Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Modify Fees for the NASDAQ Basic Data Product, 28575-28581 [2014-11296]
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Federal Register / Vol. 79, No. 95 / Friday, May 16, 2014 / Notices
should be submitted on or before June
6, 2014.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.20
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–11292 Filed 5–15–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72153; File No. SR–
NASDAQ–2014–045]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change To Modify Fees
for the NASDAQ Basic Data Product
May 12, 2014.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (the
‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on April 30,
2014, The NASDAQ Stock Market LLC
(‘‘NASDAQ’’ or the ‘‘Exchange’’) filed
with the Securities and Exchange
Commission (‘‘Commission’’) the
proposed rule change as described in
Items I and II below, which Items have
been prepared by the Exchange. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
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I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
NASDAQ is proposing modify [sic]
fees for the NASDAQ Basic data
product. The proposal, which modifies
monthly fees, is effective for the month
of May 2014 and subsequent months.
The text of the proposed rule change is
available on the Exchange’s Web site at
https://nasdaq.cchwallstreet.com, at the
principal office of the Exchange, and at
the Commission’s Public Reference
Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
20 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
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The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts 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 two
modifications to the fees for NASDAQ
Basic: (1) To cap the ‘‘per query’’ fee
paid by a single user at the level of the
monthly fee paid by monthly
Professional and Non-Professional
subscribers and (2) to clarify the
application of the recently-filed
Enterprise License fee where a single
firm receives data from multiple
External Distributors.
Background. NASDAQ Basic is a
proprietary data product that provides
best bid and offer information from the
NASDAQ Market Center and last sale
transaction reports from the NASDAQ
Market Center and from the FINRA/
NASDAQ Trade Reporting Facility
(‘‘FINRA/NASDAQ TRF’’). As such,
NASDAQ Basic provides a subset of the
‘‘core’’ quotation and last sale data
provided by securities information
processors (‘‘SIPs’’) under the CQ/CT
Plan and the NASDAQ UTP Plan.
Earlier this year, NASDAQ introduced a
new enterprise license for Professional
Subscribers to NASDAQ Basic.3 In this
proposed rule change, NASDAQ is
proposing a minor refinement to the
enterprise license.
NASDAQ Basic contains three
separate components, which may be
purchased individually or in
combination: (i) NASDAQ Basic for
NASDAQ, which contains the best bid
and offer on the NASDAQ Market
Center and last sale transaction reports
for NASDAQ and the FINRA/NASDAQ
TRF for NASDAQ-listed stocks, (ii)
NASDAQ Basic for NYSE, which covers
NYSE-listed stocks, and (iii) NASDAQ
Basic for NYSE MKT, which covers
stocks listed on NYSE MKT and other
listing venues whose quotes and trade
reports are disseminated on Tape B.
Per Query Fee Cap. The fee structure
for NASDAQ Basic features a fee for
Professional Subscribers and a reduced
fee for Non-Professional Subscribers.4
3 Securities Exchange Act Release No. 71507
(February 7, 2014), 79 FR 8763 (February 13, 2014)
(SR–NASDAQ–2014–011).
4 A ‘‘Non-Professional Subscriber’’ is ‘‘a natural
person who is not (i) registered or qualified in any
capacity with the Commission, the Commodity
Futures Trading Commission, any state securities
agency, any securities exchange or association, or
any commodities or futures contract market or
association; (ii) engaged as an ‘‘investment adviser’’
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The current monthly fees for NonProfessional Subscribers are $0.50 per
Subscriber for NASDAQ Basic for
NASDAQ, $0.25 per Subscriber for
NASDAQ Basic for NYSE, and $0.25 per
Subscriber for NASDAQ Basic for NYSE
MKT. The current monthly fees for
Professional Subscribers are $13 per
Subscriber for NASDAQ Basic for
NASDAQ, $6.50 per Subscriber for
NASDAQ Basic for NYSE, and $6.50 per
Subscriber for NASDAQ Basic for NYSE
MKT. For use cases that do not require
a monthly subscription for unlimited
usage, there is a Per Query option, with
a fee of $0.0025 for NASDAQ Basic for
NASDAQ, $0.0015 for NASDAQ Basic
for NYSE, and $0.0015 for NASDAQ
Basic for NYSE MKT.
Distributors 5 of NASDAQ Basic may
also be assessed a monthly Distributor
Fee. The fee is $1,500 per month for
either internal or external distribution;
however, a credit for Subscriber or Per
Query fees may be applied against the
Distributor Fee at the Distributor’s
request.
NASDAQ is proposing to cap the ‘‘per
query’’ fee paid by a single user at the
level of the monthly fee paid by
monthly subscribers. The fee structure
for NASDAQ Basic features a fee for
Professional Subscribers and a reduced
fee for Non-Professional Subscribers.
The current monthly fees for NonProfessional Subscribers are $0.50 per
Subscriber for NASDAQ Basic for
NASDAQ, while the Per Query fee is
$0.0025 for NASDAQ Basic for
NASDAQ. Under NASDAQ’s proposal, a
Non-Professional user would pay the
Per Query fee for the first 199 queries
during the month. However, if the
Subscriber made 200 or more queries
during the month, the cap would take
effect, such that the total aggregate
monthly charge for all queries by the
Subscriber would be $0.50. For
NASDAQ Basic for NYSE and NYSE
MKT, the corresponding breakpoint for
as that term is defined in Section 201(11) of the
Investment Advisers Act of 1940 (whether or not
registered or qualified under that Act); or (iii)
employed by a bank or other organization exempt
from registration under federal or state securities
laws to perform functions that would require
registration or qualification if such functions were
performed for an organization not so exempt.’’ A
‘‘Professional Subscriber’’ is ‘‘any Subscriber other
than a Non-Professional Subscriber.’’
5 The term ‘‘Distributor’’ ‘‘refers to any entity that
receives NASDAQ Basic data directly from
NASDAQ or indirectly through another entity and
then distributes it to one or more Subscribers.’’
Distributors may either be ‘‘Internal Distributors’’,
which are ‘‘Distributors that receive NASDAQ Basic
data and then distribute that data to one or more
Subscribers within the Distributor’s own entity,’’ or
‘‘External Distributors’’, which are ‘‘Distributors
that receive NASDAQ Basic data and then
distribute that data to one or more Subscribers
outside the Distributor’s own entity.’’
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Non-Professionals would occur at 167th
query.
With respect to Professional users,
under NASDAQ’s proposal, a
Professional user of NASDAQ Basic for
NASDAQ stocks would pay the Per
Query fee for the first 5,199 queries, but
the cap would thereafter take effect,
such that the total aggregate monthly
charge for all queries by the Subscriber
would be $13. For NASDAQ Basic for
NYSE and MKT stocks, the breakpoint
for Professional Users would occur at
4,333 queries and the cap would
thereafter take effect, such that the total
aggregate monthly charge for all queries
by the Subscriber would be $6.50.
Enterprise License Clarification. As an
alternative to monthly Subscriber fees
for Non-Professional Subscribers,
NASDAQ also offers an enterprise
license under which a broker-dealer
may distribute NASDAQ Basic to an
unlimited number of Non-Professional
Subscribers with whom the brokerdealer has a brokerage relationship at a
rate of $100,000 per month (as well as
the applicable monthly Distributor fee).
In addition, a Distributor of data derived
from NASDAQ Basic (but not NASDAQ
Basic itself) may pay a fee of $1,500 per
month (plus the applicable monthly
Distributor fee) to distribute the derived
data to an unlimited number of NonProfessional Subscribers. This type of
Distributor will typically distribute data
to a large number of downstream
customers through web-based
applications.
Under new net reporting rules
adopted earlier this year,6 Distributors
may reduce the overall number of
internal Professional Subscribers
deemed to be fee liable with respect to
‘‘Display Usage’’ of NASDAQ Basic: 7
• A Subscriber that receives access to
NASDAQ Basic through multiple
products controlled by an Internal
Distributor is considered one
Subscriber. Thus, if a broker-dealer acts
as a Distributor of NASDAQ Basic in
multiple forms to its employees, each
employee would be considered one
Subscriber.
• A Subscriber that receives access to
NASDAQ Basic through multiple
products controlled by one External
Distributor is considered one
Subscriber. Thus, if a broker-dealer
arranges for its employees to receive
6 See
supra n. 3.
