Self-Regulatory Organizations; NYSE MKT LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change Amending Its Fees for Non-Display Use of NYSE Amex Options Market Data, 54325-54331 [2014-21647]
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Federal Register / Vol. 79, No. 176 / Thursday, September 11, 2014 / Notices
additional orders to be sent to the
Exchange for execution. The Exchange
also believes that the proposed rule
change is consistent with the Act in this
regard, because it strikes an appropriate
balance between fees and credits, which
will encourage submission of orders to
the Exchange, thereby promoting
competition. The removal of obsolete
pricing tiers is not competitive in
nature, but would result in a more
streamlined Fee Schedule.
Finally, the Exchange notes that it
operates in a highly competitive market
in which market participants can
readily favor competing venues if they
deem fee levels at a particular venue to
be excessive or rebate opportunities
available at other venues to be more
favorable. In such an environment, the
Exchange must continually adjust its
fees and rebates to remain competitive
with other exchanges and with
alternative trading systems that have
been exempted from compliance with
the statutory standards applicable to
exchanges. Because competitors are free
to modify their own fees and credits in
response, and because market
participants may readily adjust their
order routing practices, the Exchange
believes that the degree to which fee
changes in this market may impose any
burden on competition is extremely
limited. As a result of all of these
considerations, the Exchange does not
believe that the proposed changes will
impair the ability of ETP Holders or
competing order execution venues to
maintain their competitive standing in
the financial markets.
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were solicited
or received with respect to the proposed
rule change.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change is effective
upon filing pursuant to Section
19(b)(3)(A) 14 of the Act and
subparagraph (f)(2) of Rule 19b–4 15
thereunder, because it establishes a due,
fee, or other charge imposed by the
Exchange.
At any time within 60 days of the
filing of such 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
U.S.C. 78s(b)(3)(A).
15 17 CFR 240.19b–4(f)(2).
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission shall institute proceedings
under Section 19(b)(2)(B) 16 of the Act to
determine whether the proposed rule
change should be approved or
disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
18:29 Sep 10, 2014
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–
NYSEARCA–2014–95 and should be
submitted on or before October 2, 2014.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.17
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–21651 Filed 9–10–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rulecomments@sec.gov. Please include File
Number SR–NYSEARCA–2014–95 on
the subject line.
[Release No. 34–73008; File No. SR–
NYSEMKT–2014–73]
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–NYSEARCA–2014–95. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Section, 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 will also be available for
inspection and copying at the NYSE’s
principal office and on its Internet Web
site at www.nyse.com. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
September 5, 2014.
14 15
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Self-Regulatory Organizations; NYSE
MKT LLC; Notice of Filing and
Immediate Effectiveness of Proposed
Rule Change Amending Its Fees for
Non-Display Use of NYSE Amex
Options Market Data
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’) 1 and Rule 19b–4 thereunder,2
notice is hereby given that, on August
25, 2014, NYSE MKT LLC (‘‘Exchange’’
or ‘‘NYSE MKT’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’ or ‘‘SEC’’) the proposed
rule change as described in Items I, II,
and III below, which Items have been
prepared by the self-regulatory
organization. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange proposes to amend its
fees for non-display use of NYSE Amex
Options market data, operative on
September 1, 2014. 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.
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
17 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
16 15
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Federal Register / Vol. 79, No. 176 / Thursday, September 11, 2014 / Notices
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 the
Statutory Basis for, the Proposed Rule
Change
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1. Purpose
The Exchange proposes to amend its
fees for non-display use of NYSE Amex
Options market data, operative on
September 1, 2014.3
The Exchange established the current
non-display fees for ArcaBook for Amex
Options—Trades, ArcaBook for Amex
Options—Top of Book, ArcaBook for
Amex Options—Depth of Book,
ArcaBook for Amex Options—Complex,
ArcaBook for Amex Options—Series
Status, and ArcaBook for Amex
Options—Order Imbalance (collectively,
‘‘Amex Options Products’’) in May
2013.4 Fees cover all six products.5
Under the proposal, non-display use
would continue to mean accessing,
processing, or consuming an Exchange
data product delivered via direct and/or
Redistributor 6 data feeds for a purpose
other than in support of a data
recipient’s display or further internal or
external redistribution (‘‘Non-Display
Use’’). As is the case today, non-display
fees would apply to the Non-Display
Use of the data product as part of
automated calculations or algorithms to
support trading decision-making
processes or the operation of trading
platforms.
The Exchange is proposing to expand
the types of uses considered NonDisplay Use to also include non-trading
uses. In addition, the proposal would
specify that Non-Display Use would
include any trading use, rather than
only certain types of trading, such as
high frequency or algorithmic trading,
as under the current fee structure.
Under the proposal, examples of Non3 The Exchange’s affiliates have submitted or will
be submitting similar proposals. See, e.g., SR–
NYSE–2014–43.
4 See Securities Exchange Act Release No. 69553
(May 10, 2013), 78 FR 28926 (May 16, 2013) (SR–
NYSEMKT–2013–40) (‘‘2013 Release’’).
5 The Exchange began offering ArcaBook for
Amex Options—Complex separately at no charge on
May 1, 2014. See Securities Exchange Act Release
No. 72074 (May 1, 2014), 79 FR 26277 (May 7,
2014) (SR–NYSEArca–2014–51).
6 ‘‘Redistributor’’ means a vendor or any person
that provides a real-time NYSE data product to a
data recipient or to any system that a data recipient
uses, irrespective of the means of transmission or
access.
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Display Use would include any trading
in any asset class, automated order or
quote generation and/or order pegging,
price referencing for algorithmic trading
or smart order routing, operations
control programs, investment analysis,
order verification, surveillance
programs, risk management,
compliance, and portfolio management.
The Exchange believes that non-trading
uses benefit data recipients by allowing
users to automate functions, achieving
greater speed and accuracy, and in turn,
for example, reducing costs of labor to
perform the functions manually. This
approach would address the difficulties
of monitoring and auditing different
types of trading versus non-trading uses
of the data and the burden of counting
devices used for non-trading purposes
under the current fees.
Proposed Changes to Non-Display Fees
The Exchange proposes to amend the
fee structure applicable to Non-Display
Use of Amex Options Products.
Specifically, the Exchange proposes
certain changes to the three categories
of, and fees applicable to, data
recipients. The Exchange also proposes
corresponding changes to the Fee
Schedule text to remove references to
the current category descriptions.
Under the proposal, Category 1 Fees
would apply when a data recipient’s
Non-Display Use of real-time market
data is on its own behalf as opposed to
on behalf of its clients. This proposal
represents an expansion of the
application of Category 1 Fees, which
currently apply solely to the NonDisplay Use of real time market data for
the purpose of principal trading, to
usage of such data for non-trading
purposes.
Under the proposal, Category 2 Fees
would apply to a data recipient’s NonDisplay Use of real-time market data on
behalf of its clients as opposed to on its
own behalf. This proposal also
represents an expansion of the
application of Category 2 Fees, which
currently apply solely to trading
activities to facilitate a customer
business, to usage of such data for nontrading purposes. In contrast to the
current fee structure, data recipients
will not be liable for Category 2 NonDisplay fees for which they are also
paying Category 1 Non-Display fees.7
The Exchange believes its proposal to
apply Category 1 Fees and Category 2
Fees to Non-Display Use of market data
for non-trading purposes would address
the difficulties of monitoring and
auditing trading versus non-trading uses
of the data and the burden of counting
devices used for purposes of applying
the per-device fees. As discussed in
more detail in the 2013 Release,8 the
ability to accurately count devices and
audit such counts creates administrative
challenges for vendors, data recipients,
and the Exchange.
Under the proposal, Category 3 Fees
would apply to data recipients’ NonDisplay Use of real-time market data for
the purpose of internally matching buy
and sell orders within an organization,
including matching customer orders on
a data recipient’s own behalf and/or on
behalf of its clients. This category would
apply to Non-Display Use in trading
platform(s), such as, but not restricted
to, alternative trading systems (‘‘ATSs’’),
broker crossing networks, broker
crossing systems not filed as ATSs, dark
pools, multilateral trading facilities,
exchanges and systematic
internalization systems. Currently,
Category 3 Fees apply where a data
recipient’s non-display use of market
data is, in whole or in part, for the
purpose of providing reference prices in
the operation of one or more trading
platforms. The Exchange believes its
proposed revision to its description of
the data recipients to whom Category 3
Fees apply is more precise because it
focuses on the functions of internally
matching orders.
In addition, the Exchange is
proposing to change the application of
Category 3 Fees to data recipients that
also use data for purposes that give rise
to Category 1 and/or Category 2 Fees.
Currently, a data recipient is not liable
for Category 3 Fees for those Amex
Options Products for which it is also
paying Category 1 and/or Category 2
Fees.9 Under the proposal, a data
recipient’s Non-Display Use of real-time
market data for Category 3 purposes
would require such data recipient to pay
Category 3 Fees in addition to any
Category 1 Fees or Category 2 Fees it is
required to pay for Non-Display Use of
market data.
There will continue to be no monthly
or other reporting requirements for data
recipients’ Non-Display Use. However,
the Exchange continues to reserve the
right to audit data recipients’ NonDisplay Use of Exchange market data
products in accordance with the
Exchange’s vendor and subscriber
agreements.
A data recipient that receives realtime Exchange market data for NonDisplay Use would be required to
complete and submit a Non-Display Use
Declaration before September 1, 2014.
