Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Modify an Optional Depth Data Enterprise License Fee for Broker-Dealer Distribution of Depth-of-Book Data, 38871-38875 [2012-15956]
Download as PDF
Federal Register / Vol. 77, No. 126 / Friday, June 29, 2012 / Notices
Reference Room, 100 F Street, NE.,
Washington, DC 20549, on official
business days between the hours of 10
a.m. and 3 p.m. Copies of such filing
also will be available for inspection and
copying at the principal offices 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–ISE–
2012–56, and should be submitted on or
before July 20, 2012.
For the Commission, by the Division
of Trading and Markets, pursuant to
delegated authority.9
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–15939 Filed 6–28–12; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–67253; File No. SR–
NASDAQ–2012–069]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change To Modify an
Optional Depth Data Enterprise
License Fee for Broker-Dealer
Distribution of Depth-of-Book Data
June 25, 2012.
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 June 12,
2012, The NASDAQ Stock Market LLC
(‘‘NASDAQ’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I, II and III
below, which Items have been prepared
by NASDAQ. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
mstockstill on DSK4VPTVN1PROD with NOTICES
I. Self-Regulatory Organization’s
Statement of the Terms of the Substance
of the Proposed Rule Change
NASDAQ proposes to modify the
optional Enterprise License fee for NonProfessional Subscribers of certain
NASDAQ Depth-of-Book market data.
NASDAQ will implement the proposed
revised fee on July 1, 2012.
*
*
*
*
*
9 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
16:52 Jun 28, 2012
(a)–(b) No change.
(c) Enterprise License Fees
(1)–(2) No Change.
(3) As an alternative to subsections (1)
and (2) above, a Distributor that is also
a broker-dealer may pay a monthly fee
of $500,000 [325,000] to provide
NASDAQ Level 2, NASDAQ TotalView,
or NASDAQ OpenView for Display
Usage by Non-Professional Subscribers
with whom the firm has a brokerage
relationship. This Enterprise License
shall not apply to relevant Level 1 or
Depth Distributor fees.
(d)–(e) No change.
*
*
*
*
*
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
NASDAQ 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.
NASDAQ 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
NASDAQ is proposing a change to the
Enterprise License Fee for NonProfessional Usage of certain NASDAQ
Depth-of-Book market data. NASDAQ
Rule 7023(c)(3) offers an optional
Enterprise License for unlimited NonProfessional Subscribers of NASDAQ
Level 2, NASDAQ TotalView, or
NASDAQ OpenView for broker-dealers
registered under the Act. Specifically,
NASDAQ proposes to increase the
optional fee for Distributors from
$325,000 to $500,000 per month that
covers all Non-Professional Subscribers
with whom the firm has a brokerage
relationship. This Depth-of-Book
Enterprise License Fee includes NonProfessional Subscriber fees, but does
not include Distributor fees. Nonbroker-dealer vendors and application
service providers are not eligible for the
Enterprise License; such firms typically
pass through the cost of market data
Subscriber fees to their customers.3
3 NASDAQ relies on Distributor self-reporting of
usage rather than on individual contact with each
end-user Subscriber. For this Enterprise License,
1 15
VerDate Mar<15>2010
7023. NASDAQ Depth-of-Book Data
Jkt 226001
PO 00000
Frm 00107
Fmt 4703
Sfmt 4703
38871
NASDAQ continues to seek broader
distribution of Depth-of-Book data and
to reduce the cost of providing Depthof-Book data to larger numbers of
investors. In the past, NASDAQ has
accomplished this goal in part by
offering similar enterprise licenses for
Professional and Non-Professional
Usage of TotalView which contains the
full Depth-of-Book data for the
NASDAQ Market Center Execution
System. NASDAQ believes that the
adoption of enterprise licenses has led
to greater distribution of market data,
particularly among Non-Professional
Subscribers.
In addition to increased
administrative flexibility, enterprise
licenses also encourage broader
distribution by firms that are currently
over the fee cap as well as those that are
approaching the cap and wish to take
advantage of the benefits of the program.
Further, NASDAQ believes that capping
fees in this manner creates goodwill
with broker-dealers and increases
transparency for retail investors.
The Depth-of-Book Enterprise License
Fee is completely optional and does not
replace existing enterprise license fee
alternatives set forth in Rule 7023.