Usage’’ means ‘‘any method of
accessing NASDAQ Basic data that involves the
display of such data on a screen or other
visualization mechanism for access or use by a
natural person or persons.’’ Netting does not apply
to uses other than Display Usage (i.e., use by an
automated device without visual access by natural
persons).
7 ‘‘Display
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access to multiple NASDAQ Basic
products provided by a single vendor,
each employee would be considered one
Subscriber.
• A Subscriber that receives access to
NASDAQ Basic through one or more
products controlled by an Internal
Distributor and also one or more
products controlled by one External
Distributor is considered one
Subscriber. Thus, if the broker-dealer
provides employees with access through
its own product(s) and through products
from a single vendor, each employee is
still considered one Subscriber.
• A Subscriber that receives access to
NASDAQ Basic through one or more
products controlled by an Internal
Distributor and also products controlled
by multiple External Distributors is
treated as one Subscriber with respect to
the products controlled by the Internal
Distributor and one of the External
Distributors, and is treated as an
additional Subscriber for each
additional External Distributor. Thus, a
Subscriber receiving products through
an Internal Distributor and two External
Distributors is treated as two
Subscribers.
At the same time, NASDAQ also
adopted a new enterprise license for
Professional Subscribers. Under the
enterprise license, a broker-dealer may
distribute NASDAQ Basic for NASDAQ,
NASDAQ Basic for NYSE, and
NASDAQ Basic for NYSE MKT for a flat
fee of $365,000 per month; provided,
however, that if the broker-dealer
obtains the license with respect to usage
of NASDAQ Basic provided by an
External Distributor that controls
display of the product, the fee will be
$365,000 per month for up to 16,000
internal Professional Subscribers, plus
$2 for each additional internal
Professional Subscriber over 16,000.
NASDAQ is proposing to adopt
clarifying language in the rule governing
the enterprise license to make it clear
that a license would cover only one
External Distributor that controls
display. Thus, if a broker-dealer used
NASDAQ Basic provided by more than
one such External Distributor, it would
be required to obtain a separate
enterprise license for each External
Distributor. Alternatively, it could
designate that the enterprise license
covered one External Distributor and
pay regular per-Subscriber fees with
respect to other External Distributor(s).
The change to rule language is necessary
to ensure that the rule reflects
NASDAQ’s original intent with regard
to the scope of the enterprise license.
Specifically, the license is intended to
provide broker-dealers with a costeffective means of obtaining NASDAQ
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Basic for internal users, but is not
intended to allow it to obtain the
product through multiple External
Distributors at the same fee it would pay
for just one External Distributor.
2. Statutory Basis
NASDAQ believes that the proposed
rule change is consistent with the
provisions of Section 6 of the Act 8 in
general, and with Sections 6(b)(4) and
(5) of the Act 9 in particular, in that it
provides for the equitable allocation of
reasonable dues, fees and other charges
among recipients of NASDAQ data and
is not designed to permit unfair
discrimination between them. In
adopting Regulation NMS, the
Commission granted self-regulatory
organizations (‘‘SROs’’) and brokerdealers (‘‘BDs’’) 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. NASDAQ believes that its
NASDAQ Basic market data product is
precisely the sort of market data product
that the Commission envisioned when it
adopted Regulation NMS. The
Commission concluded that Regulation
NMS—by deregulating the market in
proprietary data—would itself further
the Act’s goals of facilitating efficiency
and competition:
[E]fficiency is promoted when brokerdealers who do not need the data beyond the
prices, sizes, market center identifications of
the NBBO and consolidated last sale
information are not required to receive (and
pay for) such data. The Commission also
believes that efficiency is promoted when
broker-dealers may choose to receive (and
pay for) additional market data based on their
own internal analysis of the need for such
data.10
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 at all, it follows that the price at
which such data is sold should be set by
the market as well. NASDAQ Basic
exemplifies the optional nature of
proprietary data, since, depending on a
customer’s specific goals, it may opt to
purchase core SIP data or only the
subset provided through NASDAQ
Basic. Moreover, as discussed in more
detail below, the price that NASDAQ is
8 15
U.S.C. 78f.
U.S.C. 78f(b)(4), (5).
10 Securities Exchange Act Release No. 51808
(June 9, 2005), 70 FR 37496 (June 29, 2005).
9 15
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able to charge is constrained by the
existence of substitutes in the form of
SIP data and competitive products
offered by other SROs.
The decision of the United States
Court of Appeals for the District of
Columbia Circuit in NetCoalition v.
SEC, 615 F.3d 525 (D.C. Cir. 2010)
(‘‘NetCoalition I’’), 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 I, at 535 (quoting
H.R. Rep. No. 94–229, at 92 (1975), as
reprinted in 1975 U.S.C.C.A.N. 321,
323). The court agreed with the
Commission’s conclusion that
‘‘Congress intended that ‘competitive
forces should dictate the services and
practices that constitute the U.S.
national market system for trading
equity securities.’ ’’ 11
The Court in NetCoalition I, while
upholding the Commission’s conclusion
that competitive forces may be relied
upon to establish the fairness of prices,
nevertheless concluded that the record
in that case did not adequately support
the Commission’s conclusions as to the
competitive nature of the market for
NYSE Arca’s data product at issue in
that case. As explained below in
NASDAQ’s Statement on Burden on
Competition, however, NASDAQ
believes that there is substantial
evidence of competition in the
marketplace for data that was not in the
record in the NetCoalition I case, and
that the Commission is entitled to rely
upon such evidence in concluding fees
are the product of competition, and
therefore in accordance with the
relevant statutory standards.12
Moreover, NASDAQ further notes that
the product at issue in this filing—a
NASDAQ quotation and last sale data
product that replicates a subset of the
information available through ‘‘core’’
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11 NetCoalition
I, at 535.
should also be noted that Section 916 of the
Dodd-Frank Wall Street Reform and Consumer
Protection Act of 2010 (‘‘Dodd-Frank Act’’) has
amended paragraph (A) of Section 19(b)(3) of the
Act, 15 U.S.C. 78s(b)(3), to make it clear that all
exchange fees, including fees for market data, may
be filed by exchanges on an immediately effective
basis. See also NetCoalition v. SEC, 715 F.3d 342
(D.C. Cir. 2013) (‘‘NetCoalition II’’) (finding no
jurisdiction to review Commission’s nonsuspension of immediately effective fee changes).
12 It
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data products whose fees have been
reviewed and approved by the SEC—is
quite different from the NYSE Arca
depth-of-book data product at issue in
NetCoalition I. Accordingly, any
findings of the court with respect to that
product may not be relevant to the
product at issue in this filing. As the
Commission noted in approving the
initial pilot for NASDAQ Basic, all of
the information available in NASDAQ
Basic is included in the core data feeds
made available pursuant to the jointSRO plans.13 As the Commission further
determined, ‘‘the availability of
alternatives to NASDAQ Basic
significantly affect the terms on which
NASDAQ can distribute this market
data. In setting the fees for its NASDAQ
Basic service, NASDAQ must consider
the extent to which market participants
would choose one or more alternatives
instead of purchasing the exchange’s
data.’’ 14 Thus, to the extent that the fees
for core data have been established as
reasonable under the Act, it follows that
the fees for NASDAQ Basic are also
reasonable, since charging unreasonably
high fees would cause market
participants to rely solely on core data
or purchase proprietary products offered
by other exchanges rather than
purchasing NASDAQ Basic.
Moreover, as discussed in the order
approving the initial pilot, and as
further discussed below in NASDAQ’s
Statement on Burden on Competition,
data products such as NASDAQ Basic
are a means by which exchanges
compete to attract order flow. To the
extent that exchanges are successful in
such competition, they earn trading
revenues and also enhance the value of
their data products by increasing the
amount of data they are able to provide.
Conversely, to the extent that exchanges
are unsuccessful, the inputs needed to
add value to data products are
diminished. Accordingly, the need to
compete for order flow places
substantial pressure upon exchanges to
keep their fees for both executions and
data reasonable.
The enterprise license provides a
means by which broker-dealers may
reduce their fees for usage of NASDAQ
Basic by a large number of internal
Professional Subscribers. Accordingly,
the license provides a means of
providing ensuring [sic] that the overall
fees for NASDAQ Basic paid by such
broker-dealers are reasonable. The
proposed change does not alter the
reasonableness of the fees, since it will
13 Securities Exchange Act Release No. 12425
(March 16, 2009), 74 FR 12423, 12425 (March 24,
2009) (SR–NASDAQ–2008–102).