The Non-Display Use Declaration would
8 See
7 See
PO 00000
2013 Release, supra note 4, at 28929.
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id.
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replace the current declaration on the
NYSE Euronext Non-Display Usage
Declaration.10 A firm subject to Category
3 Fees would be required to identify
each platform that uses data on a NonDisplay Use basis, such as ATSs and
broker crossing systems not registered as
ATSs, as part of the Non-Display Use
Declaration. Beginning in 2016, data
recipients would be required to submit,
by January 31 of each year, a NonDisplay Use Declaration. In addition, if
a data recipient’s use of real-time
Exchange market data changes at any
time after the data recipient submits a
Non-Display Use Declaration, the data
recipient would be required to update it
54327
at the time of the change to reflect the
change of use.
Comparison of Current Fees to Proposed
Fees
The chart below compares the
proposed changes to current monthly
fees:
Data feed
Current fee
Proposed fee
Amex Options Products Non-Display Category 1 ...................................
Amex Options Products Non-Display Category 2 ...................................
Amex Options Products Non-Display Category 3 ...................................
$1,000 ............................................
$1,000 ............................................
$1,000, or $0 if Category 1 or 2
fees paid.
$5,000.*
$5,000.*
$5,000, capped at $15,000.
* Data recipients will not be liable for Category 2 Non-Display fees for which they are also paying Category 1 Non-Display fees.
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2. Statutory Basis
The Exchange believes that the
proposed rule change is consistent with
the provisions of Section 6 of the Act,11
in general, and Sections 6(b)(4) and
6(b)(5) of the Act,12 in particular, in that
it provides an equitable allocation of
reasonable fees among users and
recipients of the data and is not
designed to permit unfair
discrimination among customers,
issuers, and brokers.
The Exchange believes that charging
for non-trading uses is reasonable
because data recipients can derive
substantial value from such uses, for
example, by automating tasks so that
they can be performed more quickly and
accurately and less expensively than if
they were performed manually. The
Exchange also notes that The NASDAQ
Stock Market (‘‘NASDAQ’’) and
NASDAQ OMX PHLX (‘‘Phlx’’) do not
make any distinction in their nondisplay use fees between trading or nontrading uses, and as such, the proposed
change will harmonize the Exchange’s
approach with those exchanges. Finally,
the Exchange notes that eliminating the
trading versus non-trading distinction
would substantially simplify fee
calculations and ease administrative
burdens for the Exchange.
After further experience, the
Exchange also believes that it is more
equitable and not unfairly
discriminatory to eliminate the
distinction for non-trading versus
trading uses in light of the significant
value of both types of uses. The
Exchange notes that because nondisplay fees are flat fees, the expansion
10 As described in more detail in the Statutory
Basis section, in order to modulate the overall fee
increase that could apply, if a firm subject to
Category 3 Fees has more than three platforms, it
would only be required to declare three platforms.
11 15 U.S.C. 78f(b).
12 15 U.S.C. 78f(b)(4), (5).
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to cover non-trading uses could only
result in a fee increase for a data
recipient that is using the data solely for
non-trading purposes and is only
subject to per-device fees; at this time,
the Exchange has not identified such a
data recipient. Based on data available
to the Exchange, all data recipients use
the data for at least one trading purpose,
and therefore the changes to the fees
that they will pay under the proposal
would not be due to the elimination of
the distinction between trading and
non-trading uses. The Exchange further
notes that based on Non-Display Use
Declarations submitted to date, some
users have declared no Non-Display
Use, and as such the proposed changes
would have no impact on them.
The Exchange believes that it is
reasonable to require annual
submissions of the Non-Display Use
Declaration so that the Exchange will
have current and accurate information
about the use of its market data products
and can correctly assess fees for the uses
of those products. The annual
submission requirement is equitable and
not unfairly discriminatory because it
will apply to all users.
The Exchange believes that the
proposed fee increases of $4,000 per
month for each of Categories 1, 2, and
3 is reasonable. In establishing the nondisplay fees in May 2013, the Exchange
set its fees below comparable fees
charged by certain of its competitors.13
After gaining further experience with its
new display/non-display fee structure,
the Exchange believes that the proposed
fees better reflect the significant value of
the non-display data to data recipients,
which purchase such data on an entirely
13 See
2013 Release, supra note 4, at 28930.
also Exchange Act Release No. 69157,
March 18, 2013, 78 FR 17946, 17949 (March 25,
2013) (SR–CTA/CQ–2013–01) (‘‘[D]ata feeds have
become more valuable, as recipients now use them
to perform a far larger array of non-display
functions. Some firms even base their business
14 See
PO 00000
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voluntary basis. Non-display data can be
used by data recipients for a wide
variety of profit-generating purposes,
including proprietary and agency
trading and smart order routing, as well
as by data recipients that operate order
matching and execution platforms that
compete directly with the Exchange for
order flow. The data also can be used for
a variety of non-trading purposes that
indirectly support trading, such as risk
management and compliance. While
some of these non-trading uses do not
directly generate revenues, they can
nonetheless substantially reduce the
recipient’s costs by automating such
functions so that they can be carried out
in a more efficient and accurate manner
and reduce errors and labor costs,
thereby benefiting end users. The
Exchange believes that the proposed
fees directly and appropriately reflect
the significant value of using nondisplay data in a wide range of
computer-automated functions relating
to both trading and non-trading
activities and that the number and range
of these functions continue to grow
through innovation and technology
developments.14
The fee increases are also reasonable
in that they support the Exchange’s
efforts to regularly upgrade systems to
support more modern data distribution
formats and protocols as technology
evolves. For example, the Exchange will
make its proprietary data products
available over an upgraded distribution
channel and protocol ‘‘XDP’’ early next
year.
Charging a separate fee for Category 3
data recipients that already pay a fee
under Category 1 or 2 is reasonable
models on the incorporation of data feeds into black
boxes and application programming interfaces that
apply trading algorithms to the data, but that do not
require widespread data access by the firm’s
employees. As a result, these firms pay little for
data usage beyond access fees, yet their data access
and usage is critical to their businesses.’’).
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because it eliminates what is effectively
a discount for such data recipients
under the current Fee Schedule and
results in a more equitable allocation of
fees to users that derive a benefit from
a Category 3 use, and as such is not
unfairly discriminatory. The current fee
can be viewed as having an effective
non-display fee cap of $2,000 while the
proposed fee would have an effective
non-display fee cap of $20,000. The
Exchange believes that the proposed
fees (and their associated caps) more
closely correspond to the value that
Category 3 recipients derive from the
various uses of the data, some of which
are operating various types of
alternative trading venues that directly
compete for order flow with the
Exchange. Limiting the fees in Category
3 to no more than three trading
platforms and charging only one fee for
users that fall under both Category 1 and
2 is reasonable because it modulates the
size of the fee increase for certain
recipients as compared to what they pay
under the current fee structure, in much
the same manner as the current fee does
by limiting the non-display fees to a
maximum of two categories. The
Exchange does not believe that it will be
burdensome for Category 3 recipients to
determine, or the Exchange to audit,
whether a recipient has one, two, three
or more separate platforms.
The fees are also competitive with
offerings by other exchanges, which
structure and set their fees in a variety
of ways. For example, NASDAQ
Options Market (‘‘NOM’’) offers a $2,500
per month ‘‘Non-Display Enterprise
License’’ fee that permits distribution of
Best of NASDAQ Options (‘‘BONO’’) or
NASDAQ ITCH-to-Trade Options
(‘‘ITTO’’) to an unlimited number of
non-display devices within a firm
without any per user charge.15 In
addition, Phlx offers an alternative
$10,000 per month ‘‘Non-Display
Enterprise License’’ fee that permits
distribution to an unlimited number of
internal non-display subscribers
without incurring additional fees for
each internal subscriber.16 The NonDisplay Enterprise License covers nondisplay subscriber fees for all Phlx
proprietary direct data feed products
(Top of Phlx Options (‘‘TOPO’’), TOPO
Plus Orders, PHLX Orders and PHLX
15 See NASDAQ Options Rules Chapter XV,
Section 4. Alternatively, NOM charges each
professional subscriber $5 per month for BONO and
$10 per month for ITTO.
16 See Section IX of the NASDAQ OMX PHLX
LLC Pricing Schedule and Securities Exchange Act
Release No. 68576 (January 3, 2013), 78 FR 1886
(January 9, 2013) (SR–Phlx–2012–145).
Alternatively, Phlx charges each professional
subscriber $40 per month.
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Depth Data feeds) and is in addition to
any other associated distributor fees for
Phlx proprietary direct data feed
products,17 The Exchange further notes
that its proposed fees are less than the
non-display fees charged by the Options
Price Reporting Authority (‘‘OPRA’’).18
The Exchange also notes that all of the
products described herein are entirely
optional. The Exchange is not required
to make these proprietary data products
available or to offer any specific pricing
alternatives to any customers, nor is any
firm required to purchase any of the
products. Firms that do purchase nondisplay products do so with the primary
goals of using them to increase
revenues, reduce expenses, and in some
instances compete directly with the
Exchange for order flow; those firms are
able to determine for themselves
whether any specific product such as
these are attractively priced or not.
