Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Order Approving a Proposed Rule Change To Amend Rule 4758, 80847-80849 [2015-32527]
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Federal Register / Vol. 80, No. 248 / Monday, December 28, 2015 / Notices
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 No. SR–BATS–
2015–116 and should be submitted on
or before January 19, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.22
Brent J. Fields,
Secretary.
[FR Doc. 2015–32534 Filed 12–24–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76718; File No. SR–
NASDAQ–2015–112]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Order
Approving a Proposed Rule Change To
Amend Rule 4758
December 30, 2015.6 NASDAQ
subsequently submitted a second
response letter.7 This order approves the
proposed rule change.
II. Description of the Proposal
NASDAQ is proposing to amend Rule
4758 to add a new order routing
option—RTFY—for Designated Retail
Orders (‘‘DROs’’).8 NASDAQ states that
retail order firms 9 often send nonmarketable order flow to post and
display on exchanges. However, some
orders that have been deemed to be nonmarketable by the entering firm become
marketable by the time the exchange
receives them.10 NASDAQ notes that
these orders ultimately remove liquidity
from the NASDAQ order book even
though the firm entering the order did
not intend them to remove liquidity.11
Under the proposal, a DRO that is
marketable upon receipt by NASDAQ
and that elects to follow the RTFY
routing option will be routed to
destinations in the System routing table
instead of immediately removing
liquidity from the Exchange order
book—unless explicitly instructed by
the entering party to check the Exchange
order book first.12 RTFY orders may
December 21, 2105.
I. Introduction
On September 21, 2015, The
NASDAQ Stock Market LLC
(‘‘NASDAQ’’ or ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (‘‘Commission’’), pursuant
to Section 19(b)(1) of the Securities
Exchange Act of 1934 (‘‘Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to adopt a new routing option,
the Retail Order Process (‘‘RTFY’’). The
proposed rule change was published for
comment in the Federal Register on
October 1, 2015.3 The Commission
received two comment letters on the
proposed rule change 4 and a response
letter from NASDAQ.5 On November 3,
2015, the Commission extended the
time period within which to approve
the proposed rule change, disapprove
the proposed rule change, or institute
proceedings to determine whether to
disapprove the proposed rule change, to
22 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 75987
(September 25, 2015), 80 FR 59210 (‘‘Notice’’).
4 See letter from Joseph Saluzzi, Themis Trading
LLC to the Commission, dated September 29, 2015
(‘‘Themis Letter’’); and letter from Suzanne Shatto
to the Commission, dated October 6, 2015 (‘‘Shatto
Letter’’).
5 See letter from Jonathan F. Cayne, Senior
Associate General Counsel, NASDAQ to Brent J.
Fields, Secretary, Commission, dated October 22,
2015 (‘‘NASDAQ Response’’).
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6 See Securities Exchange Act Release No. 76335,
80 FR 69256 (November 9, 2015).
7 See letter from Jonathan F. Cayne, Senior
Associate General Counsel, NASDAQ to Brent J.
Fields, Secretary, Commission, dated December 11,
2015 (‘‘NASDAQ Supplemental Response’’).
8 A Designated Retail Order is an agency or
riskless principal order that meets the criteria of
FINRA Rule 5320.03 and that originates from a
natural person and is submitted to NASDAQ by a
member that designates it pursuant to Rule 7018,
provided that no change is made to the terms of the
order with respect to price or side of market and
the order does not originate from a trading
algorithm or any other computerized methodology.
An order from a ‘‘natural person’’ can include
orders on behalf of accounts that are held in a
corporate legal form—such as an Individual
Retirement Account, Corporation, or a Limited
Liability Company—that has been established for
the benefit of an individual or group of related
family members, provided that the order is
submitted by an individual. Members must submit
a signed written attestation, in a form prescribed by
NASDAQ, that they have implemented policies and
procedures that are reasonably designed to ensure
that substantially all orders designated by the
member as DROs comply with these requirements.