14 Id. at 12425.
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28577
help to ensure that broker-dealers do not
abuse the intent of the license by taking
receiving NASDAQ Basic through
multiple External Distributors under a
single fixed-fee license. Rather, the
change will ensure that licensees that
opt to obtain data through multiple
External Distributors pay a license fee
that is proportion [sic] to that usage.
Similarly, the Per Query fee cap is a
means of ensuring that the overall fees
for NASDAQ Basic paid by individual
Non-Professional users are reasonable.
Both the Per Query fee and the monthly
Non-Professional Subscriber fees are
used to limit the costs borne by NonProfessional users. NASDAQ’s current
proposal ensures that the two fees
interact in a manner that is fair to NonProfessional users. Likewise, while the
fees for Professional Users of NASDAQ
Basic are higher than for NonProfessionals, NASDAQ believes that
the monthly fee and the Per Query fee
must still interact in a manner that is
fair to Professional users and that the
proposed fee cap satisfies that
requirement.
The changed fee also continues to
reflect an equitable allocation and
continues not to be unfairly
discriminatory, because NASDAQ Basic
is a voluntary product for which market
participants can readily substitute core
data feeds that provide additional
quotation and last sale information not
available through NASDAQ Basic.
Accordingly, NASDAQ is constrained
from pricing the product in a manner
that would be inequitable or unfairly
discriminatory. The enterprise license
helps to ensure that fees for professional
users are not inequitable or unfairly
discriminatory, because they are subject
to limitations that will enable brokerdealers with large numbers of
subscribers to moderate the fees that
they would otherwise be required to
pay. The change being made to the
license fee does not render the fee
inequitable or unfairly discriminatory,
but rather ensures that each broker pays
a fair fee with respect to each External
Distributor from which it receives
NASDAQ Basic. Specifically, the fee
will ensure that a broker-dealer that opts
to receive NASDAQ Basic through more
than one External Distributor pays a fee
that equitably reflects additional usage,
rather than paying the same paid [sic]
by a broker receiving the product
through only one External Distributor.
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
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of the purposes of the Act, as amended.
NASDAQ’s ability to price NASDAQ
Basic is constrained by (1) competition
among exchanges, other trading
platforms, and TRFs that compete with
each other in a variety of dimensions;
(2) the existence of inexpensive realtime consolidated data and marketspecific data and free delayed
consolidated data; and (3) the inherent
contestability of the market for
proprietary data.
The market for proprietary data
products is currently 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.
Similarly, with respect to the TRF data
component of NASDAQ Basic, allowing
exchanges to operate TRFs has
permitted them to earn revenues by
providing technology and data in
support of the non-exchange segment of
the market. This revenue opportunity
has also resulted in fierce competition
between the two current TRF operators,
with both TRFs charging extremely low
trade reporting fees and rebating the
majority of the revenues they receive
from core market data to the parties
reporting trades.
Transaction executions 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.15 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 trade
executions, exchange data products
cannot exist. Moreover, data products
are valuable to many end users only
insofar as they provide information that
end users expect will assist them or
their customers in making trading
decisions.
The costs of producing market data
include not only the costs of the data
distribution infrastructure, but also the
costs of designing, maintaining, and
operating the exchange’s transaction
execution platform and the cost of
regulating the exchange to ensure its fair
operation and maintain investor
confidence. The total return that a
trading platform earns reflects the
revenues it receives from both products
and the joint costs it incurs. Moreover,
the operation of the exchange is
characterized by high fixed costs and
low marginal costs. This cost structure
is common in content and content
distribution industries such as software,
where developing new software
typically requires a large initial
investment (and continuing large
investments to upgrade the software),
but once the software is developed, the
incremental cost of providing that
software to an additional user is
typically small, or even zero (e.g., if the
software can be downloaded over the
internet after being purchased).16 In
NASDAQ’s case, it is costly to build and
maintain a trading platform, but the
incremental cost of trading each
additional share on an existing platform,
or distributing an additional instance of
data, is very low. Market information
and executions are each produced
jointly (in the sense that the activities of
trading and placing orders are the
source of the information that is
distributed) and are each subject to
significant scale economies. In such
cases, marginal cost pricing is not
feasible because if all sales were priced
at the margin, NASDAQ would be
unable to defray its platform costs of
providing the joint products. Similarly,
data products cannot make use of TRF
trade reports without the raw material of
the trade reports themselves, and
therefore necessitate the costs of
operating, regulating,17 and maintaining
a trade reporting system, costs that must
be covered through the fees charged for
use of the facility and sales of associated
data.
An exchange’s BD customers view the
costs of transaction executions and of
data as a unified cost of doing business
with the exchange. A BD will direct
15 A complete explanation of the pricing
dynamics associated with joint products is
presented in a study that NASDAQ originally
submitted to the Commission in SR–NASDAQ–
2011–010. See Statement of Janusz Ordover and
Gustavo Bamberger at 2–17 (December 29, 2010)
(available at https://nasdaq.cchwallstreet.com/
NASDAQ/pdf/nasdaq-filings/2011/SR-NASDAQ2011-010.pdf).
16 See William J. Baumol and Daniel G. Swanson,
‘‘The New Economy and Ubiquitous Competitive
Price Discrimination: Identifying Defensible Criteria
of Market Power,’’ Antitrust Law Journal, Vol. 70,
No. 3 (2003).
17 It should be noted that the costs of operating
the FINRA/NASDAQ TRF borne by NASDAQ
include regulatory charges paid by NASDAQ to
FINRA.
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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 BD 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 BD will choose not to buy it.
Moreover, as a BD chooses to direct
fewer orders to a particular exchange,
the value of the product to that BD
decreases, for two reasons. First, the
product will contain less information,
because executions of the BD’s trading
activity will not be reflected in it.
Second, and perhaps more important,
the product will be less valuable to that
BD because it does not provide
information about the venue to which it
is directing its orders. Data from the
competing venue to which the BD is
directing orders will become
correspondingly more valuable.
Similarly, in the case of products such
as NASDAQ Basic that may be
distributed through market data
vendors, the vendors provide price
discipline for proprietary data products
because they control a means of access
to end users. 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 users 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 BDs, such as Charles 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. Exchanges,
TRFs, 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.
Moreover, NASDAQ believes that
products such as NASDAQ Basic can
enhance order flow to NASDAQ by
providing more widespread distribution
of information about transactions in real
time, thereby encouraging wider
participation in the market by investors
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with access to the data through their
brokerage firm or other distribution
sources. Conversely, the value of such
products to distributors and investors
decreases if order flow falls, because the
products contain less content.
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
exchange data without a fast,
technologically robust, and wellregulated 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. Similarly, the inclusion
of trade reporting data in a product such
as NASDAQ Basic may assist in
attracting customers to the product,
thereby assisting in covering the
additional costs associated with
operating and regulating a TRF.
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.
NASDAQ pays rebates to attract orders,
charges relatively low prices for market
information and charges relatively high
prices for accessing posted liquidity.
Other platforms may choose a strategy
of paying lower liquidity rebates to
attract orders, setting relatively low
prices for accessing posted liquidity,
and setting relatively high prices for
market information. Still others may
provide most data free of charge and
rely exclusively on transaction fees to
recover their costs. Finally, some
platforms may incentivize use by
providing opportunities for equity
ownership, which may allow them to
charge lower direct fees for executions
and data.
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. Such regulation is
unnecessary because an ‘‘excessive’’
price for one of the joint products will
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20:00 May 15, 2014
Jkt 232001
ultimately have to be reflected in lower
prices for other products sold by the
firm, or otherwise the firm will
experience a loss in the volume of its
sales that will be adverse to its overall
profitability. In other words, an
unreasonable increase in the price of
data will ultimately have to be
accompanied by a decrease in the cost
of executions, or the volume of both
data and executions will fall.
The level of competition and
contestability in the market is evident in
the numerous alternative venues that
compete for order flow, including
thirteen 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 TRFs compete
to attract internalized transaction
reports. It is common for BDs to further
and exploit this competition by sending
their order flow and transaction reports
to multiple markets, rather than
providing them all to a single market.
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 MKT, NYSE Arca, BATS, and
Direct Edge.