Firms that do not wish to purchase
the data at the new prices have a wide
variety of alternative market data
products from which to choose,19 or if
the non-display data products do not
provide sufficient value to firms as
offered based on the uses those firms
have or planned to make of them, such
firms may simply choose to conduct
their business operations in ways that
do not require those data products. The
Exchange notes that broker-dealers are
not required to purchase proprietary
market data to comply with their best
execution obligations.20 Similarly, there
is no requirement in Regulation NMS or
any other rule that proprietary data be
utilized for order routing decisions.
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),
upheld reliance by the Securities and
Exchange Commission (‘‘Commission’’)
upon the existence of competitive
market mechanisms to set reasonable
and equitably allocated fees for
proprietary market data:
17 See
id.
Securities Exchange Act Release No. 67648
(August 14, 2012), 77 FR (August 17, 2012) (SR–
OPRA–2012–04) (establishing effective October 1,
2012 a non-display application fee of $500/
installation/month, with an enterprise fee
alternative of $7500/month that would permit a
professional subscriber to receive access to OPRA
data for use in an unlimited number of non-display
application installations).
19 See supra notes 14–17. Because ArcaBook for
Amex Options—Trades and ArcaBook for Amex
Options—Top of Book are subsets of the
consolidated core data offered by OPRA, customers
may choose to purchase those consolidated data
products instead.
20 See In the Matter of the Application of
Securities Industry And Financial Markets
Association For Review of Actions Taken by SelfRegulatory Organizations, Release Nos. 34–72182;
AP–3–15350; AP–3–15351 (May 16, 2014).
18 See
PO 00000
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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.’
635 F.3d at 535 (quoting H.R. Rep. No.
94–229 at 92 (1975), as reprinted in
1975 U.S.C.C.A.N. 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.’ ’’ 21
As explained below in the Exchange’s
Statement on Burden on Competition,
the Exchange believes that there is
substantial evidence of competition in
the marketplace for proprietary market
data and that the Commission can rely
upon such evidence in concluding that
the fees established in this filing are the
product of competition and therefore
satisfy the relevant statutory standards.
In addition, the existence of alternatives
to these data products, such as
consolidated data and proprietary data
from other sources, as described below,
further ensures that the Exchange
cannot set unreasonable fees, or fees
that are unreasonably discriminatory,
when vendors and subscribers can
select such alternatives.
As the NetCoalition decision noted,
the Commission is not required to
undertake a cost-of-service or
ratemaking approach. The Exchange
believes that, even if it were possible as
a matter of economic theory, cost-based
pricing for non-core market data would
be so complicated that it could not be
done practically or offer any significant
benefits.22
21 NetCoalition,
615 F.3d at 535.
Exchange believes that cost-based pricing
would be impractical because it would create
enormous administrative burdens for all parties,
including the Commission, to cost-regulate a large
number of participants and standardize and analyze
extraordinary amounts of information, accounts,
and reports. In addition, and as described below, it
is impossible to regulate market data prices in
isolation from prices charged by markets for other
services that are joint products. Cost-based rate
regulation would also lead to litigation and may
distort incentives, including those to minimize
costs and to innovate, leading to further waste.
Under cost-based pricing, the Commission would
be burdened with determining a fair rate of return,
and the industry could experience frequent rate
increases based on escalating expense levels. Even
in industries historically subject to utility
regulation, cost-based ratemaking has been
discredited. As such, the Exchange believes that
cost-based ratemaking would be inappropriate for
proprietary market data and inconsistent with
Congress’s direction that the Commission use its
authority to foster the development of the national
market system, and that market forces will continue
22 The
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For these reasons, the Exchange
believes that the proposed fees are
reasonable, equitable, and not unfairly
discriminatory.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
mstockstill on DSK4VPTVN1PROD with NOTICES
The Exchange does not believe that
the proposed rule change will impose
any burden on competition that is not
necessary or appropriate in furtherance
of the purposes of the Act. An
exchange’s ability to price its
proprietary market data feed products is
constrained by actual competition for
the sale of proprietary market data
products, the joint product nature of
exchange platforms, and the existence of
alternatives to the Exchange’s
proprietary data.
The Existence of Actual Competition.
The market for proprietary options data
products is currently competitive and
inherently contestable because there is
fierce competition for the inputs
necessary for the creation of proprietary
data and strict pricing discipline for the
proprietary products themselves.
Numerous exchanges compete with one
another for options trades and sales of
options market data itself, providing
ample opportunities for entrepreneurs
who wish to compete in any or all of
those areas, including producing and
distributing their own options market
data. Proprietary options data products
are produced and distributed by each
individual exchange, as well as other
entities, in a vigorously competitive
market. Indeed, the U.S. Department of
Justice (‘‘DOJ’’) (the primary antitrust
regulator) has expressly acknowledged
the aggressive actual competition among
exchanges, including for the sale of
proprietary market data. In 2011, the
DOJ stated that exchanges ‘‘compete
head to head to offer real-time equity
data products. These data products
include the best bid and offer of every
exchange and information on each
equity trade, including the last sale.’’ 23
Similarly, the options markets
vigorously compete with respect to
options data products.24
to provide appropriate pricing discipline. See
Appendix C to NYSE’s comments to the
Commission’s 2000 Concept Release on the
Regulation of Market Information Fees and
Revenues, which can be found on the Commission’s
Web site at https://www.sec.gov/rules/concept/
s72899/buck1.htm.
23 Press Release, U.S. Department of Justice,
Assistant Attorney General Christine Varney Holds
Conference Call Regarding NASDAQ OMX Group
Inc. and IntercontinentalExchange Inc. Abandoning
Their Bid for NYSE Euronext (May 16, 2011),
available at https://www.justice.gov/iso/opa/atr/
speeches/2011/at-speech-110516.html.
24 See, e.g., Securities Exchange Act Release No.
67466 (July 19, 2012), 77 FR 43629 (July 25, 2012)
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Moreover, competitive markets for
order flow, executions, and transaction
reports provide pricing discipline for
the inputs of proprietary options data
products and therefore constrain
markets from overpricing proprietary
options market data. Broker-dealers
send their order flow to multiple
venues, rather than providing them all
to a single venue, which in turn
reinforces this competitive constraint.
Options markets, similar to the equities
markets, are highly fragmented.25
If an exchange succeeds in its
competition for quotations, order flow,
and trade executions, then it earns
trading revenues and increases the value
of its proprietary options market data
products because they will contain
greater quote and trade information.
Conversely, if an exchange is less
successful in attracting quotes, order
flow, and trade executions, then its
options market data products may be
less desirable to customers using them
in support of order routing and trading
decisions in light of the diminished
content; data products offered by
competing venues may become
correspondingly more attractive. Thus,
competition for quotations, order flow,
and trade executions puts significant
pressure on an exchange to maintain
both execution and data fees at
reasonable levels.
In addition, in the case of products
that are distributed through market data
vendors, such as Bloomberg and
Thompson Reuters, the vendors
themselves provide additional price
discipline for proprietary data products
because they control the primary means
of access to certain end users. These
vendors impose price discipline based
upon their business models. For
example, vendors that assess a
surcharge on data they sell are able to
refuse to offer proprietary products that
their end users do not or will not
purchase in sufficient numbers. Vendors
will not elect to make available Amex
Options Products described herein
unless their customers request them,
and customers will not elect to pay the
proposed increased fees for non-display
uses unless the non-display uses of
these data products can provide value
by sufficiently increasing revenues or
reducing costs in the customer’s
(SR–Phlx–2012–93), which describes a variety of
options market data products and their pricing.
25 See, e.g., Press Release, TABB Says US Equity
Options Market Makers Need Scalable Technology
to Compete in Today’s Complex Market Structure
(February 25, 2013), available at https://
www.tabbgroup.com/
PageDetail.aspx?PageID=16&ItemID=1231;
Fragmentation Vexes Options Markets (April 21,
2014), available at https://marketsmedia.com/
fragmentation-vexes-options-market/.
PO 00000
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54329
business in a manner that will offset the
fees. All of these factors operate as
constraints on pricing proprietary data
products.
Joint Product Nature of Exchange
Platform. Transaction execution and
proprietary data products are
complementary in that market data is
both an input and a byproduct of the
execution service. In fact, proprietary
market data and trade executions are a
paradigmatic example of joint products
with joint costs. The decision whether
and on which platform to post an order
will depend on the attributes of the
platforms where the order can be
posted, including the execution fees,
data availability and quality, and price
and distribution of their data products.
Without a platform to post quotations,
receive orders, and execute trades,
exchange data products would not exist.
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 platform for
posting quotes, accepting orders, and
executing transactions and the cost of
regulating the exchange to ensure its fair
operation and maintain investor
confidence. The total return that a
trading platform earns reflects the
revenues it receives from both products
and the joint costs it incurs.
Moreover, an exchange’s brokerdealer customers generally view the
costs of transaction executions and
market data as a unified cost of doing
business with the exchange. A brokerdealer will only choose to direct orders
to an exchange if the revenue from the
transaction exceeds its cost, including
the cost of any market data that the
broker-dealer chooses to buy in support
of its order routing and trading
decisions. If the costs of the transaction
are not offset by its value, then the
broker-dealer may choose instead not to
purchase the product and trade away
from that exchange. There is substantial
evidence of the strong correlation
between order flow and market data
purchases. For example, in July 2014
more than 80% of the options
transaction volume on each of NYSE
MKT and NYSE Arca was executed by
market participants that purchased one
or more proprietary market data
products. A super-competitive increase
in the fees for either executions or
market data would create a risk of
reducing an exchange’s revenues from
both products.