Additionally, the proposal does not
impact individual Subscriber fees for
any product or raise the costs to any
Subscriber of any NASDAQ data
product. The market for this Depth-ofBook information is highly competitive
and continually evolves as products
develop and change. As a result, it is
proposed that the current fee be
increased, in part, due to a change in
market data distribution and growing
economies of scale in the industry.
Subsequent to the introduction of the
Depth-of-Book Enterprise License, there
has been a substantial change in the
adoption rate and distribution of Depthof-Book data. Additionally, as broker/
dealers consolidate and continue to
grow organically, NASDAQ needs to
adjust its enterprise license pricing
model to better reflect current market
conditions. The adjustment of this fee
reflects these and other market forces.
2. Statutory Basis
NASDAQ believes that the proposed
rule change is consistent with the
provisions of Section 6 of the Act,4 in
general, and with Section 6(b)(4) of the
NASDAQ permits Distributors to designate an
entire Subscriber population as Non-Professional
provided that the number of Professional
Subscribers within that Subscriber population does
not exceed ten percent (10%) of the total
population.
4 15 U.S.C. 78f.
E:\FR\FM\29JNN1.SGM
29JNN1
38872
Federal Register / Vol. 77, No. 126 / Friday, June 29, 2012 / Notices
Act,5 in particular, in that it provides an
equitable allocation of reasonable fees
among Subscribers and recipients of
NASDAQ data. In adopting Regulation
NMS, the Commission granted selfregulatory organizations and brokerdealers 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:
mstockstill on DSK4VPTVN1PROD with NOTICES
[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.6
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.
Level 2, TotalView and OpenView are
precisely the sort of market data
products that the Commission
envisioned when it adopted Regulation
NMS.
On July 21, 2010, President Barack
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 selfregulatory 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.
5 15
U.S.C. 78f(b)(4).
Exchange Act Release No. 51808
(June 9, 2005), 70 FR 37496 (June 29, 2005).
6 Securities
VerDate Mar<15>2010
16:52 Jun 28, 2012
Jkt 226001
Section 916 further amended paragraph
(C) of Section 19(b)(3) of the 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.’’
The decision of the United States
Court of Appeals for the District of
Columbia Circuit in NetCoalition v.
SEC, No. 09–1042 (D.C. 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.’ ’’ NetCoalition, 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.
For the reasons stated above,
NASDAQ believes that the proposed
fees are fair and equitable, and not
unreasonably discriminatory. As
described above, the proposed fees are
based on pricing conventions and
distinctions that exist in NASDAQ’s
current fee schedule, and the fee
schedules of other exchanges. These
PO 00000
Frm 00108
Fmt 4703
Sfmt 4703
distinctions (top-of-book versus Depthof-Book, Professional versus nonProfessional Subscribers, Direct versus
Indirect Access, Internal versus External
Distribution) are each based on
principles of fairness and equity that
have helped for many years to maintain
fair, equitable, and not unreasonably
discriminatory fees, and that apply with
equal or greater force to the current
proposal.
As described in greater detail below,
if NASDAQ has calculated improperly
and the market deems the proposed fees
to be unfair, inequitable, or
unreasonably discriminatory, firms can
diminish or discontinue the use of their
data because the proposed fee is entirely
optional to all parties. Firms are not
required to purchase Depth-of-Book data
or to utilize any specific pricing
alternative if they do choose to purchase
Depth-of-Book data. NASDAQ is not
required to make Depth-of-Book data
available or to offer specific pricing
alternatives for potential purchases.
NASDAQ can discontinue offering a
pricing alternative (as it has in the past)
and firms can discontinue their use at
any time and for any reason (as they
often do), including due to their
assessment of the reasonableness of fees
charged. NASDAQ continues to
establish and revise pricing policies
aimed at increasing fairness and
equitable allocation of fees among
Subscribers.
NASDAQ believes that the Depth-ofBook Enterprise License promotes
increased transparency by offering a
pricing option resulting in lower fees for
heavy users of Depth-of-Book data.