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 BDs’ production of
proprietary data products. The potential
sources of proprietary products are
virtually limitless. Notably, the
potential sources of data include the
BDs that submit trade reports to TRFs
and that have the ability to consolidate
and distribute their data without the
involvement of FINRA or an exchangeoperated TRF.
The fact that proprietary data from
ATSs, BDs, and vendors can by-pass
SROs is significant in two respects.
First, non-SROs can compete directly
with SROs for the production and sale
of proprietary data products, as BATS
and Arca did before registering as
exchanges by publishing proprietary
book data on the internet. Second,
PO 00000
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28579
because a single order or transaction
report can appear in a core data product,
an SRO proprietary product, and/or a
non-SRO proprietary product, the data
available in proprietary products is
exponentially greater than the actual
number of orders and transaction
reports that exist in the marketplace.
Indeed, in the case of NASDAQ Basic,
the data provided through that product
appears both in (i) real-time core data
products offered by the SIPs for a fee,
and (ii) free SIP data products with a 15minute time delay, and finds a close
substitute in similar products of
competing venues.
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 BDs have previously
published their proprietary data
individually, Regulation NMS
encourages market data vendors and
BDs 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. In Europe, Markit
aggregates and disseminates data from
over 50 brokers and multilateral trading
facilities.18
In the case of TRFs, the rapid entry of
several exchanges into this space in
2006–2007 following the development
and Commission approval of the TRF
structure demonstrates the
contestability of this aspect of the
market.19 Given the demand for trade
reporting services that is itself a byproduct of the fierce competition for
transaction executions—characterized
notably by a proliferation of ATSs and
BDs offering internalization—any supracompetitive increase in the fees
18 https://www.markit.com/en/products/data/boat/
boat-boat-data.page.
19 The low cost exit of two TRFs from the market
is also evidence of a contestible market, because
new entrants are reluctant to enter a market where
exit may involve substantial shut-down costs.
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associated with trade reporting or TRF
data would shift trade report volumes
from one of the existing TRFs to the
other 20 and create incentives for other
TRF operators to enter the space.
Alternatively, because BDs reporting to
TRFs are themselves free to consolidate
the market data that they report, the
market for over-the-counter data itself,
separate and apart from the markets for
execution and trade reporting services—
is fully contestable.
Moreover, consolidated data provides
substantial pricing discipline for
proprietary data products that are a
subset of the consolidated data stream.
Because consolidated data contains
marketwide information, it effectively
places a cap on the fees assessed for
proprietary data (such as quotation and
last sale data) that is simply a subset of
the consolidated data. The availability
provides a powerful form of pricing
discipline for proprietary data products
that contain data elements that are a
subset of the consolidated data, by
highlighting the optional nature of
proprietary products.
The competitive nature of the market
for non-core ‘‘sub-set’’ products such as
NASDAQ Basic is borne out by the
performance of the market. In May 2008,
the internet portal Yahoo! began offering
its Web site viewers real-time last sale
data (as well as best quote data)
provided by BATS. In June 2008,
NASDAQ launched NLS, which was
initially subject to an ‘‘enterprise cap’’
of $100,000 for customers receiving only
one of the NLS products, and $150,000
for customers receiving both products.
The majority of NASDAQ’s sales were at
the capped level. In early 2009, BATS
expanded its offering of free data to
include depth-of-book data. Also in
early 2009, NYSE Arca announced the
launch of a competitive last sale product
with an enterprise price of $30,000 per
month. In response, NASDAQ combined
the enterprise cap for the NLS products
and reduced the cap to $50,000 (i.e., a
reduction of $100,000 per month).
Similarly, the enterprise license and
netting option being offered for
NASDAQ Basic through this proposed
rule change reflects a means by which
the overall cost of the product is limited
in accordance with the existence of
competitive alternatives, including both
core and proprietary data.
20 It should be noted that the FINRA/NYSE TRF
has, in recent weeks, received reports for over 10%
of all over-the-counter volume in NMS stocks. In
addition, FINRA has announced plans to update its
Alternative Display Facility, which is also able to
receive over-the-counter trade reports. See
Securities Exchange Act Release No. 70048 (July 26,
2013), 78 FR 46652 (August 1, 2013) (SR–FINRA–
2013–031).
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In this environment, a supercompetitive 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 I at 539. The existence of
fierce competition for order flow
implies a high degree of price sensitivity
on the part of BDs with order flow, since
they may readily reduce costs by
directing orders toward the lowest-cost
trading venues. A BD 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. If a
platform increases its market data fees,
the change will affect the overall cost of
doing business with the platform, and
affected BDs will assess whether they
can lower their trading costs by
directing orders elsewhere and thereby
lessening the need for the more
expensive data. Similarly, increases in
the cost of NASDAQ Basic would
impair the willingness of distributors to
take a product for which there are
numerous alternatives, impacting
NASDAQ Basic data revenues, the value
of NASDAQ Basic as a tool for attracting
order flow, and ultimately, the volume
of orders routed to NASDAQ and
reported to the FINRA/NASDAQ TRF
and the value of its other data products.
Competition has also driven NASDAQ
continually to improve its data offerings
and to cater to customers’ data needs.
The NASDAQ Basic product itself is a
product of this competition, offering a
subset of core data to users that may not
wish to receive or pay for all
consolidated data.
The existence of numerous
alternatives to NASDAQ Basic,
including real-time consolidated data,
free delayed consolidated data, and
proprietary data from other sources
ensures that NASDAQ cannot set
unreasonable fees, or fees that are
unreasonably discriminatory, without
losing business to these alternatives.
Accordingly, NASDAQ believes that the
acceptance of the NASDAQ Basic
product in the marketplace
demonstrates the consistency of these
fees with applicable statutory standards.
Likewise, the fee changes proposed
herein will be subject to these same
competitive forces. If the proposed fee
increase is excessive, or if the proposals
for an enterprise license and netting are
unattractive to market participants, only
NASDAQ will suffer, since its
customers will merely migrate to
competitive alternatives.
PO 00000
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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)
of the Act 21 and paragraph (f) of Rule
19b-4 thereunder.22 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.
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–2014–045 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NASDAQ–2014–045. 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
21 15
22 17
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U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f).
16MYN1
Federal Register / Vol. 79, No. 95 / Friday, May 16, 2014 / Notices
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE.,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office 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–2014–045 and should be
submitted on or before June 6, 2014.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend
Section 902.02 of the Listed Company
Manual (the ‘‘Manual’’) to modify how
it calculates annual fees for certain
issuers in their first year of listing on the
Exchange. Such modification will result
in large issuers receiving a reduction in
their first year’s annual fee that is
proportional to their reduced time listed
on the Exchange. The text of the
proposed rule change is available on the
Exchange’s Web site at www.nyse.com,
at the principal office of the Exchange,
and at the Commission’s Public
Reference Room.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.23
Kevin M. O’Neill,
Deputy Secretary.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
self-regulatory organization included
statements concerning the purpose of,
and basis for, the proposed rule change
and discussed any comments it received
on the proposed rule change. The text
of those statements may be examined at
the places specified in Item IV below.
The Exchange has prepared summaries,
set forth in sections A, B, and C below,
of the most significant parts of such
statements.
[FR Doc. 2014–11296 Filed 5–15–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–72147; File No. SR–NYSE–
2014–24]
Self-Regulatory Organizations; New
York Stock Exchange LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change Amending
Section 902.02 of the Listed Company
Manual To Modify How It Calculates
Annual Fees for Certain Issuers in
Their First Year of Listing on the
Exchange Which Will Result in Large
Issuers Receiving a Reduction in Their
First Year’s Annual Fee That Is
Proportional to Their Reduced Time
Listed on the Exchange
EMCDONALD on DSK67QTVN1PROD with NOTICES
May 12, 2014.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934 (the
‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that, on May 6,
2014, New York Stock Exchange LLC
(‘‘NYSE’’ or the ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (the ‘‘Commission’’) the
proposed rule change as described in
Items I, II, and III below, which Items
have been prepared by the selfregulatory organization. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
23 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 15 U.S.C. 78a.
3 17 CFR 240.19b–4.
20:00 May 15, 2014
1. Purpose
The Exchange proposes to amend
Section 902.02 of the Manual to modify
how it calculates annual fees for certain
issuers in their first year of listing on the
Exchange. Such modification will result
in large issuers receiving a reduction in
their first year’s annual fee that is
proportional to their reduced time listed
on the Exchange.