Orders may be designated on an order-by-order
basis, or by designating all orders on a particular
order entry port as DROs. See NASDAQ Rule 7018.
9 The term ‘‘retail order firms’’ refers to NASDAQ
member firms that provide orders that qualify as
Designated Retail Orders under NASDAQ Rule
7018.
10 See Notice, 80 FR at 59210.
11 See id.
12 See id. The term ‘‘System routing table’’ refers
to the proprietary process for determining the
specific trading venues to which the System routes
orders and the order in which it routes them.
NASDAQ reserves the right to maintain a different
System routing table for different routing options
and to modify the System routing table at any time
without notice. See NASDAQ Rule 4758(a)(1)(A).
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remove liquidity from the Exchange
book after routing to other
destinations.13 All non-marketable
RTFY orders will post on the Exchange
book.14
According to NASDAQ, the
destinations in the System routing table
for RTFY will include OTC market
makers,15 which may also be registered
NASDAQ market makers.16 NASDAQ
believes these market makers will likely
provide the greatest opportunity for
price improvement for the DROs, and
the RTFY routing option will benefit
DROs by providing additional price
improvement opportunities for retail
investors.17 NASDAQ anticipates that
the RTFY routing option will route to
trading centers in the System routing
table that have experience executing
and providing price improvement to
DROs.18
As proposed, an order using the RTFY
routing option will be sent to the
primary listing exchange for opening,
reopening, and closing auctions.19
Orders received in non-NASDAQ listed
securities prior to market open that are
not eligible for the pre-market session
will be submitted to the primary listing
market for inclusion in that market’s
opening process.20 Orders received in
NASDAQ-listed securities prior to
market open that are not eligible for the
pre-market session will follow normal
pre-market processing.21 Orders
received prior to the market open that
are eligible for the pre-market session
will be posted—and routed if
13 See
Notice, 80 FR at 59210.
a RTFY order is posted on the Exchange,
either because it was non-marketable when it was
received or it has exhausted all available liquidity
within its limit price—including on the Exchange,
Regulation NMS protected quotations and other
destinations in the System routing table—and the
order is subsequently locked or crossed by another
market center, the System will not route to the
locking or crossing market center. See id.
15 An ‘‘OTC market maker’’ in a stock is defined
in Rule 600(b)(52) of Regulation NMS as, in general,
a dealer that holds itself out as willing to buy and
sell the stock, otherwise than on a national
securities exchange, in amounts of less than block
size (less than 10,000 shares).
16 See Notice, 80 FR at 59210.
17 See id. NASDAQ believes that, because retail
orders are generally smaller on average, they are
often able to receive better prices than the
prevailing national best bid and offer. See id. at
59211. NASDAQ believes that this is achieved by
retail order firms sending their orders to OTC
market makers that provide some level of price
improvement. See id.
18 See id. NASDAQ believes that approximately
96% of the DROs that will use the RTFY routing
option will not be marketable and will add liquidity
on the Exchange, while the remainder will be
routed to destinations on the System routing table
for potential price improvement, including to OTC
market makers. See id.