Other market participants have noted
that proprietary market data and trade
executions are joint products of a joint
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mstockstill on DSK4VPTVN1PROD with NOTICES
platform and have common costs.26 The
Exchange agrees with and adopts those
discussions and the arguments therein.
The Exchange also notes that the
economics literature confirms that there
is no way to allocate common costs
between joint products that would shed
any light on competitive or efficient
pricing.27
Analyzing the cost of market data
product production and distribution in
isolation from the cost of all of the
inputs supporting the creation of market
data and market data products will
inevitably underestimate the cost of the
data and data products because it is
impossible to obtain the data inputs to
create market data products without a
fast, technologically robust, and wellregulated execution system, and system
and regulatory costs affect the price of
both obtaining the market data itself and
creating and distributing market data
products. It would be equally
misleading, however, to attribute all of
an exchange’s costs to the market data
portion of an exchange’s joint products.
Rather, all of an 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.
26 See Securities Exchange Act Release No. 72153
(May 12, 2014), 79 FR 28575, 28578 n.15 (May 16,
2014) (SR–NASDAQ–2014–045) (‘‘[A]ll 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.’’). See also Securities Exchange Act
Release No. 62907 (September 14, 2010), 75 FR
57314, 57317 (September 20, 2010) (SR–NASDAQ–
2010–110), and Securities Exchange Act Release
No. 62908 (September 14, 2010), 75 FR 57321,
57324 (September 20, 2010) (SR–NASDAQ–2010–
111).
27 See generally Mark Hirschey, Fundamentals of
Managerial Economics, at 600 (2009) (‘‘It is
important to note, however, that although it is
possible to determine the separate marginal costs of
goods produced in variable proportions, it is
impossible to determine their individual average
costs. This is because common costs are expenses
necessary for manufacture of a joint product.
Common costs of production—raw material and
equipment costs, management expenses, and other
overhead—cannot be allocated to each individual
by-product on any economically sound basis.. . .
Any allocation of common costs is wrong and
arbitrary.’’). This is not new economic theory. See,
e.g., F. W. Taussig, ‘‘A Contribution to the Theory
of Railway Rates,’’ Quarterly Journal of Economics
V(4) 438, 465 (July 1891) (‘‘Yet, surely, the division
is purely arbitrary. These items of cost, in fact, are
jointly incurred for both sorts of traffic; and I cannot
share the hope entertained by the statistician of the
Commission, Professor Henry C. Adams, that we
shall ever reach a mode of apportionment that will
lead to trustworthy results.’’).
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As noted above, the level of
competition and contestability in the
market is evident in the numerous
alternative venues that compete for
order flow, including 12 self-regulatory
organization (‘‘SRO’’) options markets.
Two of the 12 have launched operations
since December 2012.28 The Exchange
believes that these new entrants
demonstrate that competition is robust.
Competition among trading platforms
can be expected to constrain the
aggregate return that each platform
earns from the sale of its joint products,
but different trading platforms may
choose from a range of possible, and
equally reasonable, pricing strategies as
the means of recovering total costs. For
example, some platforms may choose to
pay rebates to attract orders, charge
relatively low prices for market data
products (or provide market data
products free of charge), and charge
relatively high prices for accessing
posted liquidity. Other platforms may
choose a strategy of paying lower
rebates (or no rebates) to attract orders,
setting relatively high prices for market
data products, and setting relatively low
prices for accessing posted liquidity. For
example, BATS Exchange, Inc.
(‘‘BATS’’), which previously operated as
an ATS and obtained exchange status in
2008, has provided certain market data
at no charge on its Web site in order to
attract more order flow, and uses
revenue rebates from resulting
additional executions to maintain low
execution charges for its users.29 The
Exchange currently offers ArcaBook for
Arca Options—Complex for free. 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.30
28 See Securities Exchange Act Release Nos.
70050 (July 26, 2013), 78 FR (August 1, 2013)
(approving exchange registration for Topaz
Exchange, LLC) (known as ISE Gemini); and 68341
(December 3, 2012), 77 FR 73065 (December 7,
2012) (approving exchange registration for Miami
International Securities Exchange LLC (‘‘Miami
Exchange’’)).
29 See description of free market data from BATS
Options, available at https://www.batsoptions.com/
market_data/products/. This is simply a securities
market-specific example of the well-established
principle that in certain circumstances more sales
at lower margins can be more profitable than fewer
sales at higher margins; this example is additional
evidence that market data is an inherent part of a
market’s joint platform.
30 The Exchange notes that a small number of
Category 3 non-display data recipients could be
using the market data strictly for competitive
purposes (e.g., other exchanges) or for business
purposes unrelated to trading or investment (e.g.,
Internet portals that wish to attract ‘‘eyeballs’’ to
their pages primarily generate advertising revenue
for themselves). The Exchange does not believe that
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Existence of Alternatives. The large
number of SROs that currently produce
proprietary data or are currently capable
of producing it provides further pricing
discipline for proprietary data products.
Each SRO is currently permitted to
produce and sell proprietary data
products, and many currently do or
have announced plans to do so,
including but not limited to the
Exchange, NYSE Arca, Inc.; Chicago
Board Options Exchange, Incorporated;
C2 Options Exchange, Incorporated;
International Securities Exchange, LLC;
ISE Gemini; NASDAQ; Phlx; BX; BATS;
and Miami Exchange.
The fact that proprietary data from
vendors can bypass SROs is significant
in two respects. First, non-SROs can
compete directly with SROs for the
production and sale of proprietary data
products. By way of example, BATS and
NYSE Arca both published proprietary
data on the Internet before registering as
exchanges. Second, because a single
order or transaction report can appear in
an SRO proprietary product, a non-SRO
proprietary product, or both, the amount
of data available via proprietary
products is greater in size than the
actual number of orders and transaction
reports that exist in the marketplace. For
example, with respect to ArcaBook for
Arca Options—Trades and ArcaBook for
Arca Options—Top of Book, the data
appears in the real-time core data
offered by OPRA for a fee. Close
substitute products also are offered by
several competitors.31 Because market
data users can find suitable substitutes
for most proprietary market data
products, a market that overprices its
market data products stands a high risk
that users may substitute one or more
other sources of market data information
for its own.
Those competitive pressures imposed
by available alternatives are evident in
the Exchange’s proposed pricing. As
noted above, the proposed non-display
fees are generally lower than the
maximum non-display fees charged by
other exchanges such as NASDAQ and
Phlx, for comparable products.32
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 and inexpensive. 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
the proposed fees will impose any unnecessary
burden on these competitors or other businesses.
31 See supra notes 15–18.
32 Id.
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Tradebook, Island, RediBook, Attain,
TrackECN, and BATS. As noted above,
BATS launched as an ATS in 2006 and
became an exchange in 2008. Two new
options exchanges have launched
operations since December 2012.33
In establishing the proposed fees, the
Exchange considered the
competitiveness of the market for
proprietary options market data and all
of the implications of that competition.
The Exchange believes that it has
considered all relevant factors, and has
not considered irrelevant factors, in
order to establish fair, reasonable, and
not unreasonably discriminatory fees
and an equitable allocation of fees
among all users. The existence of
numerous alternatives to the Exchange’s
products, including proprietary data
from other sources, ensures that the
Exchange cannot set unreasonable fees,
or fees that are unreasonably
discriminatory, when vendors and
subscribers can elect these alternatives
or choose not to purchase a specific
proprietary data product if the attendant
fees are not justified by the returns that
any particular vendor or data recipient
would achieve through the purchase.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
No written comments were solicited
or received with respect to the proposed
rule change.
mstockstill on DSK4VPTVN1PROD with NOTICES
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change is effective
upon filing pursuant to Section
19(b)(3)(A) 34 of the Act and
subparagraph (f)(2) of Rule 19b–4 35
thereunder, because it establishes a due,
fee, or other charge imposed by the
Exchange.
At any time within 60 days of the
filing of such proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is necessary or appropriate in the
public interest, for the protection of
investors, or otherwise in furtherance of
the purposes of the Act. If the
Commission takes such action, the
Commission shall institute proceedings
under Section 19(b)(2)(B) 36 of the Act to
determine whether the proposed rule
33 See
supra note 28.
U.S.C. 78s(b)(3)(A).
35 17 CFR 240.19b–4(f)(2).
36 15 U.S.C. 78s(b)(2)(B).
34 15
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change should be approved or
disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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–
NYSEMKT–2014–73 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–NYSEMKT–2014–73. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
Internet Web site (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for Web site viewing and
printing in the Commission’s Public
Reference Room, 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 such
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change;
the Commission does not edit personal
identifying information from
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–
NYSEMKT–2014–73 and should be
submitted on or before October 2, 2014.
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54331
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.37
Kevin M. O’Neill,
Deputy Secretary.
[FR Doc. 2014–21647 Filed 9–10–14; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–73007; File No. SR–ICC–
2014–11]
Self-Regulatory Organizations; ICE
Clear Credit LLC; Order Approving
Proposed Rule Change, As Modified by
Amendment No. 2 Thereto, To Revise
Rules To Provide for the 2014 ISDA
Definitions
September 5, 2014.
I. Introduction
On July 24, 2014, ICE Clear Credit
LLC (‘‘ICC’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’) the proposed rule
change SR–ICC–2014–11 pursuant to
Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder.2 The proposed rule
change was published for comment in
the Federal Register on August 5, 2014.3
The Commission did not receive
comments on the proposed rule change.