Pursuant to Section 902.02 of the
Manual, listed companies are charged
an annual fee for each class or series of
security listed on the Exchange. The
annual fee is calculated based on the
number of shares issued and
outstanding, including treasury stock
and restricted stock.4 In its first year of
listing, a company’s annual fee is
prorated from the date of initial listing
through the year end.
Listed companies also pay other fees
to the Exchange, including fees
associated with initial and
4 Currently, the annual fee for a listed company’s
primary class of common shares is $0.00093 per
share, subject to a minimum total annual fee of
$42,000.
1 15
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A. Self-Regulatory Organization’s
Statement of the Purpose of, and the
Statutory Basis for, the Proposed Rule
Change
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supplemental listing applications. In
any given calendar year, however,
Section 902.02 of the Manual specifies
that the total fees that the Exchange may
bill a listed company are capped at
$500,000 (the ‘‘Total Maximum Fee’’).
Therefore, a large company with a
significant number of shares
outstanding whose annual fee would
otherwise exceed $500,000 will only be
billed the Total Maximum Fee for that
year. Similarly, a company whose
annual fee is below $500,000 will only
incur additional fees (with respect to
supplemental listing applications, for
example) up to the Total Maximum Fee.
As noted above, the Exchange
prorates an [sic] company’s annual fee
in its first year of listing. Currently, the
Exchange determines a newly listed
company’s prorated annual fee by
calculating what the company’s annual
fee would be if it were listed for the
entire calendar year and then charging
only that percentage that corresponds to
the period from the date of initial listing
through the year end. If a listed
company’s prorated annual fee exceeds
$500,000 it is only charged that portion
of the annual fee that, when aggregated
with any other fees it has already been
billed by the Exchange, brings it to the
Total Maximum Fee, and it will not
incur any additional fees during the
calendar year. If a company’s prorated
annual fee is below $500,000 it would
pay the full amount of such prorated
annual fee and continue to incur
additional fees until it hits the Total
Maximum Fee.
By way of example, assume Company
A lists on the Exchange on July 1. If
Company A had been listed on the
Exchange for the entire calendar year,
its annual fee would be $2,000,000.
Because it will be listed for only six
months, however, Company A’s annual
fee is prorated to $1,000,000. Under its
current policy, the Exchange then
applies the Total Maximum Fee and
bills Company A only $500,000 of its
prorated annual fee. Because Company
A has hit the Total Maximum Fee, it
will not incur any additional fees (with
respect to supplemental listing
applications, for example) during that
calendar year.
Assume Company B also lists on the
Exchange on July 1. If Company B had
been listed on the Exchange for the
entire calendar year, its annual fee
would be $800,000. Because it will be
listed for only six months, however,
Company B’s annual fee is prorated to
$400,000. Under the Exchange’s current
policy, Company B will be billed the
$400,000 prorated annual fee and will
continue to incur additional fees (with
respect to supplemental listing
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Agencies
[Federal Register Volume 79, Number 95 (Friday, May 16, 2014)]
[Notices]
[Pages 28575-28581]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-11296]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-72153; File No. SR-NASDAQ-2014-045]
Self-Regulatory Organizations; The NASDAQ Stock Market LLC;
Notice of Filing and Immediate Effectiveness of Proposed Rule Change To
Modify Fees for the NASDAQ Basic Data Product
May 12, 2014.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(the ``Act''),\1\ and Rule 19b-4 thereunder,\2\ notice is hereby given
that on April 30, 2014, The NASDAQ Stock Market LLC (``NASDAQ'' or the
``Exchange'') filed with the Securities and Exchange Commission
(``Commission'') the proposed rule change as described in Items I and
II below, which Items have been prepared by the Exchange. The
Commission is publishing this notice to solicit comments on the
proposed rule change from interested persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
NASDAQ is proposing modify [sic] fees for the NASDAQ Basic data
product. The proposal, which modifies monthly fees, is effective for
the month of May 2014 and subsequent months. The text of the proposed
rule change is available on the Exchange's Web site at https://nasdaq.cchwallstreet.com, at the principal office of the Exchange, and
at the Commission's Public Reference Room.
II. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
In its filing with the Commission, the self-regulatory organization
included statements concerning the purpose of, and basis for, the
proposed rule change and discussed any comments it received on the
proposed rule change. The text of those statements may be examined at
the places specified in Item IV below. The Exchange has prepared
summaries, set forth in sections A, B, and C below, of the most
significant parts 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 two modifications to the fees for NASDAQ Basic:
(1) To cap the ``per query'' fee paid by a single user at the level of
the monthly fee paid by monthly Professional and Non-Professional
subscribers and (2) to clarify the application of the recently-filed
Enterprise License fee where a single firm receives data from multiple
External Distributors.
Background. NASDAQ Basic is a proprietary data product that
provides best bid and offer information from the NASDAQ Market Center
and last sale transaction reports from the NASDAQ Market Center and
from the FINRA/NASDAQ Trade Reporting Facility (``FINRA/NASDAQ TRF'').
As such, NASDAQ Basic provides a subset of the ``core'' quotation and
last sale data provided by securities information processors (``SIPs'')
under the CQ/CT Plan and the NASDAQ UTP Plan. Earlier this year, NASDAQ
introduced a new enterprise license for Professional Subscribers to
NASDAQ Basic.\3\ In this proposed rule change, NASDAQ is proposing a
minor refinement to the enterprise license.
---------------------------------------------------------------------------
\3\ Securities Exchange Act Release No. 71507 (February 7,
2014), 79 FR 8763 (February 13, 2014) (SR-NASDAQ-2014-011).
---------------------------------------------------------------------------
NASDAQ Basic contains three separate components, which may be
purchased individually or in combination: (i) NASDAQ Basic for NASDAQ,
which contains the best bid and offer on the NASDAQ Market Center and
last sale transaction reports for NASDAQ and the FINRA/NASDAQ TRF for
NASDAQ-listed stocks, (ii) NASDAQ Basic for NYSE, which covers NYSE-
listed stocks, and (iii) NASDAQ Basic for NYSE MKT, which covers stocks
listed on NYSE MKT and other listing venues whose quotes and trade
reports are disseminated on Tape B.
Per Query Fee Cap. The fee structure for NASDAQ Basic features a
fee for Professional Subscribers and a reduced fee for Non-Professional
Subscribers.\4\ The current monthly fees for Non-Professional
Subscribers are $0.50 per Subscriber for NASDAQ Basic for NASDAQ, $0.25
per Subscriber for NASDAQ Basic for NYSE, and $0.25 per Subscriber for
NASDAQ Basic for NYSE MKT. The current monthly fees for Professional
Subscribers are $13 per Subscriber for NASDAQ Basic for NASDAQ, $6.50
per Subscriber for NASDAQ Basic for NYSE, and $6.50 per Subscriber for
NASDAQ Basic for NYSE MKT. For use cases that do not require a monthly
subscription for unlimited usage, there is a Per Query option, with a
fee of $0.0025 for NASDAQ Basic for NASDAQ, $0.0015 for NASDAQ Basic
for NYSE, and $0.0015 for NASDAQ Basic for NYSE MKT.
---------------------------------------------------------------------------
\4\ A ``Non-Professional Subscriber'' is ``a natural person who
is not (i) registered or qualified in any capacity with the
Commission, the Commodity Futures Trading Commission, any state
securities agency, any securities exchange or association, or any
commodities or futures contract market or association; (ii) engaged
as an ``investment adviser'' as that term is defined in Section
201(11) of the Investment Advisers Act of 1940 (whether or not
registered or qualified under that Act); or (iii) employed by a bank
or other organization exempt from registration under federal or
state securities laws to perform functions that would require
registration or qualification if such functions were performed for
an organization not so exempt.'' A ``Professional Subscriber'' is
``any Subscriber other than a Non-Professional Subscriber.''
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Distributors \5\ of NASDAQ Basic may also be assessed a monthly
Distributor Fee. The fee is $1,500 per month for either internal or
external distribution; however, a credit for Subscriber or Per Query
fees may be applied against the Distributor Fee at the Distributor's
request.
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\5\ The term ``Distributor'' ``refers to any entity that
receives NASDAQ Basic data directly from NASDAQ or indirectly
through another entity and then distributes it to one or more
Subscribers.'' Distributors may either be ``Internal Distributors'',
which are ``Distributors that receive NASDAQ Basic data and then
distribute that data to one or more Subscribers within the
Distributor's own entity,'' or ``External Distributors'', which are
``Distributors that receive NASDAQ Basic data and then distribute
that data to one or more Subscribers outside the Distributor's own
entity.''