19 See id.
20 See id.
21 See id. and NASDAQ Rule 4752.
14 If
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Federal Register / Vol. 80, No. 248 / Monday, December 28, 2015 / Notices
marketable—for potential execution.22
Approximately two minutes prior to
market open, active pre-market session
orders in the Exchange’s possession will
be routed to the primary listing
exchange.23 When a security that is
listed on an exchange other than
NASDAQ is halted, RTFY orders—
including RTFY orders received during
the halt—will be sent to the primary
listing exchange for inclusion in that
exchange’s reopening process.24 All
RTFY orders will be sent to the primary
listing exchange approximately two
minutes prior to that exchange’s closing
process.25
In its proposal, NASDAQ notes that
the RTFY routing option is similar to
the existing TFTY routing option.26
NASDAQ specifically notes that orders
using the TFTY routing option do not
check the NASDAQ book—unless so
instructed by the entering firm—for
available shares, and instead route to
the TFTY destinations on the System
routing table with the goal of executing
with lower transaction fees.27 NASDAQ
states that the RTFY routing option
differs from TFTY in three ways: (i)
RTFY is only available to DROs; (ii)
RTFY uses a separate and distinct
routing table; and (iii) RTFY orders will
be sent to the primary listing exchange
for opening, reopening, and closing
auctions.28
NASDAQ notes that there are several
alternatives to using an Exchange
routing strategy.29 NASDAQ also notes
that it offers multiple routing options,
that each routing option has its own set
of strengths and trade-offs, and that
these varying routing strategies are
designed to meet varying market
participants’ needs.30 NASDAQ believes
the RTFY routing option will meet the
needs of the retail order firms that opt
to use it based on their routing
technology, business model, or level of
retail order flow.31
22 See
Notice, 80 FR at 59211.
id.
24 See id.
25 See id.
26 See NASDAQ Rule 4758(a)(1)(A)(v). NASDAQ
further notes that RFTY is also similar to BATS’
TRIM routing option, under which an order checks
the BATS system for available shares only if so
instructed by the entering firm and then is sent to
destinations on the system routing table. See
Notice, 80 FR at 59211.
27 See Notice, 80 FR at 59210.
28 See id. at 59211.
29 See id. For example, the Exchange notes that
broker-dealers and vendors provide customized
routing strategies and order execution algorithms,
order flow firms may choose to make their own
routing decisions based on proprietary routing
processes, and retail order firms may use other
firms to enhance their routing capabilities. See id.
30 See id.
31 See id.
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NASDAQ states that the RTFY routing
table will be monitored and approved
by a best execution committee
(‘‘Committee’’).32 NASDAQ states that
the Committee determines how to
organize the System routing table and
which trading destinations are included
in the routing table by reviewing various
parameters, such as price improvement,
fill rate, latency, interaction rate,
experience of the execution venue
operator, and the volume the execution
venue handles on a daily basis.33
NASDAQ notes that the parameters
considered by the Committee evolve
over time; often resulting in new
parameters being considered.34
NASDAQ states that neither the
Exchange, nor any of its affiliates, will
accept payment for order flow from any
OTC market maker to which an RTFY
order is sent.35 If the trading venue pays
a standard rebate for DROs to all of its
subscribers or another exchange pays a
rebate to remove liquidity, NASDAQ
will accept and retain those rebates.36
However, NASDAQ expects that most, if
not all, orders routed using the RTFY
routing option will be sent to and
executed by an OTC market maker that
may also be a registered NASDAQ
market maker.37
III. Comment Summary and
Commission Findings
After careful review, the Commission
finds that the proposed rule change is
consistent with the requirements of the
Act and the rules and regulations
thereunder applicable to a national
securities exchange.38 In particular, the
Commission finds that the proposed
rule change is consistent with Section
6(b)(5) of the Act,39 which requires,
among other things, that the rules of a
national securities exchange be
designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, to remove impediments to and
perfect the mechanism of a free and
open market and a national market
system, and, in general, to protect
investors and the public interest.
32 See id. at 59212. The Exchange states that the
Committee consists of several internal NASDAQ
participants representing product management,
internal audit, economic research, broker-dealer
compliance, and market operations. See id.
33 See id.
34 See id.
35 See id.
36 See id.
37 See id.
38 In approving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
39 15 U.S.C. 78f(b)(5).
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The Commission received two
comment letters opposing the proposal,
as well as a response and a
supplemental response from
NASDAQ.40
The commenters express concern that
RFTY is designed to allow leakage of
order flow information.41 The
Commission notes that, in response,
NASDAQ states that this claim is
factually incorrect and is speculation.42
NASDAQ reiterates that RTFY is
designed to enhance execution quality
and benefit retail investors by providing
price improvement opportunities to
retail order flow.43 According to
NASDAQ, it will use the Committee to
review and determine the structure and
destinations of the System routing table,
and if the Committee observes that a
particular destination is not providing
sufficient price improvement, the
destination will have to improve or be
dropped from the System routing
table.44 NASDAQ also notes that RFTY
is a voluntary routing type, and retail
orders firms can elect not to use RTFY
if it fails to benefit their clients.45
Moreover, NASDAQ notes that retail
investors have a choice when routing
their orders and it is up to them to
determine whether they will use a
broker-provided router or send their
orders directly to a particular
destination.46
The commenters also express
concerns related to best execution.