On September 2, 2014, ICC filed
Amendment No. 2 to the proposed rule
change to correct a factual inaccuracy in
a statement made in its filing.4 For the
reasons described below, the
Commission is approving the proposed
rule change.
37 17
CFR 200.30–3(a)(12).
U.S.C. 78(s)(b)(1).
2 17 CFR 240.19b–4.
3 Securities Exchange Act Release No. 34–72701
(Jul. 29, 2014); 79 FR 45565 (Aug. 5, 2014) (SR–
ICC–2014–11).
4 On August 28, 2014, ICC filed Amendment No.
1 to the proposed rule change. ICC withdrew
Amendment No. 1 on September 2, 2014. ICC
subsequently filed Amendment No. 2 on September
2, 2014. In Amendment No. 2, ICC clarified that
CDS contracts on sovereigns cleared at ICC will be
Converting Contracts (as discussed herein). ICC
stated that its implementation of the 2014 ISDA
definitions is intended to be fully consistent with
the planned ISDA protocol implementation. ICC
noted that, on August 15, 2014, ISDA published a
memorandum and FAQ that, in relevant part,
explains that based on industry feedback related to
the draft protocol, the protocol would be amended
to include certain emerging market sovereign single
names. Following the protocol amendment, all
sovereign single names cleared at ICC will now be
included in the protocol. Amendment No. 2
corrects a factual inaccuracy in a statement made
in ICC’s filing, and because it does not materially
affect the substance of the proposed rule change,
the Commission is not publishing it for comment.
1 15
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Agencies
[Federal Register Volume 79, Number 176 (Thursday, September 11, 2014)]
[Notices]
[Pages 54325-54331]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-21647]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-73008; File No. SR-NYSEMKT-2014-73]
Self-Regulatory Organizations; NYSE MKT LLC; Notice of Filing and
Immediate Effectiveness of Proposed Rule Change Amending Its Fees for
Non-Display Use of NYSE Amex Options Market Data
September 5, 2014.
Pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934
(``Act'') \1\ and Rule 19b-4 thereunder,\2\ notice is hereby given
that, on August 25, 2014, NYSE MKT LLC (``Exchange'' or ``NYSE MKT'')
filed with the Securities and Exchange Commission (``Commission'' or
``SEC'') the proposed rule change as described in Items I, II, and III
below, which Items have been prepared by the self-regulatory
organization. The Commission is publishing this notice to solicit
comments on the proposed rule change from interested persons.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
---------------------------------------------------------------------------
I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
The Exchange proposes to amend its fees for non-display use of NYSE
Amex Options market data, operative on September 1, 2014. 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.
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
[[Page 54326]]
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 the
Statutory Basis for, the Proposed Rule Change
1. Purpose
The Exchange proposes to amend its fees for non-display use of NYSE
Amex Options market data, operative on September 1, 2014.\3\
---------------------------------------------------------------------------
\3\ The Exchange's affiliates have submitted or will be
submitting similar proposals. See, e.g., SR-NYSE-2014-43.
---------------------------------------------------------------------------
The Exchange established the current non-display fees for ArcaBook
for Amex Options--Trades, ArcaBook for Amex Options--Top of Book,
ArcaBook for Amex Options--Depth of Book, ArcaBook for Amex Options--
Complex, ArcaBook for Amex Options--Series Status, and ArcaBook for
Amex Options--Order Imbalance (collectively, ``Amex Options Products'')
in May 2013.\4\ Fees cover all six products.\5\
---------------------------------------------------------------------------
\4\ See Securities Exchange Act Release No. 69553 (May 10,
2013), 78 FR 28926 (May 16, 2013) (SR-NYSEMKT-2013-40) (``2013
Release'').
\5\ The Exchange began offering ArcaBook for Amex Options--
Complex separately at no charge on May 1, 2014. See Securities
Exchange Act Release No. 72074 (May 1, 2014), 79 FR 26277 (May 7,
2014) (SR-NYSEArca-2014-51).
---------------------------------------------------------------------------
Under the proposal, non-display use would continue to mean
accessing, processing, or consuming an Exchange data product delivered
via direct and/or Redistributor \6\ data feeds for a purpose other than
in support of a data recipient's display or further internal or
external redistribution (``Non-Display Use''). As is the case today,
non-display fees would apply to the Non-Display Use of the data product
as part of automated calculations or algorithms to support trading
decision-making processes or the operation of trading platforms.
---------------------------------------------------------------------------
\6\ ``Redistributor'' means a vendor or any person that provides
a real-time NYSE data product to a data recipient or to any system
that a data recipient uses, irrespective of the means of
transmission or access.
---------------------------------------------------------------------------
The Exchange is proposing to expand the types of uses considered
Non-Display Use to also include non-trading uses. In addition, the
proposal would specify that Non-Display Use would include any trading
use, rather than only certain types of trading, such as high frequency
or algorithmic trading, as under the current fee structure. Under the
proposal, examples of Non-Display Use would include any trading in any
asset class, automated order or quote generation and/or order pegging,
price referencing for algorithmic trading or smart order routing,
operations control programs, investment analysis, order verification,
surveillance programs, risk management, compliance, and portfolio
management. The Exchange believes that non-trading uses benefit data
recipients by allowing users to automate functions, achieving greater
speed and accuracy, and in turn, for example, reducing costs of labor
to perform the functions manually. This approach would address the
difficulties of monitoring and auditing different types of trading
versus non-trading uses of the data and the burden of counting devices
used for non-trading purposes under the current fees.
Proposed Changes to Non-Display Fees
The Exchange proposes to amend the fee structure applicable to Non-
Display Use of Amex Options Products. Specifically, the Exchange
proposes certain changes to the three categories of, and fees
applicable to, data recipients. The Exchange also proposes
corresponding changes to the Fee Schedule text to remove references to
the current category descriptions.
Under the proposal, Category 1 Fees would apply when a data
recipient's Non-Display Use of real-time market data is on its own
behalf as opposed to on behalf of its clients. This proposal represents
an expansion of the application of Category 1 Fees, which currently
apply solely to the Non-Display Use of real time market data for the
purpose of principal trading, to usage of such data for non-trading
purposes.
Under the proposal, Category 2 Fees would apply to a data
recipient's Non-Display Use of real-time market data on behalf of its
clients as opposed to on its own behalf. This proposal also represents
an expansion of the application of Category 2 Fees, which currently
apply solely to trading activities to facilitate a customer business,
to usage of such data for non-trading purposes. In contrast to the
current fee structure, data recipients will not be liable for Category
2 Non-Display fees for which they are also paying Category 1 Non-
Display fees.\7\
---------------------------------------------------------------------------
\7\ See 2013 Release, supra note 4, at 28929.
---------------------------------------------------------------------------
The Exchange believes its proposal to apply Category 1 Fees and
Category 2 Fees to Non-Display Use of market data for non-trading
purposes would address the difficulties of monitoring and auditing
trading versus non-trading uses of the data and the burden of counting
devices used for purposes of applying the per-device fees. As discussed
in more detail in the 2013 Release,\8\ the ability to accurately count
devices and audit such counts creates administrative challenges for
vendors, data recipients, and the Exchange.
---------------------------------------------------------------------------
\8\ See id. at 28928.
---------------------------------------------------------------------------
Under the proposal, Category 3 Fees would apply to data recipients'
Non-Display Use of real-time market data for the purpose of internally
matching buy and sell orders within an organization, including matching
customer orders on a data recipient's own behalf and/or on behalf of
its clients. This category would apply to Non-Display Use in trading
platform(s), such as, but not restricted to, alternative trading
systems (``ATSs''), broker crossing networks, broker crossing systems
not filed as ATSs, dark pools, multilateral trading facilities,
exchanges and systematic internalization systems. Currently, Category 3
Fees apply where a data recipient's non-display use of market data is,
in whole or in part, for the purpose of providing reference prices in
the operation of one or more trading platforms. The Exchange believes
its proposed revision to its description of the data recipients to whom
Category 3 Fees apply is more precise because it focuses on the
functions of internally matching orders.
In addition, the Exchange is proposing to change the application of
Category 3 Fees to data recipients that also use data for purposes that
give rise to Category 1 and/or Category 2 Fees. Currently, a data
recipient is not liable for Category 3 Fees for those Amex Options
Products for which it is also paying Category 1 and/or Category 2
Fees.\9\ Under the proposal, a data recipient's Non-Display Use of
real-time market data for Category 3 purposes would require such data
recipient to pay Category 3 Fees in addition to any Category 1 Fees or
Category 2 Fees it is required to pay for Non-Display Use of market
data.
---------------------------------------------------------------------------
\9\ See id.
---------------------------------------------------------------------------
There will continue to be no monthly or other reporting
requirements for data recipients' Non-Display Use. However, the
Exchange continues to reserve the right to audit data recipients' Non-
Display Use of Exchange market data products in accordance with the
Exchange's vendor and subscriber agreements.
