.
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\29\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\30\
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\30\ 17 CFR 200.30-3(a)(12).
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Cathy H. Ahn,
Deputy Secretary.
[FR Doc. 2011-7285 Filed 3-28-11; 8:45 am]
BILLING CODE 8011-01-P