Specifically, one commenter questions
whether retail investors will forgo their
marketable orders interacting with the
NBBO at NASDAQ for ‘‘meaningless’’
price improvement at OTC market
makers.47 This commenter expresses
concern that RTFY could result in a
failure to obtain best execution,
specifically in situations where
NASDAQ was at the NBBO when a
marketable retail order that has elected
the RTFY routing option was received,
NASDAQ routes the marketable retail
order away but the order does not
execute on the away destinations, and
by the time the order comes back to
NASDAQ, the NBBO has moved so that
the retail order is no longer marketable
and posts to the book instead of
executing.48 In addition, both
commenters express concerns regarding
the transparency of the RTFY routing
40 See
41 See
supra notes 4, 5, and 7.
Themis Letter and Shatto Letter, supra note
4.
42 See
NASDAQ Response, supra note 5, at 2.
id.
44 See id.
45 See id.
46 See id. at 4.
47 See Themis Letter, supra note 4.
48 See id.
43 See
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table and the effectiveness of the
Committee.49
In response, NASDAQ states its belief
that providing additional price
improvement opportunities for retail
investors is a ‘‘critical component of its
best execution obligations.’’ 50 In its
supplemental response letter, NASDAQ
states that, in all routing of orders, when
one routing destination is chosen over
another, there is always a possibility
that an execution will be missed.51 The
Commission notes, however, that
NASDAQ believes that any chance of an
RTFY order missing a better price at the
Exchange is ‘‘miniscule.’’ 52 The
Commission notes that, according to
NASDAQ, some routing destinations
agree to a guaranteed minimum price
improvement per share for RTFY orders,
some focus more on the average price
improvement, and others are unsure of
what the level of price improvement
will be, but provide assurances that they
will compete vigorously with their
execution quality.53 Consequently,
NASDAQ believes that the competition
for RTFY orders, and thus the resulting
execution quality, will be better than
what is experienced today.54
The Commission notes that, with
respect to commenters’ concerns
regarding the RTFY routing table and
the Committee, NASDAQ states that—as
with all other routing options, other
than Directed Orders—the RTFY routing
table will be monitored and approved
by the Committee.55 According to
NASDAQ, the use of a best execution
committee is not novel, and such
committees are widely-used at many
broker-dealers.56 In addition, the
Committee is subject to FINRA
oversight, as well as oversight by
NASDAQ Inc.’s internal audit group,
which reports to the audit committee of
the Board of Directors of NASDAQ
Inc.57 According to NASDAQ, the
Committee reviews the performance of
routing destinations on a regular basis
49 See
Themis Letter and Shatto Letter, supra note
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4.
50 See NASDAQ Response, supra note 5, at 4.
Moreover, NASDAQ reiterates that it will not accept
any negotiated payment for order flow. See
NASDAQ Supplemental Response, supra note 7, at
1–2.
51 See NASDAQ Supplemental Response, supra
note 7, at 2.
52 See id. at 3.
53 See id. at 2.
54 See id.
55 See NASDAQ Response, supra note 5, at 3.
NASDAQ notes that many factors are weighed
when making best execution determinations, and
that price improvement opportunities for retail
investors are an ‘‘integral component of such
decisions by both the Committee and by retail order
firms.’’ See id.