A data recipient that receives real-time Exchange market data for
Non-Display Use would be required to complete and submit a Non-Display
Use Declaration before September 1, 2014. The Non-Display Use
Declaration would
[[Page 54327]]
replace the current declaration on the NYSE Euronext Non-Display Usage
Declaration.\10\ A firm subject to Category 3 Fees would be required to
identify each platform that uses data on a Non-Display Use basis, such
as ATSs and broker crossing systems not registered as ATSs, as part of
the Non-Display Use Declaration. Beginning in 2016, data recipients
would be required to submit, by January 31 of each year, a Non-Display
Use Declaration. In addition, if a data recipient's use of real-time
Exchange market data changes at any time after the data recipient
submits a Non-Display Use Declaration, the data recipient would be
required to update it at the time of the change to reflect the change
of use.
---------------------------------------------------------------------------
\10\ As described in more detail in the Statutory Basis section,
in order to modulate the overall fee increase that could apply, if a
firm subject to Category 3 Fees has more than three platforms, it
would only be required to declare three platforms.
---------------------------------------------------------------------------
Comparison of Current Fees to Proposed Fees
The chart below compares the proposed changes to current monthly
fees:
------------------------------------------------------------------------
Data feed Current fee Proposed fee
------------------------------------------------------------------------
Amex Options Products Non- $1,000............ $5,000.*
Display Category 1.
Amex Options Products Non- $1,000............ $5,000.*
Display Category 2.
Amex Options Products Non- $1,000, or $0 if $5,000, capped at
Display Category 3. Category 1 or 2 $15,000.
fees paid.
------------------------------------------------------------------------
* Data recipients will not be liable for Category 2 Non-Display fees for
which they are also paying Category 1 Non-Display fees.
2. Statutory Basis
The Exchange believes that the proposed rule change is consistent
with the provisions of Section 6 of the Act,\11\ in general, and
Sections 6(b)(4) and 6(b)(5) of the Act,\12\ in particular, in that it
provides an equitable allocation of reasonable fees among users and
recipients of the data and is not designed to permit unfair
discrimination among customers, issuers, and brokers.
---------------------------------------------------------------------------
\11\ 15 U.S.C. 78f(b).
\12\ 15 U.S.C. 78f(b)(4), (5).
---------------------------------------------------------------------------
The Exchange believes that charging for non-trading uses is
reasonable because data recipients can derive substantial value from
such uses, for example, by automating tasks so that they can be
performed more quickly and accurately and less expensively than if they
were performed manually. The Exchange also notes that The NASDAQ Stock
Market (``NASDAQ'') and NASDAQ OMX PHLX (``Phlx'') do not make any
distinction in their non-display use fees between trading or non-
trading uses, and as such, the proposed change will harmonize the
Exchange's approach with those exchanges. Finally, the Exchange notes
that eliminating the trading versus non-trading distinction would
substantially simplify fee calculations and ease administrative burdens
for the Exchange.
After further experience, the Exchange also believes that it is
more equitable and not unfairly discriminatory to eliminate the
distinction for non-trading versus trading uses in light of the
significant value of both types of uses. The Exchange notes that
because non-display fees are flat fees, the expansion to cover non-
trading uses could only result in a fee increase for a data recipient
that is using the data solely for non-trading purposes and is only
subject to per-device fees; at this time, the Exchange has not
identified such a data recipient. Based on data available to the
Exchange, all data recipients use the data for at least one trading
purpose, and therefore the changes to the fees that they will pay under
the proposal would not be due to the elimination of the distinction
between trading and non-trading uses. The Exchange further notes that
based on Non-Display Use Declarations submitted to date, some users
have declared no Non-Display Use, and as such the proposed changes
would have no impact on them.
The Exchange believes that it is reasonable to require annual
submissions of the Non-Display Use Declaration so that the Exchange
will have current and accurate information about the use of its market
data products and can correctly assess fees for the uses of those
products. The annual submission requirement is equitable and not
unfairly discriminatory because it will apply to all users.
The Exchange believes that the proposed fee increases of $4,000 per
month for each of Categories 1, 2, and 3 is reasonable. In establishing
the non-display fees in May 2013, the Exchange set its fees below
comparable fees charged by certain of its competitors.\13\ After
gaining further experience with its new display/non-display fee
structure, the Exchange believes that the proposed fees better reflect
the significant value of the non-display data to data recipients, which
purchase such data on an entirely voluntary basis. Non-display data can
be used by data recipients for a wide variety of profit-generating
purposes, including proprietary and agency trading and smart order
routing, as well as by data recipients that operate order matching and
execution platforms that compete directly with the Exchange for order
flow. The data also can be used for a variety of non-trading purposes
that indirectly support trading, such as risk management and
compliance. While some of these non-trading uses do not directly
generate revenues, they can nonetheless substantially reduce the
recipient's costs by automating such functions so that they can be
carried out in a more efficient and accurate manner and reduce errors
and labor costs, thereby benefiting end users. The Exchange believes
that the proposed fees directly and appropriately reflect the
significant value of using non-display data in a wide range of
computer-automated functions relating to both trading and non-trading
activities and that the number and range of these functions continue to
grow through innovation and technology developments.\14\
---------------------------------------------------------------------------
\13\ See 2013 Release, supra note 4, at 28930.
\14\ See also Exchange Act Release No. 69157, March 18, 2013, 78
FR 17946, 17949 (March 25, 2013) (SR-CTA/CQ-2013-01) (``[D]ata feeds
have become more valuable, as recipients now use them to perform a
far larger array of non-display functions. Some firms even base
their business models on the incorporation of data feeds into black
boxes and application programming interfaces that apply trading
algorithms to the data, but that do not require widespread data
access by the firm's employees. As a result, these firms pay little
for data usage beyond access fees, yet their data access and usage
is critical to their businesses.'').
---------------------------------------------------------------------------
The fee increases are also reasonable in that they support the
Exchange's efforts to regularly upgrade systems to support more modern
data distribution formats and protocols as technology evolves. For
example, the Exchange will make its proprietary data products available
over an upgraded distribution channel and protocol ``XDP'' early next
year.
Charging a separate fee for Category 3 data recipients that already
pay a fee under Category 1 or 2 is reasonable
[[Page 54328]]
because it eliminates what is effectively a discount for such data
recipients under the current Fee Schedule and results in a more
equitable allocation of fees to users that derive a benefit from a
Category 3 use, and as such is not unfairly discriminatory. The current
fee can be viewed as having an effective non-display fee cap of $2,000
while the proposed fee would have an effective non-display fee cap of
$20,000. The Exchange believes that the proposed fees (and their
associated caps) more closely correspond to the value that Category 3
recipients derive from the various uses of the data, some of which are
operating various types of alternative trading venues that directly
compete for order flow with the Exchange. Limiting the fees in Category
3 to no more than three trading platforms and charging only one fee for
users that fall under both Category 1 and 2 is reasonable because it
modulates the size of the fee increase for certain recipients as
compared to what they pay under the current fee structure, in much the
same manner as the current fee does by limiting the non-display fees to
a maximum of two categories. The Exchange does not believe that it will
be burdensome for Category 3 recipients to determine, or the Exchange
to audit, whether a recipient has one, two, three or more separate
platforms.
The fees are also competitive with offerings by other exchanges,
which structure and set their fees in a variety of ways. For example,
NASDAQ Options Market (``NOM'') offers a $2,500 per month ``Non-Display
Enterprise License'' fee that permits distribution of Best of NASDAQ
Options (``BONO'') or NASDAQ ITCH-to-Trade Options (``ITTO'') to an
unlimited number of non-display devices within a firm without any per
user charge.\15\ In addition, Phlx offers an alternative $10,000 per
month ``Non-Display Enterprise License'' fee that permits distribution
to an unlimited number of internal non-display subscribers without
incurring additional fees for each internal subscriber.\16\ The Non-
Display Enterprise License covers non-display subscriber fees for all
Phlx proprietary direct data feed products (Top of Phlx Options
(``TOPO''), TOPO Plus Orders, PHLX Orders and PHLX Depth Data feeds)
and is in addition to any other associated distributor fees for Phlx
proprietary direct data feed products,\17\ The Exchange further notes
that its proposed fees are less than the non-display fees charged by
the Options Price Reporting Authority (``OPRA'').\18\
---------------------------------------------------------------------------
\15\ See NASDAQ Options Rules Chapter XV, Section 4.
Alternatively, NOM charges each professional subscriber $5 per month
for BONO and $10 per month for ITTO.
\16\ See Section IX of the NASDAQ OMX PHLX LLC Pricing Schedule
and Securities Exchange Act Release No. 68576 (January 3, 2013), 78
FR 1886 (January 9, 2013) (SR-Phlx-2012-145). Alternatively, Phlx
charges each professional subscriber $40 per month.
\17\ See id.
\18\ See Securities Exchange Act Release No. 67648 (August 14,
2012), 77 FR (August 17, 2012) (SR-OPRA-2012-04) (establishing
effective October 1, 2012 a non-display application fee of $500/
installation/month, with an enterprise fee alternative of $7500/
month that would permit a professional subscriber to receive access
to OPRA data for use in an unlimited number of non-display
application installations).
---------------------------------------------------------------------------
The Exchange also notes that all of the products described herein
are entirely optional. The Exchange is not required to make these
proprietary data products available or to offer any specific pricing
alternatives to any customers, nor is any firm required to purchase any
of the products. Firms that do purchase non-display products do so with
the primary goals of using them to increase revenues, reduce expenses,
and in some instances compete directly with the Exchange for order
flow; those firms are able to determine for themselves whether any
specific product such as these are attractively priced or not.