While NASDAQ may need to
periodically adjust the Depth-of-Book
Enterprise License to reflect market
forces, it continues to view the fee cap
as a way for firms to make additional
information available to the firms’
clients, thereby increasing transparency
of the market.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
NASDAQ 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 NetCoalition 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. NASDAQ believes that a
record may readily be established to
E:\FR\FM\29JNN1.SGM
29JNN1
mstockstill on DSK4VPTVN1PROD with NOTICES
Federal Register / Vol. 77, No. 126 / Friday, June 29, 2012 / Notices
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 Subscribers only insofar as
they provide information that end
Subscribers 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 brokerdealer because it does not provide
VerDate Mar<15>2010
16:52 Jun 28, 2012
Jkt 226001
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’.’’ NetCoalition at 24. 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.
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
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 platform 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
PO 00000
Frm 00109
Fmt 4703
Sfmt 4703
38873
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 after-market 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 SRO markets,
as well as internalizing 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.
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 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.
E:\FR\FM\29JNN1.SGM
29JNN1
mstockstill on DSK4VPTVN1PROD with NOTICES
38874
Federal Register / Vol. 77, No. 126 / Friday, June 29, 2012 / Notices
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 Depth-of-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
Subscribers. Vendors impose price
restraints based upon their business
models. For example, vendors such as
Bloomberg and Thomson Reuters that
assess a surcharge on data they sell may
refuse to offer proprietary products that
end Subscribers will not purchase in
sufficient numbers. Internet portals,
such as Google, 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. NASDAQ 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
VerDate Mar<15>2010
16:52 Jun 28, 2012
Jkt 226001
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. NASDAQ
believes, however, that evidence not
before the court clearly demonstrates
that availability of data attracts order
flow. For example, as of July 2010, 92
of the top 100 broker-dealers by shares
executed on NASDAQ consumed NQDS
and 80 of the top 100 broker-dealers
consumed TotalView. During that
month, the NQDS-Subscribers were
responsible for 94.44% of the orders
entered into NASDAQ and TotalView
Subscribers were responsible for
92.98%.
Competition among platforms has
driven NASDAQ continually to improve
its platform data offerings and to cater
to customers’ data needs. For example,
NASDAQ has developed and
maintained multiple delivery
mechanisms (IP, multi-cast, and
compression) that enable customers to
receive data in the form and manner
they prefer and at the lowest cost to
them. NASDAQ offers front end
applications such as its ‘‘Bookviewer’’
to help customers utilize data. NASDAQ
has created new products like
TotalView Aggregate to complement
TotalView ITCH and/NQDS, because
offering data in multiple formatting
allows NASDAQ to better fit customer
needs. NASDAQ offers data via multiple
extranet providers, thereby helping to
reduce network and total cost for its
data products. NASDAQ has developed
an online administrative system to
provide customers transparency into
their data feed requests and streamline
data usage reporting. NASDAQ has also
expanded its Enterprise License options
that reduce the administrative burden
and costs to firms that purchase market
data.
Despite these enhancements and a
dramatic increase in message traffic,
NASDAQ’s fees for market data have
remained flat. In fact, as a percent of
PO 00000
Frm 00110
Fmt 4703
Sfmt 4703
total Subscriber costs, NASDAQ data
fees have fallen relative to other data
usage costs—including bandwidth,
programming, and infrastructure—that
have risen. The same holds true for
execution services; despite numerous
enhancements to NASDAQ’s trading
platform, absolute and relative trading
costs have declined. Platform
competition has intensified as new
entrants have emerged, constraining
prices for both executions and for data.
The vigor of competition for Depth-ofBook information is significant and the
Exchange believes that this proposal
itself clearly evidences such
competition. NASDAQ is offering a new
pricing model in order to keep pace
with changes in the industry and
evolving customer needs. It is entirely
optional and is geared towards
attracting new customers, as well as
retaining existing customers.
The Exchange has witnessed
competitors creating new products and
innovative pricing in this space over the
course of the past year. NASDAQ
continues to see firms challenge its
pricing on the basis of the Exchange’s
explicit fees being higher than the zeropriced fees from other competitors such
as BATS. In all cases, firms make
decisions on how much and what types
of data to consume on the basis of the
total cost of interacting with NASDAQ
or other exchanges. Of course, the
explicit data fees are but one factor in
a total platform analysis. Some
competitors have lower transactions fees
and higher data fees, and others are vice
versa. The market for this Depth-of-Book
information is highly competitive and
continually evolves as products develop
and change.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
Written comments were neither
solicited nor 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.7 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
7 15
E:\FR\FM\29JNN1.SGM
U.S.C. 78s(b)(3)(a)(ii). [sic]
29JNN1
Federal Register / Vol. 77, No. 126 / Friday, June 29, 2012 / Notices
takes such action, the Commission shall
institute proceedings to determine
whether the proposed rule should be
approved or disapproved.