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NASDAQ is proposing to cap the ``per query'' fee paid by a single
user at the level of the monthly fee paid by monthly subscribers. The
fee structure for NASDAQ Basic features a fee for Professional
Subscribers and a reduced fee for Non-Professional Subscribers. The
current monthly fees for Non-Professional Subscribers are $0.50 per
Subscriber for NASDAQ Basic for NASDAQ, while the Per Query fee is
$0.0025 for NASDAQ Basic for NASDAQ. Under NASDAQ's proposal, a Non-
Professional user would pay the Per Query fee for the first 199 queries
during the month. However, if the Subscriber made 200 or more queries
during the month, the cap would take effect, such that the total
aggregate monthly charge for all queries by the Subscriber would be
$0.50. For NASDAQ Basic for NYSE and NYSE MKT, the corresponding
breakpoint for
[[Page 28576]]
Non-Professionals would occur at 167th query.
With respect to Professional users, under NASDAQ's proposal, a
Professional user of NASDAQ Basic for NASDAQ stocks would pay the Per
Query fee for the first 5,199 queries, but the cap would thereafter
take effect, such that the total aggregate monthly charge for all
queries by the Subscriber would be $13. For NASDAQ Basic for NYSE and
MKT stocks, the breakpoint for Professional Users would occur at 4,333
queries and the cap would thereafter take effect, such that the total
aggregate monthly charge for all queries by the Subscriber would be
$6.50.
Enterprise License Clarification. As an alternative to monthly
Subscriber fees for Non-Professional Subscribers, NASDAQ also offers an
enterprise license under which a broker-dealer may distribute NASDAQ
Basic to an unlimited number of Non-Professional Subscribers with whom
the broker-dealer has a brokerage relationship at a rate of $100,000
per month (as well as the applicable monthly Distributor fee). In
addition, a Distributor of data derived from NASDAQ Basic (but not
NASDAQ Basic itself) may pay a fee of $1,500 per month (plus the
applicable monthly Distributor fee) to distribute the derived data to
an unlimited number of Non-Professional Subscribers. This type of
Distributor will typically distribute data to a large number of
downstream customers through web-based applications.
Under new net reporting rules adopted earlier this year,\6\
Distributors may reduce the overall number of internal Professional
Subscribers deemed to be fee liable with respect to ``Display Usage''
of NASDAQ Basic: \7\
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\6\ See supra n. 3.
\7\ ``Display Usage'' means ``any method of accessing NASDAQ
Basic data that involves the display of such data on a screen or
other visualization mechanism for access or use by a natural person
or persons.'' Netting does not apply to uses other than Display
Usage (i.e., use by an automated device without visual access by
natural persons).
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A Subscriber that receives access to NASDAQ Basic through
multiple products controlled by an Internal Distributor is considered
one Subscriber. Thus, if a broker-dealer acts as a Distributor of
NASDAQ Basic in multiple forms to its employees, each employee would be
considered one Subscriber.
A Subscriber that receives access to NASDAQ Basic through
multiple products controlled by one External Distributor is considered
one Subscriber. Thus, if a broker-dealer arranges for its employees to
receive access to multiple NASDAQ Basic products provided by a single
vendor, each employee would be considered one Subscriber.
A Subscriber that receives access to NASDAQ Basic through
one or more products controlled by an Internal Distributor and also one
or more products controlled by one External Distributor is considered
one Subscriber. Thus, if the broker-dealer provides employees with
access through its own product(s) and through products from a single
vendor, each employee is still considered one Subscriber.
A Subscriber that receives access to NASDAQ Basic through
one or more products controlled by an Internal Distributor and also
products controlled by multiple External Distributors is treated as one
Subscriber with respect to the products controlled by the Internal
Distributor and one of the External Distributors, and is treated as an
additional Subscriber for each additional External Distributor. Thus, a
Subscriber receiving products through an Internal Distributor and two
External Distributors is treated as two Subscribers.
At the same time, NASDAQ also adopted a new enterprise license for
Professional Subscribers. Under the enterprise license, a broker-dealer
may distribute NASDAQ Basic for NASDAQ, NASDAQ Basic for NYSE, and
NASDAQ Basic for NYSE MKT for a flat fee of $365,000 per month;
provided, however, that if the broker-dealer obtains the license with
respect to usage of NASDAQ Basic provided by an External Distributor
that controls display of the product, the fee will be $365,000 per
month for up to 16,000 internal Professional Subscribers, plus $2 for
each additional internal Professional Subscriber over 16,000.
NASDAQ is proposing to adopt clarifying language in the rule
governing the enterprise license to make it clear that a license would
cover only one External Distributor that controls display. Thus, if a
broker-dealer used NASDAQ Basic provided by more than one such External
Distributor, it would be required to obtain a separate enterprise
license for each External Distributor. Alternatively, it could
designate that the enterprise license covered one External Distributor
and pay regular per-Subscriber fees with respect to other External
Distributor(s). The change to rule language is necessary to ensure that
the rule reflects NASDAQ's original intent with regard to the scope of
the enterprise license. Specifically, the license is intended to
provide broker-dealers with a cost-effective means of obtaining NASDAQ
Basic for internal users, but is not intended to allow it to obtain the
product through multiple External Distributors at the same fee it would
pay for just one External Distributor.
2. Statutory Basis
NASDAQ believes that the proposed rule change is consistent with
the provisions of Section 6 of the Act \8\ in general, and with
Sections 6(b)(4) and (5) of the Act \9\ in particular, in that it
provides for the equitable allocation of reasonable dues, fees and
other charges among recipients of NASDAQ data and is not designed to
permit unfair discrimination between them. In adopting Regulation NMS,
the Commission granted self-regulatory organizations (``SROs'') and
broker-dealers (``BDs'') 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.
NASDAQ believes that its NASDAQ Basic market data product is precisely
the sort of market data product that the Commission envisioned when it
adopted Regulation NMS. 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:
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\8\ 15 U.S.C. 78f.
\9\ 15 U.S.C. 78f(b)(4), (5).
[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.\10\
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\10\ 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 at all,
it follows that the price at which such data is sold should be set by
the market as well. NASDAQ Basic exemplifies the optional nature of
proprietary data, since, depending on a customer's specific goals, it
may opt to purchase core SIP data or only the subset provided through
NASDAQ Basic. Moreover, as discussed in more detail below, the price
that NASDAQ is
[[Page 28577]]
able to charge is constrained by the existence of substitutes in the
form of SIP data and competitive products offered by other SROs.
The decision of the United States Court of Appeals for the District
of Columbia Circuit in NetCoalition v. SEC, 615 F.3d 525 (D.C. Cir.
2010) (``NetCoalition I''), 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 I, at 535 (quoting H.R. Rep. No. 94-229, at 92 (1975), as
reprinted in 1975 U.S.C.C.A.N. 321, 323). The court agreed with the
Commission's conclusion that ``Congress intended that `competitive
forces should dictate the services and practices that constitute the
U.S. national market system for trading equity securities.' '' \11\
---------------------------------------------------------------------------
\11\ NetCoalition I, at 535.
---------------------------------------------------------------------------
The Court in NetCoalition I, while upholding the Commission's
conclusion that competitive forces may be relied upon to establish the
fairness of prices, nevertheless concluded that the record in that case
did not adequately support the Commission's conclusions as to the
competitive nature of the market for NYSE Arca's data product at issue
in that case. As explained below in NASDAQ's Statement on Burden on
Competition, however, NASDAQ believes that there is substantial
evidence of competition in the marketplace for data that was not in the
record in the NetCoalition I case, and that the Commission is entitled
to rely upon such evidence in concluding fees are the product of
competition, and therefore in accordance with the relevant statutory
standards.\12\ Moreover, NASDAQ further notes that the product at issue
in this filing--a NASDAQ quotation and last sale data product that
replicates a subset of the information available through ``core'' data
products whose fees have been reviewed and approved by the SEC--is
quite different from the NYSE Arca depth-of-book data product at issue
in NetCoalition I. Accordingly, any findings of the court with respect
to that product may not be relevant to the product at issue in this
filing. As the Commission noted in approving the initial pilot for
NASDAQ Basic, all of the information available in NASDAQ Basic is
included in the core data feeds made available pursuant to the joint-
SRO plans.\13\ As the Commission further determined, ``the availability
of alternatives to NASDAQ Basic significantly affect the terms on which
NASDAQ can distribute this market data. In setting the fees for its
NASDAQ Basic service, NASDAQ must consider the extent to which market
participants would choose one or more alternatives instead of
purchasing the exchange's data.'' \14\ Thus, to the extent that the
fees for core data have been established as reasonable under the Act,
it follows that the fees for NASDAQ Basic are also reasonable, since
charging unreasonably high fees would cause market participants to rely
solely on core data or purchase proprietary products offered by other
exchanges rather than purchasing NASDAQ Basic.