Firms that do not wish to purchase the data at the new prices have
a wide variety of alternative market data products from which to
choose,\19\ or if the non-display data products do not provide
sufficient value to firms as offered based on the uses those firms have
or planned to make of them, such firms may simply choose to conduct
their business operations in ways that do not require those data
products. The Exchange notes that broker-dealers are not required to
purchase proprietary market data to comply with their best execution
obligations.\20\ Similarly, there is no requirement in Regulation NMS
or any other rule that proprietary data be utilized for order routing
decisions.
---------------------------------------------------------------------------
\19\ See supra notes 14-17. Because ArcaBook for Amex Options--
Trades and ArcaBook for Amex Options--Top of Book are subsets of the
consolidated core data offered by OPRA, customers may choose to
purchase those consolidated data products instead.
\20\ See In the Matter of the Application of Securities Industry
And Financial Markets Association For Review of Actions Taken by
Self-Regulatory Organizations, Release Nos. 34-72182; AP-3-15350;
AP-3-15351 (May 16, 2014).
---------------------------------------------------------------------------
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), upheld reliance by the Securities and Exchange Commission
(``Commission'') upon the existence of competitive market mechanisms to
set reasonable and equitably allocated fees for proprietary 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.'
635 F.3d at 535 (quoting H.R. Rep. No. 94-229 at 92 (1975), as
reprinted in 1975 U.S.C.C.A.N. 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.' '' \21\
---------------------------------------------------------------------------
\21\ NetCoalition, 615 F.3d at 535.
---------------------------------------------------------------------------
As explained below in the Exchange's Statement on Burden on
Competition, the Exchange believes that there is substantial evidence
of competition in the marketplace for proprietary market data and that
the Commission can rely upon such evidence in concluding that the fees
established in this filing are the product of competition and therefore
satisfy the relevant statutory standards. In addition, the existence of
alternatives to these data products, such as consolidated data and
proprietary data from other sources, as described below, further
ensures that the Exchange cannot set unreasonable fees, or fees that
are unreasonably discriminatory, when vendors and subscribers can
select such alternatives.
As the NetCoalition decision noted, the Commission is not required
to undertake a cost-of-service or ratemaking approach. The Exchange
believes that, even if it were possible as a matter of economic theory,
cost-based pricing for non-core market data would be so complicated
that it could not be done practically or offer any significant
benefits.\22\
---------------------------------------------------------------------------
\22\ The Exchange believes that cost-based pricing would be
impractical because it would create enormous administrative burdens
for all parties, including the Commission, to cost-regulate a large
number of participants and standardize and analyze extraordinary
amounts of information, accounts, and reports. In addition, and as
described below, it is impossible to regulate market data prices in
isolation from prices charged by markets for other services that are
joint products. Cost-based rate regulation would also lead to
litigation and may distort incentives, including those to minimize
costs and to innovate, leading to further waste. Under cost-based
pricing, the Commission would be burdened with determining a fair
rate of return, and the industry could experience frequent rate
increases based on escalating expense levels. Even in industries
historically subject to utility regulation, cost-based ratemaking
has been discredited. As such, the Exchange believes that cost-based
ratemaking would be inappropriate for proprietary market data and
inconsistent with Congress's direction that the Commission use its
authority to foster the development of the national market system,
and that market forces will continue to provide appropriate pricing
discipline. See Appendix C to NYSE's comments to the Commission's
2000 Concept Release on the Regulation of Market Information Fees
and Revenues, which can be found on the Commission's Web site at
https://www.sec.gov/rules/concept/s72899/buck1.htm.
---------------------------------------------------------------------------
[[Page 54329]]
For these reasons, the Exchange believes that the proposed fees are
reasonable, equitable, and not unfairly discriminatory.
B. Self-Regulatory Organization's Statement on Burden on Competition
The Exchange does not believe that the proposed rule change will
impose any burden on competition that is not necessary or appropriate
in furtherance of the purposes of the Act. An exchange's ability to
price its proprietary market data feed products is constrained by
actual competition for the sale of proprietary market data products,
the joint product nature of exchange platforms, and the existence of
alternatives to the Exchange's proprietary data.
The Existence of Actual Competition. The market for proprietary
options data products is currently competitive and inherently
contestable because there is fierce competition for the inputs
necessary for the creation of proprietary data and strict pricing
discipline for the proprietary products themselves. Numerous exchanges
compete with one another for options trades and sales of options market
data itself, providing ample opportunities for entrepreneurs who wish
to compete in any or all of those areas, including producing and
distributing their own options market data. Proprietary options data
products are produced and distributed by each individual exchange, as
well as other entities, in a vigorously competitive market. Indeed, the
U.S. Department of Justice (``DOJ'') (the primary antitrust regulator)
has expressly acknowledged the aggressive actual competition among
exchanges, including for the sale of proprietary market data. In 2011,
the DOJ stated that exchanges ``compete head to head to offer real-time
equity data products. These data products include the best bid and
offer of every exchange and information on each equity trade, including
the last sale.'' \23\ Similarly, the options markets vigorously compete
with respect to options data products.\24\
---------------------------------------------------------------------------
\23\ Press Release, U.S. Department of Justice, Assistant
Attorney General Christine Varney Holds Conference Call Regarding
NASDAQ OMX Group Inc. and IntercontinentalExchange Inc. Abandoning
Their Bid for NYSE Euronext (May 16, 2011), available at https://www.justice.gov/iso/opa/atr/speeches/2011/at-speech-110516.html.
\24\ See, e.g., Securities Exchange Act Release No. 67466 (July
19, 2012), 77 FR 43629 (July 25, 2012) (SR-Phlx-2012-93), which
describes a variety of options market data products and their
pricing.
---------------------------------------------------------------------------
Moreover, competitive markets for order flow, executions, and
transaction reports provide pricing discipline for the inputs of
proprietary options data products and therefore constrain markets from
overpricing proprietary options market data. Broker-dealers send their
order flow to multiple venues, rather than providing them all to a
single venue, which in turn reinforces this competitive constraint.
Options markets, similar to the equities markets, are highly
fragmented.\25\
---------------------------------------------------------------------------
\25\ See, e.g., Press Release, TABB Says US Equity Options
Market Makers Need Scalable Technology to Compete in Today's Complex
Market Structure (February 25, 2013), available at https://www.tabbgroup.com/PageDetail.aspx?PageID=16&ItemID=1231;
Fragmentation Vexes Options Markets (April 21, 2014), available at
https://marketsmedia.com/fragmentation-vexes-options-market/.
---------------------------------------------------------------------------
If an exchange succeeds in its competition for quotations, order
flow, and trade executions, then it earns trading revenues and
increases the value of its proprietary options market data products
because they will contain greater quote and trade information.
Conversely, if an exchange is less successful in attracting quotes,
order flow, and trade executions, then its options market data products
may be less desirable to customers using them in support of order
routing and trading decisions in light of the diminished content; data
products offered by competing venues may become correspondingly more
attractive. Thus, competition for quotations, order flow, and trade
executions puts significant pressure on an exchange to maintain both
execution and data fees at reasonable levels.
In addition, in the case of products that are distributed through
market data vendors, such as Bloomberg and Thompson Reuters, the
vendors themselves provide additional price discipline for proprietary
data products because they control the primary means of access to
certain end users. These vendors impose price discipline based upon
their business models. For example, vendors that assess a surcharge on
data they sell are able to refuse to offer proprietary products that
their end users do not or will not purchase in sufficient numbers.
Vendors will not elect to make available Amex Options Products
described herein unless their customers request them, and customers
will not elect to pay the proposed increased fees for non-display uses
unless the non-display uses of these data products can provide value by
sufficiently increasing revenues or reducing costs in the customer's
business in a manner that will offset the fees. All of these factors
operate as constraints on pricing proprietary data products.
Joint Product Nature of Exchange Platform. Transaction execution
and proprietary data products are complementary in that market data is
both an input and a byproduct of the execution service. In fact,
proprietary market data and trade executions are a paradigmatic example
of joint products with joint costs. The decision whether and on which
platform to post an order will depend on the attributes of the
platforms where the order can be posted, including the execution fees,
data availability and quality, and price and distribution of their data
products. Without a platform to post quotations, receive orders, and
execute trades, exchange data products would not exist.
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 platform for posting quotes,
accepting orders, and executing transactions and the cost of regulating
the exchange to ensure its fair operation and maintain investor
confidence. The total return that a trading platform earns reflects the
revenues it receives from both products and the joint costs it incurs.
Moreover, an exchange's broker-dealer customers generally view the
costs of transaction executions and market data as a unified cost of
doing business with the exchange. A broker-dealer will only choose to
direct orders to an exchange if the revenue from the transaction
exceeds its cost, including the cost of any market data that the
broker-dealer chooses to buy in support of its order routing and
trading decisions. If the costs of the transaction are not offset by
its value, then the broker-dealer may choose instead not to purchase
the product and trade away from that exchange. There is substantial
evidence of the strong correlation between order flow and market data
purchases. For example, in July 2014 more than 80% of the options
transaction volume on each of NYSE MKT and NYSE Arca was executed by
market participants that purchased one or more proprietary market data
products. A super-competitive increase in the fees for either
executions or market data would create a risk of reducing an exchange's
revenues from both products.