IV. Solicitation of Comments
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.8
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2012–15956 Filed 6–28–12; 8:45 am]
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:
BILLING CODE 8011–01–P
Electronic Comments
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing of Proposed Rule Change To
Amend Rule 4758(a)(1)(A) To Reflect a
Change in NASDAQ’s Routing
Functionality
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number SR–NASDAQ–2012–069 on the
subject line.
mstockstill on DSK4VPTVN1PROD with NOTICES
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–NASDAQ–2012–069. This
file number should be included on the
subject line if email 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 10:00 a.m.
and 3:00 p.m. Copies of such filing also
will be available for inspection and
copying at the principal offices of
NASDAQ. All comments received will
be posted without change; the
Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–
NASDAQ–2012–069, and should be
submitted on or before July 20, 2012.
VerDate Mar<15>2010
16:52 Jun 28, 2012
Jkt 226001
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–67246; File No. SR–
NASDAQ–2012–071]
June 25, 2012.
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 June 14,
2012, The NASDAQ Stock Market LLC
(‘‘NASDAQ’’ or ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I, II, and III below, which Items
have been prepared by the selfregulatory organization. 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
Rule 4758(a)(1)(A) to reflect a change in
NASDAQ’s routing functionality.
The text of the proposed rule change
is below. Proposed new language is in
italics; proposed deletions are in
brackets.
*
*
*
*
*
4758. Order Routing
(a) Order Routing Process
(1) The Order Routing Process shall be
available to Participants from 7:00 a.m. until
8:00 p.m. Eastern Time, and shall route
orders as described below. All routing of
orders shall comply with Rule 611 of
Regulation NMS under the Exchange Act.
(A) The System provides a variety of
routing options. Routing options may be
combined with all available order types and
times-in-force, with the exception of order
types and times-in-force whose terms are
inconsistent with the terms of a particular
routing option. The System will consider the
quotations only of accessible markets. The
8 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
PO 00000
Frm 00111
Fmt 4703
Sfmt 4703
38875
term ‘‘System routing table’’ refers to the
proprietary process for determining the
specific trading venues to which the System
routes orders and the order in which it routes
them. Nasdaq reserves the right to maintain
a different System routing table for different
routing options and to modify the System
routing table at any time without notice. The
System routing options are:
(i) DOT is a routing option for orders that
the entering firm wishes to designate for
participation in the NYSE or NYSE Amex
opening or closing processes. DOT orders are
routed directly to NYSE or NYSE Amex, as
appropriate. After attempting to execute in
the opening or closing process, DOT orders
thereafter check the System for available
shares and are converted into SCAN or STGY
orders, depending on the designation of the
entering firm. DOT orders that are designated
to participate in the NYSE or NYSE Amex
opening process but that are entered after
9:30 a.m. will also be converted into SCAN
or STGY orders, depending on the
designation of the entering firm.
(ii) a. DOTI is a routing option for orders
that the entering firm wishes to direct to the
NYSE or NYSE Amex without returning to
the Nasdaq Market Center. DOTI orders
check the System for available shares and
then are sent to destinations on the System
routing table before being sent to NYSE or
NYSE Amex, as appropriate. DOTI orders do
not return to the Nasdaq Market Center book
after routing.
b. The entering firm may alternatively elect
to have DOTI orders check the System for
available shares and thereafter be directly
sent to NYSE or NYSE Amex as appropriate.
(iii) STGY is a routing option under which
orders check the System for available shares
and simultaneously route the remaining
shares[then are sent] to destinations on the
System routing table. If shares remain unexecuted after routing, they are posted on the
book. Once on the book, should the order
subsequently be locked or crossed by another
accessible market center, the System shall
route the order to the locking or crossing
market center. SKNY is a form of STGY in
which the entering firm instructs the System
to bypass any market centers included in the
STGY System routing table that are not
posting Protected Quotations within the
meaning of Regulation NMS.