56 See id.
57 See id. at 3–4.
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for all routing and the same will be true
for RTFY.58 If the Committee
determines that a particular routing
destination is underperforming based on
the various parameters, such as price
improvement, fill rate, and latency, the
Committee may either remove that
destination altogether or lower its
priority within the routing table.59
According to NASDAQ, this process
ensures that these
destinations will compete
aggressively with each other in order to
receive RTFY orders.60
Based on the foregoing, the
Commission believes that the proposed
rule change is consistent with the Act.
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,61 that the
proposed rule change (SR–NASDAQ–
2015–112) be and hereby is approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.62
Brent J. Fields,
Secretary.
[FR Doc. 2015–32527 Filed 12–24–15; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–76717; File No. SR–MIAX–
2015–73]
Self-Regulatory Organizations; Miami
International Securities Exchange LLC;
Notice of Filing and Immediate
Effectiveness of a Proposed Rule
Change To Amend Its Fee Schedule
December 21, 2015.
Pursuant to the provisions of Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’) 1 and Rule 19b–4
58 See
NASDAQ Supplemental Response, supra
note 7, at 2.
59 See id. NASDAQ notes that missed executions
often may be due to latency in away destinations
systems. See id. at 3. According to NASDAQ,
because latency is one of the parameters that the
Committee considers in its regular reviews of
routing destinations, destinations causing undue
latency that may lead to missed executions or
inferior execution prices would lose their priority
within the routing table or be removed altogether.
See id. NASDAQ also notes that, if the Committee
determines that a particular routing destination is
not providing sufficient price improvement
opportunities, then that destination will likely be
removed from the RTFY routing table. See
NASDAQ Response, supra note 5, at 4.
60 See NASDAQ Supplemental Response, supra
note 7, at 2. NASDAQ states that, in the past, the
Committee has moved venues down within the
routing table due, in part, to unsatisfactory fill rate,
unsatisfactory price improvement, and/or
unsatisfactory latency profile. See id.
61 15 U.S.C. 78s(b)(2).
62 17 CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
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80849
thereunder,2 notice is hereby given that
on December 14, 2015, Miami
International Securities Exchange LLC
(‘‘MIAX’’ or ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) a proposed rule change
as described in Items I, II, and III below,
which Items have been prepared by the
Exchange. The Commission is
publishing this notice to solicit
comments on the proposed rule change
from interested persons.
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange is filing a proposal to
amend the MIAX Options Fee Schedule
(the ‘‘Fee Schedule’’).
The text of the proposed rule change
is available on the Exchange’s Web site
at https://www.miaxoptions.com/filter/
wotitle/rule_filing, at MIAX’s principal
office, and at the Commission’s Public
Reference Room.
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend the
Fee Schedule to modify the transaction
fees for Members that participate in the
price improvement auction (‘‘PRIME
Auction’’ or ‘‘PRIME’’) pursuant to Rule
515A.3 Specifically, the Exchange
proposes to: (i) Increase the fee for a
PRIME AOC Response 4 from $0.49 per
2 17
CFR 240.19b–4.
Exchange Rule 515A. See also Securities
Exchange Act Release Nos. 75408 (July 9, 2015) 80
FR 41530 (July 15, 2015)(SR–MIAX–2015–45);
72943 (August 28, 2014), 79 FR 52785 (September
4, 2014) (SR–MIAX–2014–45); MIAX Options Fee
Schedule, Section (1)(a)(iv).
4 See Exchange Rule 515A(a)(2)(i). When the
Exchange receives a properly designated Agency
Order for auction processing, a Request for
Responses (‘‘RFR’’) detailing the option, side, size,
and initiating price will be sent to all subscribers
of the Exchange’s data feeds. Members may submit
3 See
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[Federal Register Volume 80, Number 248 (Monday, December 28, 2015)]
[Notices]
[Pages 80847-80849]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2015-32527]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-76718; File No. SR-NASDAQ-2015-112]
Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Order
Approving a Proposed Rule Change To Amend Rule 4758
December 21, 2105.