Other market participants have noted that proprietary market data
and trade executions are joint products of a joint
[[Page 54330]]
platform and have common costs.\26\ The Exchange agrees with and adopts
those discussions and the arguments therein. The Exchange also notes
that the economics literature confirms that there is no way to allocate
common costs between joint products that would shed any light on
competitive or efficient pricing.\27\
---------------------------------------------------------------------------
\26\ See Securities Exchange Act Release No. 72153 (May 12,
2014), 79 FR 28575, 28578 n.15 (May 16, 2014) (SR-NASDAQ-2014-045)
(``[A]ll 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.'').
See also Securities Exchange Act Release No. 62907 (September 14,
2010), 75 FR 57314, 57317 (September 20, 2010) (SR-NASDAQ-2010-110),
and Securities Exchange Act Release No. 62908 (September 14, 2010),
75 FR 57321, 57324 (September 20, 2010) (SR-NASDAQ-2010-111).
\27\ See generally Mark Hirschey, Fundamentals of Managerial
Economics, at 600 (2009) (``It is important to note, however, that
although it is possible to determine the separate marginal costs of
goods produced in variable proportions, it is impossible to
determine their individual average costs. This is because common
costs are expenses necessary for manufacture of a joint product.
Common costs of production--raw material and equipment costs,
management expenses, and other overhead--cannot be allocated to each
individual by-product on any economically sound basis.. . . Any
allocation of common costs is wrong and arbitrary.''). This is not
new economic theory. See, e.g., F. W. Taussig, ``A Contribution to
the Theory of Railway Rates,'' Quarterly Journal of Economics V(4)
438, 465 (July 1891) (``Yet, surely, the division is purely
arbitrary. These items of cost, in fact, are jointly incurred for
both sorts of traffic; and I cannot share the hope entertained by
the statistician of the Commission, Professor Henry C. Adams, that
we shall ever reach a mode of apportionment that will lead to
trustworthy results.'').
---------------------------------------------------------------------------
Analyzing the cost of market data product production and
distribution in isolation from the cost of all of the inputs supporting
the creation of market data and market data products will inevitably
underestimate the cost of the data and data products because it is
impossible to obtain the data inputs to create market data products
without a fast, technologically robust, and well-regulated execution
system, and system and regulatory costs affect the price of both
obtaining the market data itself and creating and distributing market
data products. It would be equally misleading, however, to attribute
all of an exchange's costs to the market data portion of an exchange's
joint products. Rather, all of an 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.
As noted above, the level of competition and contestability in the
market is evident in the numerous alternative venues that compete for
order flow, including 12 self-regulatory organization (``SRO'') options
markets. Two of the 12 have launched operations since December
2012.\28\ The Exchange believes that these new entrants demonstrate
that competition is robust.
---------------------------------------------------------------------------
\28\ See Securities Exchange Act Release Nos. 70050 (July 26,
2013), 78 FR (August 1, 2013) (approving exchange registration for
Topaz Exchange, LLC) (known as ISE Gemini); and 68341 (December 3,
2012), 77 FR 73065 (December 7, 2012) (approving exchange
registration for Miami International Securities Exchange LLC
(``Miami Exchange'')).
---------------------------------------------------------------------------
Competition among trading platforms can be expected to constrain
the aggregate return that each platform earns from the sale of its
joint products, but different trading platforms may choose from a range
of possible, and equally reasonable, pricing strategies as the means of
recovering total costs. For example, some platforms may choose to pay
rebates to attract orders, charge relatively low prices for market data
products (or provide market data products free of charge), and charge
relatively high prices for accessing posted liquidity. Other platforms
may choose a strategy of paying lower rebates (or no rebates) to
attract orders, setting relatively high prices for market data
products, and setting relatively low prices for accessing posted
liquidity. For example, BATS Exchange, Inc. (``BATS''), which
previously operated as an ATS and obtained exchange status in 2008, has
provided certain market data at no charge on its Web site in order to
attract more order flow, and uses revenue rebates from resulting
additional executions to maintain low execution charges for its
users.\29\ The Exchange currently offers ArcaBook for Arca Options--
Complex for free. 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.\30\
---------------------------------------------------------------------------
\29\ See description of free market data from BATS Options,
available at https://www.batsoptions.com/marketdata/
products/. This is simply a securities market-specific example of
the well-established principle that in certain circumstances more
sales at lower margins can be more profitable than fewer sales at
higher margins; this example is additional evidence that market data
is an inherent part of a market's joint platform.
\30\ The Exchange notes that a small number of Category 3 non-
display data recipients could be using the market data strictly for
competitive purposes (e.g., other exchanges) or for business
purposes unrelated to trading or investment (e.g., Internet portals
that wish to attract ``eyeballs'' to their pages primarily generate
advertising revenue for themselves). The Exchange does not believe
that the proposed fees will impose any unnecessary burden on these
competitors or other businesses.
---------------------------------------------------------------------------
Existence of Alternatives. The large number of SROs that currently
produce proprietary data or are currently capable of producing it
provides further pricing discipline for proprietary data products. Each
SRO is currently permitted to produce and sell proprietary data
products, and many currently do or have announced plans to do so,
including but not limited to the Exchange, NYSE Arca, Inc.; Chicago
Board Options Exchange, Incorporated; C2 Options Exchange,
Incorporated; International Securities Exchange, LLC; ISE Gemini;
NASDAQ; Phlx; BX; BATS; and Miami Exchange.
The fact that proprietary data from vendors can bypass SROs is
significant in two respects. First, non-SROs can compete directly with
SROs for the production and sale of proprietary data products. By way
of example, BATS and NYSE Arca both published proprietary data on the
Internet before registering as exchanges. Second, because a single
order or transaction report can appear in an SRO proprietary product, a
non-SRO proprietary product, or both, the amount of data available via
proprietary products is greater in size than the actual number of
orders and transaction reports that exist in the marketplace. For
example, with respect to ArcaBook for Arca Options--Trades and ArcaBook
for Arca Options--Top of Book, the data appears in the real-time core
data offered by OPRA for a fee. Close substitute products also are
offered by several competitors.\31\ Because market data users can find
suitable substitutes for most proprietary market data products, a
market that overprices its market data products stands a high risk that
users may substitute one or more other sources of market data
information for its own.
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\31\ See supra notes 15-18.
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Those competitive pressures imposed by available alternatives are
evident in the Exchange's proposed pricing. As noted above, the
proposed non-display fees are generally lower than the maximum non-
display fees charged by other exchanges such as NASDAQ and Phlx, for
comparable products.\32\
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\32\ Id.
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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 and inexpensive. 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
[[Page 54331]]
Tradebook, Island, RediBook, Attain, TrackECN, and BATS. As noted
above, BATS launched as an ATS in 2006 and became an exchange in 2008.
Two new options exchanges have launched operations since December
2012.\33\
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\33\ See supra note 28.
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In establishing the proposed fees, the Exchange considered the
competitiveness of the market for proprietary options market data and
all of the implications of that competition. The Exchange believes that
it has considered all relevant factors, and has not considered
irrelevant factors, in order to establish fair, reasonable, and not
unreasonably discriminatory fees and an equitable allocation of fees
among all users. The existence of numerous alternatives to the
Exchange's products, including proprietary data from other sources,
ensures that the Exchange cannot set unreasonable fees, or fees that
are unreasonably discriminatory, when vendors and subscribers can elect
these alternatives or choose not to purchase a specific proprietary
data product if the attendant fees are not justified by the returns
that any particular vendor or data recipient would achieve through the
purchase.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants, or Others
No written comments were solicited or received with respect to the
proposed rule change.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
The foregoing rule change is effective upon filing pursuant to
Section 19(b)(3)(A) \34\ of the Act and subparagraph (f)(2) of Rule
19b-4 \35\ thereunder, because it establishes a due, fee, or other
charge imposed by the Exchange.
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\34\ 15 U.S.C. 78s(b)(3)(A).
\35\ 17 CFR 240.19b-4(f)(2).
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At any time within 60 days of the filing of such proposed rule
change, the Commission summarily may temporarily suspend such rule
change if it appears to the Commission that such action is necessary or
appropriate in the public interest, for the protection of investors, or
otherwise in furtherance of the purposes of the Act. If the Commission
takes such action, the Commission shall institute proceedings under
Section 19(b)(2)(B) \36\ of the Act to determine whether the proposed
rule change should be approved or disapproved.
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\36\ 15 U.S.C. 78s(b)(2)(B).
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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-NYSEMKT-2014-73 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-NYSEMKT-2014-73. This
file number should be included on the subject line if email is used. To
help the Commission process and review your comments more efficiently,
please use only one method. The Commission will post all comments on
the Commission's Internet Web site (https://www.sec.gov/rules/sro.shtml). Copies of the submission, all subsequent amendments, all
written statements with respect to the proposed rule change that are
filed with the Commission, and all written communications relating to
the proposed rule change between the Commission and any person, other
than those that may be withheld from the public in accordance with the
provisions of 5 U.S.C. 552, will be available for Web site viewing and
printing in the Commission's Public Reference Room, 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 such filing also will be available
for inspection and copying at the principal office of the Exchange. All
comments received will be posted without change; the Commission does
not edit personal identifying information from submissions. You should
submit only information that you wish to make available publicly. All
submissions should refer to File Number SR-NYSEMKT-2014-73 and should
be submitted on or before October 2, 2014.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\37\
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\37\ 17 CFR 200.30-3(a)(12).
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Kevin M. O'Neill,
Deputy Secretary.
[FR Doc. 2014-21647 Filed 9-10-14; 8:45 am]
BILLING CODE 8011-01-P