(iv) SCAN is a routing option under which
orders check the System for available shares
and simultaneously route the remaining
shares[then are sent] to destinations on the
System routing table. If shares remain unexecuted after routing, they are posted on the
book. Once on the book, should the order
subsequently be locked or crossed by another
market center, the System will not route the
order to the locking or crossing market
center. SKIP is a form of SCAN in which the
entering firm instructs the System to bypass
any market centers included in the SCAN
System routing table that are not posting
Protected Quotations within the meaning of
Regulation NMS.
(v) TFTY is a routing option under which
orders check the System for available shares
only if so instructed by the entering firm and
are thereafter routed to destinations on the
System routing table. If shares remain un-
E:\FR\FM\29JNN1.SGM
29JNN1
Agencies
[Federal Register Volume 77, Number 126 (Friday, June 29, 2012)]
[Notices]
[Pages 38871-38875]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2012-15956]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-67253; File No. SR-NASDAQ-2012-069]
Self-Regulatory Organizations; The NASDAQ Stock Market LLC;
Notice of Filing and Immediate Effectiveness of Proposed Rule Change To
Modify an Optional Depth Data Enterprise License Fee for Broker-Dealer
Distribution of Depth-of-Book Data
June 25, 2012.
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 June 12, 2012, The NASDAQ Stock Market LLC (``NASDAQ'') filed with
the Securities and Exchange Commission (``Commission'') the proposed
rule change as described in Items I, II and III below, which Items have
been prepared by NASDAQ. 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 the
Substance of the Proposed Rule Change
NASDAQ proposes to modify the optional Enterprise License fee for
Non-Professional Subscribers of certain NASDAQ Depth-of-Book market
data. NASDAQ will implement the proposed revised fee on July 1, 2012.
* * * * *
7023. NASDAQ Depth-of-Book Data
(a)-(b) No change.
(c) Enterprise License Fees
(1)-(2) No Change.
(3) As an alternative to subsections (1) and (2) above, a
Distributor that is also a broker-dealer may pay a monthly fee of
$500,000 [325,000] to provide NASDAQ Level 2, NASDAQ TotalView, or
NASDAQ OpenView for Display Usage by Non-Professional Subscribers with
whom the firm has a brokerage relationship. This Enterprise License
shall not apply to relevant Level 1 or Depth Distributor fees.
(d)-(e) No change.
* * * * *
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, NASDAQ 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. NASDAQ 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
NASDAQ is proposing a change to the Enterprise License Fee for Non-
Professional Usage of certain NASDAQ Depth-of-Book market data. NASDAQ
Rule 7023(c)(3) offers an optional Enterprise License for unlimited
Non-Professional Subscribers of NASDAQ Level 2, NASDAQ TotalView, or
NASDAQ OpenView for broker-dealers registered under the Act.
Specifically, NASDAQ proposes to increase the optional fee for
Distributors from $325,000 to $500,000 per month that covers all Non-
Professional Subscribers with whom the firm has a brokerage
relationship. This Depth-of-Book Enterprise License Fee includes Non-
Professional Subscriber fees, but does not include Distributor fees.
Non-broker-dealer vendors and application service providers are not
eligible for the Enterprise License; such firms typically pass through
the cost of market data Subscriber fees to their customers.\3\
---------------------------------------------------------------------------
\3\ NASDAQ relies on Distributor self-reporting of usage rather
than on individual contact with each end-user Subscriber. For this
Enterprise License, NASDAQ permits Distributors to designate an
entire Subscriber population as Non-Professional provided that the
number of Professional Subscribers within that Subscriber population
does not exceed ten percent (10%) of the total population.
---------------------------------------------------------------------------
NASDAQ continues to seek broader distribution of Depth-of-Book data
and to reduce the cost of providing Depth-of-Book data to larger
numbers of investors. In the past, NASDAQ has accomplished this goal in
part by offering similar enterprise licenses for Professional and Non-
Professional Usage of TotalView which contains the full Depth-of-Book
data for the NASDAQ Market Center Execution System. NASDAQ believes
that the adoption of enterprise licenses has led to greater
distribution of market data, particularly among Non-Professional
Subscribers.