I. Introduction
On September 21, 2015, The NASDAQ Stock Market LLC (``NASDAQ'' or
``Exchange'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4 thereunder,\2\ a
proposed rule change to adopt a new routing option, the Retail Order
Process (``RTFY''). The proposed rule change was published for comment
in the Federal Register on October 1, 2015.\3\ The Commission received
two comment letters on the proposed rule change \4\ and a response
letter from NASDAQ.\5\ On November 3, 2015, the Commission extended the
time period within which to approve the proposed rule change,
disapprove the proposed rule change, or institute proceedings to
determine whether to disapprove the proposed rule change, to December
30, 2015.\6\ NASDAQ subsequently submitted a second response letter.\7\
This order approves the proposed rule change.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 75987 (September 25,
2015), 80 FR 59210 (``Notice'').
\4\ See letter from Joseph Saluzzi, Themis Trading LLC to the
Commission, dated September 29, 2015 (``Themis Letter''); and letter
from Suzanne Shatto to the Commission, dated October 6, 2015
(``Shatto Letter'').
\5\ See letter from Jonathan F. Cayne, Senior Associate General
Counsel, NASDAQ to Brent J. Fields, Secretary, Commission, dated
October 22, 2015 (``NASDAQ Response'').
\6\ See Securities Exchange Act Release No. 76335, 80 FR 69256
(November 9, 2015).
\7\ See letter from Jonathan F. Cayne, Senior Associate General
Counsel, NASDAQ to Brent J. Fields, Secretary, Commission, dated
December 11, 2015 (``NASDAQ Supplemental Response'').
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II. Description of the Proposal
NASDAQ is proposing to amend Rule 4758 to add a new order routing
option--RTFY--for Designated Retail Orders (``DROs'').\8\ NASDAQ states
that retail order firms \9\ often send non-marketable order flow to
post and display on exchanges. However, some orders that have been
deemed to be non-marketable by the entering firm become marketable by
the time the exchange receives them.\10\ NASDAQ notes that these orders
ultimately remove liquidity from the NASDAQ order book even though the
firm entering the order did not intend them to remove liquidity.\11\
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\8\ A Designated Retail Order is an agency or riskless principal
order that meets the criteria of FINRA Rule 5320.03 and that
originates from a natural person and is submitted to NASDAQ by a
member that designates it pursuant to Rule 7018, provided that no
change is made to the terms of the order with respect to price or
side of market and the order does not originate from a trading
algorithm or any other computerized methodology. An order from a
``natural person'' can include orders on behalf of accounts that are
held in a corporate legal form--such as an Individual Retirement
Account, Corporation, or a Limited Liability Company--that has been
established for the benefit of an individual or group of related
family members, provided that the order is submitted by an
individual. Members must submit a signed written attestation, in a
form prescribed by NASDAQ, that they have implemented policies and
procedures that are reasonably designed to ensure that substantially
all orders designated by the member as DROs comply with these
requirements. Orders may be designated on an order-by-order basis,
or by designating all orders on a particular order entry port as
DROs. See NASDAQ Rule 7018.
\9\ The term ``retail order firms'' refers to NASDAQ member
firms that provide orders that qualify as Designated Retail Orders
under NASDAQ Rule 7018.
\10\ See Notice, 80 FR at 59210.
\11\ See id.
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Under the proposal, a DRO that is marketable upon receipt by NASDAQ
and that elects to follow the RTFY routing option will be routed to
destinations in the System routing table instead of immediately
removing liquidity from the Exchange order book--unless explicitly
instructed by the entering party to check the Exchange order book
first.\12\ RTFY orders may remove liquidity from the Exchange book
after routing to other destinations.\13\ All non-marketable RTFY orders
will post on the Exchange book.\14\
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\12\ See id. The term ``System routing table'' refers to the
proprietary process for determining the specific trading venues to
which the System routes orders and the order in which it routes
them. NASDAQ reserves the right to maintain a different System
routing table for different routing options and to modify the System
routing table at any time without notice. See NASDAQ Rule
4758(a)(1)(A).