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\12\ It should also be noted that Section 916 of the Dodd-Frank
Wall Street Reform and Consumer Protection Act of 2010 (``Dodd-Frank
Act'') has amended paragraph (A) of Section 19(b)(3) of the Act, 15
U.S.C. 78s(b)(3), to make it clear that all exchange fees, including
fees for market data, may be filed by exchanges on an immediately
effective basis. See also NetCoalition v. SEC, 715 F.3d 342 (D.C.
Cir. 2013) (``NetCoalition II'') (finding no jurisdiction to review
Commission's non-suspension of immediately effective fee changes).
\13\ Securities Exchange Act Release No. 12425 (March 16, 2009),
74 FR 12423, 12425 (March 24, 2009) (SR-NASDAQ-2008-102).
\14\ Id. at 12425.
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Moreover, as discussed in the order approving the initial pilot,
and as further discussed below in NASDAQ's Statement on Burden on
Competition, data products such as NASDAQ Basic are a means by which
exchanges compete to attract order flow. To the extent that exchanges
are successful in such competition, they earn trading revenues and also
enhance the value of their data products by increasing the amount of
data they are able to provide. Conversely, to the extent that exchanges
are unsuccessful, the inputs needed to add value to data products are
diminished. Accordingly, the need to compete for order flow places
substantial pressure upon exchanges to keep their fees for both
executions and data reasonable.
The enterprise license provides a means by which broker-dealers may
reduce their fees for usage of NASDAQ Basic by a large number of
internal Professional Subscribers. Accordingly, the license provides a
means of providing ensuring [sic] that the overall fees for NASDAQ
Basic paid by such broker-dealers are reasonable. The proposed change
does not alter the reasonableness of the fees, since it will help to
ensure that broker-dealers do not abuse the intent of the license by
taking receiving NASDAQ Basic through multiple External Distributors
under a single fixed-fee license. Rather, the change will ensure that
licensees that opt to obtain data through multiple External
Distributors pay a license fee that is proportion [sic] to that usage.
Similarly, the Per Query fee cap is a means of ensuring that the
overall fees for NASDAQ Basic paid by individual Non-Professional users
are reasonable. Both the Per Query fee and the monthly Non-Professional
Subscriber fees are used to limit the costs borne by Non-Professional
users. NASDAQ's current proposal ensures that the two fees interact in
a manner that is fair to Non-Professional users. Likewise, while the
fees for Professional Users of NASDAQ Basic are higher than for Non-
Professionals, NASDAQ believes that the monthly fee and the Per Query
fee must still interact in a manner that is fair to Professional users
and that the proposed fee cap satisfies that requirement.
The changed fee also continues to reflect an equitable allocation
and continues not to be unfairly discriminatory, because NASDAQ Basic
is a voluntary product for which market participants can readily
substitute core data feeds that provide additional quotation and last
sale information not available through NASDAQ Basic. Accordingly,
NASDAQ is constrained from pricing the product in a manner that would
be inequitable or unfairly discriminatory. The enterprise license helps
to ensure that fees for professional users are not inequitable or
unfairly discriminatory, because they are subject to limitations that
will enable broker-dealers with large numbers of subscribers to
moderate the fees that they would otherwise be required to pay. The
change being made to the license fee does not render the fee
inequitable or unfairly discriminatory, but rather ensures that each
broker pays a fair fee with respect to each External Distributor from
which it receives NASDAQ Basic. Specifically, the fee will ensure that
a broker-dealer that opts to receive NASDAQ Basic through more than one
External Distributor pays a fee that equitably reflects additional
usage, rather than paying the same paid [sic] by a broker receiving the
product through only one External Distributor.
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
[[Page 28578]]
of the purposes of the Act, as amended. NASDAQ's ability to price
NASDAQ Basic is constrained by (1) competition among exchanges, other
trading platforms, and TRFs that compete with each other in a variety
of dimensions; (2) the existence of inexpensive real-time consolidated
data and market-specific data and free delayed consolidated data; and
(3) the inherent contestability of the market for proprietary data.
The market for proprietary data products is currently 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. Similarly, with respect to the TRF
data component of NASDAQ Basic, allowing exchanges to operate TRFs has
permitted them to earn revenues by providing technology and data in
support of the non-exchange segment of the market. This revenue
opportunity has also resulted in fierce competition between the two
current TRF operators, with both TRFs charging extremely low trade
reporting fees and rebating the majority of the revenues they receive
from core market data to the parties reporting trades.
Transaction executions 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.\15\ 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 trade executions, exchange data products cannot
exist. Moreover, data products are valuable to many end users only
insofar as they provide information that end users expect will assist
them or their customers in making trading decisions.
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\15\ A complete explanation of the pricing dynamics associated
with joint products is presented in a study that NASDAQ originally
submitted to the Commission in SR-NASDAQ-2011-010. See Statement of
Janusz Ordover and Gustavo Bamberger at 2-17 (December 29, 2010)
(available at https://nasdaq.cchwallstreet.com/NASDAQ/pdf/nasdaq-filings/2011/SR-NASDAQ-2011-010.pdf).
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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, the operation of the
exchange is characterized by high fixed costs and low marginal costs.
This cost structure is common in content and content distribution
industries such as software, where developing new software typically
requires a large initial investment (and continuing large investments
to upgrade the software), but once the software is developed, the
incremental cost of providing that software to an additional user is
typically small, or even zero (e.g., if the software can be downloaded
over the internet after being purchased).\16\ In NASDAQ's case, it is
costly to build and maintain a trading platform, but the incremental
cost of trading each additional share on an existing platform, or
distributing an additional instance of data, is very low. Market
information and executions are each produced jointly (in the sense that
the activities of trading and placing orders are the source of the
information that is distributed) and are each subject to significant
scale economies. In such cases, marginal cost pricing is not feasible
because if all sales were priced at the margin, NASDAQ would be unable
to defray its platform costs of providing the joint products.
Similarly, data products cannot make use of TRF trade reports without
the raw material of the trade reports themselves, and therefore
necessitate the costs of operating, regulating,\17\ and maintaining a
trade reporting system, costs that must be covered through the fees
charged for use of the facility and sales of associated data.
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\16\ See William J. Baumol and Daniel G. Swanson, ``The New
Economy and Ubiquitous Competitive Price Discrimination: Identifying
Defensible Criteria of Market Power,'' Antitrust Law Journal, Vol.
70, No. 3 (2003).
\17\ It should be noted that the costs of operating the FINRA/
NASDAQ TRF borne by NASDAQ include regulatory charges paid by NASDAQ
to FINRA.
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An exchange's BD customers view the costs of transaction executions
and of data as a unified cost of doing business with the exchange. A BD
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 BD 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 BD will choose not to buy it. Moreover, as a BD
chooses to direct fewer orders to a particular exchange, the value of
the product to that BD decreases, for two reasons. First, the product
will contain less information, because executions of the BD's trading
activity will not be reflected in it. Second, and perhaps more
important, the product will be less valuable to that BD because it does
not provide information about the venue to which it is directing its
orders. Data from the competing venue to which the BD is directing
orders will become correspondingly more valuable.
Similarly, in the case of products such as NASDAQ Basic that may be
distributed through market data vendors, the vendors provide price
discipline for proprietary data products because they control a means
of access to end users. 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 users 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 BDs,
such as Charles 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.
Exchanges, TRFs, 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.
Moreover, NASDAQ believes that products such as NASDAQ Basic can
enhance order flow to NASDAQ by providing more widespread distribution
of information about transactions in real time, thereby encouraging
wider participation in the market by investors
[[Page 28579]]
with access to the data through their brokerage firm or other
distribution sources. Conversely, the value of such products to
distributors and investors decreases if order flow falls, because the
products contain less content.