In addition to increased administrative flexibility, enterprise
licenses also encourage broader distribution by firms that are
currently over the fee cap as well as those that are approaching the
cap and wish to take advantage of the benefits of the program. Further,
NASDAQ believes that capping fees in this manner creates goodwill with
broker-dealers and increases transparency for retail investors.
The Depth-of-Book Enterprise License Fee is completely optional and
does not replace existing enterprise license fee alternatives set forth
in Rule 7023. Additionally, the proposal does not impact individual
Subscriber fees for any product or raise the costs to any Subscriber of
any NASDAQ data product. The market for this Depth-of-Book information
is highly competitive and continually evolves as products develop and
change. As a result, it is proposed that the current fee be increased,
in part, due to a change in market data distribution and growing
economies of scale in the industry. Subsequent to the introduction of
the Depth-of-Book Enterprise License, there has been a substantial
change in the adoption rate and distribution of Depth-of-Book data.
Additionally, as broker/dealers consolidate and continue to grow
organically, NASDAQ needs to adjust its enterprise license pricing
model to better reflect current market conditions. The adjustment of
this fee reflects these and other market forces.
2. Statutory Basis
NASDAQ believes that the proposed rule change is consistent with
the provisions of Section 6 of the Act,\4\ in general, and with Section
6(b)(4) of the
[[Page 38872]]
Act,\5\ in particular, in that it provides an equitable allocation of
reasonable fees among Subscribers and recipients of NASDAQ 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.
---------------------------------------------------------------------------
\4\ 15 U.S.C. 78f.
\5\ 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.\6\
---------------------------------------------------------------------------
\6\ 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. Level 2, TotalView and
OpenView are precisely the sort of market data products that the
Commission envisioned when it adopted Regulation NMS.
On July 21, 2010, President Barack 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
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.''
The decision of the United States Court of Appeals for the District
of Columbia Circuit in NetCoalition v. SEC, No. 09-1042 (D.C. 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.' ''
NetCoalition, 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.
For the reasons stated above, NASDAQ believes that the proposed
fees are fair and equitable, and not unreasonably discriminatory. As
described above, the proposed fees are based on pricing conventions and
distinctions that exist in NASDAQ's current fee schedule, and the fee
schedules of other exchanges. These distinctions (top-of-book versus
Depth-of-Book, Professional versus non-Professional Subscribers, Direct
versus Indirect Access, Internal versus External Distribution) are each
based on principles of fairness and equity that have helped for many
years to maintain fair, equitable, and not unreasonably discriminatory
fees, and that apply with equal or greater force to the current
proposal.
As described in greater detail below, if NASDAQ has calculated
improperly and the market deems the proposed fees to be unfair,
inequitable, or unreasonably discriminatory, firms can diminish or
discontinue the use of their data because the proposed fee is entirely
optional to all parties. Firms are not required to purchase Depth-of-
Book data or to utilize any specific pricing alternative if they do
choose to purchase Depth-of-Book data. NASDAQ is not required to make
Depth-of-Book data available or to offer specific pricing alternatives
for potential purchases. NASDAQ can discontinue offering a pricing
alternative (as it has in the past) and firms can discontinue their use
at any time and for any reason (as they often do), including due to
their assessment of the reasonableness of fees charged. NASDAQ
continues to establish and revise pricing policies aimed at increasing
fairness and equitable allocation of fees among Subscribers.
NASDAQ believes that the Depth-of-Book Enterprise License promotes
increased transparency by offering a pricing option resulting in lower
fees for heavy users of Depth-of-Book data. While NASDAQ may need to
periodically adjust the Depth-of-Book Enterprise License to reflect
market forces, it continues to view the fee cap as a way for firms to
make additional information available to the firms' clients, thereby
increasing transparency of the market.
B. Self-Regulatory Organization's Statement on Burden on Competition
NASDAQ 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
NetCoalition 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. NASDAQ
believes that a record may readily be established to
[[Page 38873]]
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 Subscribers only
insofar as they provide information that end Subscribers 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'.'' NetCoalition at 24. 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.
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 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 platform 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 after-market 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 SRO markets, as well as internalizing 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.
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 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.