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 exchange 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. Similarly, the inclusion of trade
reporting data in a product such as NASDAQ Basic may assist in
attracting customers to the product, thereby assisting in covering the
additional costs associated with operating and regulating a TRF.
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. NASDAQ pays rebates to attract orders, charges relatively
low prices for market information and charges relatively high prices
for accessing posted liquidity. Other platforms may choose a strategy
of paying lower liquidity rebates to attract orders, setting relatively
low prices for accessing posted liquidity, and setting relatively high
prices for market information. Still others may provide most data free
of charge and rely exclusively on transaction fees to recover their
costs. Finally, some platforms may incentivize use by providing
opportunities for equity ownership, which may allow them to charge
lower direct fees for executions and data.
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. Such regulation is unnecessary because an ``excessive'' price
for one of the joint products will ultimately have to be reflected in
lower prices for other products sold by the firm, or otherwise the firm
will experience a loss in the volume of its sales that will be adverse
to its overall profitability. In other words, an unreasonable increase
in the price of data will ultimately have to be accompanied by a
decrease in the cost of executions, or the volume of both data and
executions will fall.
The level of competition and contestability in the market is
evident in the numerous alternative venues that compete for order flow,
including thirteen 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 TRFs compete to attract internalized transaction
reports. It is common for BDs to further and exploit this competition
by sending their order flow and transaction reports to multiple
markets, rather than providing them all to a single market. 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 MKT, NYSE Arca, BATS, and Direct Edge.
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 BDs'
production of proprietary data products. The potential sources of
proprietary products are virtually limitless. Notably, the potential
sources of data include the BDs that submit trade reports to TRFs and
that have the ability to consolidate and distribute their data without
the involvement of FINRA or an exchange-operated TRF.
The fact that proprietary data from ATSs, BDs, and vendors can by-
pass SROs is significant in two respects. First, non-SROs can compete
directly with SROs for the production and sale of proprietary data
products, as BATS and Arca did before registering as exchanges by
publishing proprietary book data on the internet. Second, because a
single order or transaction report can appear in a core data product,
an SRO proprietary product, and/or a non-SRO proprietary product, the
data available in proprietary products is exponentially greater than
the actual number of orders and transaction reports that exist in the
marketplace. Indeed, in the case of NASDAQ Basic, the data provided
through that product appears both in (i) real-time core data products
offered by the SIPs for a fee, and (ii) free SIP data products with a
15-minute time delay, and finds a close substitute in similar products
of competing venues.
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 BDs have
previously published their proprietary data individually, Regulation
NMS encourages market data vendors and BDs 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. In Europe, Markit aggregates and disseminates data from over
50 brokers and multilateral trading facilities.\18\
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\18\ https://www.markit.com/en/products/data/boat/boat-boat-data.page.
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In the case of TRFs, the rapid entry of several exchanges into this
space in 2006-2007 following the development and Commission approval of
the TRF structure demonstrates the contestability of this aspect of the
market.\19\ Given the demand for trade reporting services that is
itself a by-product of the fierce competition for transaction
executions--characterized notably by a proliferation of ATSs and BDs
offering internalization--any supra-competitive increase in the fees
[[Page 28580]]
associated with trade reporting or TRF data would shift trade report
volumes from one of the existing TRFs to the other \20\ and create
incentives for other TRF operators to enter the space. Alternatively,
because BDs reporting to TRFs are themselves free to consolidate the
market data that they report, the market for over-the-counter data
itself, separate and apart from the markets for execution and trade
reporting services--is fully contestable.
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\19\ The low cost exit of two TRFs from the market is also
evidence of a contestible market, because new entrants are reluctant
to enter a market where exit may involve substantial shut-down
costs.
\20\ It should be noted that the FINRA/NYSE TRF has, in recent
weeks, received reports for over 10% of all over-the-counter volume
in NMS stocks. In addition, FINRA has announced plans to update its
Alternative Display Facility, which is also able to receive over-
the-counter trade reports. See Securities Exchange Act Release No.
70048 (July 26, 2013), 78 FR 46652 (August 1, 2013) (SR-FINRA-2013-
031).
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Moreover, consolidated data provides substantial pricing discipline
for proprietary data products that are a subset of the consolidated
data stream. Because consolidated data contains marketwide information,
it effectively places a cap on the fees assessed for proprietary data
(such as quotation and last sale data) that is simply a subset of the
consolidated data. The availability provides a powerful form of pricing
discipline for proprietary data products that contain data elements
that are a subset of the consolidated data, by highlighting the
optional nature of proprietary products.
The competitive nature of the market for non-core ``sub-set''
products such as NASDAQ Basic is borne out by the performance of the
market. In May 2008, the internet portal Yahoo! began offering its Web
site viewers real-time last sale data (as well as best quote data)
provided by BATS. In June 2008, NASDAQ launched NLS, which was
initially subject to an ``enterprise cap'' of $100,000 for customers
receiving only one of the NLS products, and $150,000 for customers
receiving both products. The majority of NASDAQ's sales were at the
capped level. In early 2009, BATS expanded its offering of free data to
include depth-of-book data. Also in early 2009, NYSE Arca announced the
launch of a competitive last sale product with an enterprise price of
$30,000 per month. In response, NASDAQ combined the enterprise cap for
the NLS products and reduced the cap to $50,000 (i.e., a reduction of
$100,000 per month). Similarly, the enterprise license and netting
option being offered for NASDAQ Basic through this proposed rule change
reflects a means by which the overall cost of the product is limited in
accordance with the existence of competitive alternatives, including
both core and proprietary data.
In this environment, 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 I at 539. The existence of
fierce competition for order flow implies a high degree of price
sensitivity on the part of BDs with order flow, since they may readily
reduce costs by directing orders toward the lowest-cost trading venues.
A BD 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. If a platform increases its market
data fees, the change will affect the overall cost of doing business
with the platform, and affected BDs will assess whether they can lower
their trading costs by directing orders elsewhere and thereby lessening
the need for the more expensive data. Similarly, increases in the cost
of NASDAQ Basic would impair the willingness of distributors to take a
product for which there are numerous alternatives, impacting NASDAQ
Basic data revenues, the value of NASDAQ Basic as a tool for attracting
order flow, and ultimately, the volume of orders routed to NASDAQ and
reported to the FINRA/NASDAQ TRF and the value of its other data
products.
Competition has also driven NASDAQ continually to improve its data
offerings and to cater to customers' data needs. The NASDAQ Basic
product itself is a product of this competition, offering a subset of
core data to users that may not wish to receive or pay for all
consolidated data.
The existence of numerous alternatives to NASDAQ Basic, including
real-time consolidated data, free delayed consolidated data, and
proprietary data from other sources ensures that NASDAQ cannot set
unreasonable fees, or fees that are unreasonably discriminatory,
without losing business to these alternatives. Accordingly, NASDAQ
believes that the acceptance of the NASDAQ Basic product in the
marketplace demonstrates the consistency of these fees with applicable
statutory standards. Likewise, the fee changes proposed herein will be
subject to these same competitive forces. If the proposed fee increase
is excessive, or if the proposals for an enterprise license and netting
are unattractive to market participants, only NASDAQ will suffer, since
its customers will merely migrate to competitive alternatives.
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) of the Act \21\ and paragraph (f) of Rule 19b-4
thereunder.\22\ 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.
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\21\ 15 U.S.C. 78s(b)(3)(A).
\22\ 17 CFR 240.19b-4(f).
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IV. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to rule-comments@sec.gov. Please include
File Number SR-NASDAQ-2014-045 on the subject line.
Paper Comments
Send paper comments in triplicate to Secretary, Securities
and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.
All submissions should refer to File Number SR-NASDAQ-2014-045. 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
[[Page 28581]]
available for Web site viewing and printing in the Commission's Public
Reference Room, 100 F Street NE., Washington, DC 20549, on official
business days between the hours of 10:00 a.m. and 3:00 p.m. Copies of
the filing also will be available for inspection and copying at the
principal office 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-2014-045 and should be submitted on or before
June 6, 2014.
For the Commission, by the Division of Trading and Markets, pursuant
to delegated authority.\23\
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\23\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-11296 Filed 5-15-14; 8:45 am]
BILLING CODE 8011-01-P