[[Page 38874]]
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 Depth-of-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 Subscribers. Vendors impose price restraints based upon
their business models. For example, vendors such as Bloomberg and
Thomson Reuters that assess a surcharge on data they sell may refuse to
offer proprietary products that end Subscribers will not purchase in
sufficient numbers. Internet portals, such as Google, 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. NASDAQ 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.
NASDAQ believes, however, that evidence not before the court clearly
demonstrates that availability of data attracts order flow. For
example, as of July 2010, 92 of the top 100 broker-dealers by shares
executed on NASDAQ consumed NQDS and 80 of the top 100 broker-dealers
consumed TotalView. During that month, the NQDS-Subscribers were
responsible for 94.44% of the orders entered into NASDAQ and TotalView
Subscribers were responsible for 92.98%.
Competition among platforms has driven NASDAQ continually to
improve its platform data offerings and to cater to customers' data
needs. For example, NASDAQ has developed and maintained multiple
delivery mechanisms (IP, multi-cast, and compression) that enable
customers to receive data in the form and manner they prefer and at the
lowest cost to them. NASDAQ offers front end applications such as its
``Bookviewer'' to help customers utilize data. NASDAQ has created new
products like TotalView Aggregate to complement TotalView ITCH and/
NQDS, because offering data in multiple formatting allows NASDAQ to
better fit customer needs. NASDAQ offers data via multiple extranet
providers, thereby helping to reduce network and total cost for its
data products. NASDAQ has developed an online administrative system to
provide customers transparency into their data feed requests and
streamline data usage reporting. NASDAQ has also expanded its
Enterprise License options that reduce the administrative burden and
costs to firms that purchase market data.
Despite these enhancements and a dramatic increase in message
traffic, NASDAQ's fees for market data have remained flat. In fact, as
a percent of total Subscriber costs, NASDAQ data fees have fallen
relative to other data usage costs--including bandwidth, programming,
and infrastructure--that have risen. The same holds true for execution
services; despite numerous enhancements to NASDAQ's trading platform,
absolute and relative trading costs have declined. Platform competition
has intensified as new entrants have emerged, constraining prices for
both executions and for data.
The vigor of competition for Depth-of-Book information is
significant and the Exchange believes that this proposal itself clearly
evidences such competition. NASDAQ is offering a new pricing model in
order to keep pace with changes in the industry and evolving customer
needs. It is entirely optional and is geared towards attracting new
customers, as well as retaining existing customers.
The Exchange has witnessed competitors creating new products and
innovative pricing in this space over the course of the past year.
NASDAQ continues to see firms challenge its pricing on the basis of the
Exchange's explicit fees being higher than the zero-priced fees from
other competitors such as BATS. In all cases, firms make decisions on
how much and what types of data to consume on the basis of the total
cost of interacting with NASDAQ or other exchanges. Of course, the
explicit data fees are but one factor in a total platform analysis.
Some competitors have lower transactions fees and higher data fees, and
others are vice versa. The market for this Depth-of-Book information is
highly competitive and continually evolves as products develop and
change.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
Written comments were neither solicited nor 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.\7\ 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
[[Page 38875]]
takes such action, the Commission shall institute proceedings to
determine whether the proposed rule should be approved or disapproved.
---------------------------------------------------------------------------
\7\ 15 U.S.C. 78s(b)(3)(a)(ii). [sic]
---------------------------------------------------------------------------
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 email to rule-comments@sec.gov. Please include
File Number SR-NASDAQ-2012-069 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-NASDAQ-2012-069. This
file number should be included on the subject line if email 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 10:00 a.m. and 3:00 p.m.
Copies of such filing also will be available for inspection and copying
at the principal offices of NASDAQ. All comments received will be
posted without change; the Commission does not edit personal
identifying information from submissions. You should submit only
information that you wish to make available publicly. All submissions
should refer to File Number SR-NASDAQ-2012-069, and should be submitted
on or before July 20, 2012.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\8\
Kevin M. O'Neill,
Deputy Secretary.
---------------------------------------------------------------------------
\8\ 17 CFR 200.30-3(a)(12).
---------------------------------------------------------------------------
[FR Doc. 2012-15956 Filed 6-28-12; 8:45 am]
BILLING CODE 8011-01-P