\13\ See Notice, 80 FR at 59210.
\14\ If a RTFY order is posted on the Exchange, either because
it was non-marketable when it was received or it has exhausted all
available liquidity within its limit price--including on the
Exchange, Regulation NMS protected quotations and other destinations
in the System routing table--and the order is subsequently locked or
crossed by another market center, the System will not route to the
locking or crossing market center. See id.
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According to NASDAQ, the destinations in the System routing table
for RTFY will include OTC market makers,\15\ which may also be
registered NASDAQ market makers.\16\ NASDAQ believes these market
makers will likely provide the greatest opportunity for price
improvement for the DROs, and the RTFY routing option will benefit DROs
by providing additional price improvement opportunities for retail
investors.\17\ NASDAQ anticipates that the RTFY routing option will
route to trading centers in the System routing table that have
experience executing and providing price improvement to DROs.\18\
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\15\ An ``OTC market maker'' in a stock is defined in Rule
600(b)(52) of Regulation NMS as, in general, a dealer that holds
itself out as willing to buy and sell the stock, otherwise than on a
national securities exchange, in amounts of less than block size
(less than 10,000 shares).
\16\ See Notice, 80 FR at 59210.
\17\ See id. NASDAQ believes that, because retail orders are
generally smaller on average, they are often able to receive better
prices than the prevailing national best bid and offer. See id. at
59211. NASDAQ believes that this is achieved by retail order firms
sending their orders to OTC market makers that provide some level of
price improvement. See id.
\18\ See id. NASDAQ believes that approximately 96% of the DROs
that will use the RTFY routing option will not be marketable and
will add liquidity on the Exchange, while the remainder will be
routed to destinations on the System routing table for potential
price improvement, including to OTC market makers. See id.
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As proposed, an order using the RTFY routing option will be sent to
the primary listing exchange for opening, reopening, and closing
auctions.\19\ Orders received in non-NASDAQ listed securities prior to
market open that are not eligible for the pre-market session will be
submitted to the primary listing market for inclusion in that market's
opening process.\20\ Orders received in NASDAQ-listed securities prior
to market open that are not eligible for the pre-market session will
follow normal pre-market processing.\21\ Orders received prior to the
market open that are eligible for the pre-market session will be
posted--and routed if
[[Page 80848]]
marketable--for potential execution.\22\ Approximately two minutes
prior to market open, active pre-market session orders in the
Exchange's possession will be routed to the primary listing
exchange.\23\ When a security that is listed on an exchange other than
NASDAQ is halted, RTFY orders--including RTFY orders received during
the halt--will be sent to the primary listing exchange for inclusion in
that exchange's reopening process.\24\ All RTFY orders will be sent to
the primary listing exchange approximately two minutes prior to that
exchange's closing process.\25\
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\19\ See id.
\20\ See id.
\21\ See id. and NASDAQ Rule 4752.
\22\ See Notice, 80 FR at 59211.
\23\ See id.
\24\ See id.
\25\ See id.
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In its proposal, NASDAQ notes that the RTFY routing option is
similar to the existing TFTY routing option.\26\ NASDAQ specifically
notes that orders using the TFTY routing option do not check the NASDAQ
book--unless so instructed by the entering firm--for available shares,
and instead route to the TFTY destinations on the System routing table
with the goal of executing with lower transaction fees.\27\ NASDAQ
states that the RTFY routing option differs from TFTY in three ways:
(i) RTFY is only available to DROs; (ii) RTFY uses a separate and
distinct routing table; and (iii) RTFY orders will be sent to the
primary listing exchange for opening, reopening, and closing
auctions.\28\
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\26\ See NASDAQ Rule 4758(a)(1)(A)(v). NASDAQ further notes that
RFTY is also similar to BATS' TRIM routing option, under which an
order checks the BATS system for available shares only if so
instructed by the entering firm and then is sent to destinations on
the system routing table. See Notice, 80 FR at 59211.
\27\ See Notice, 80 FR at 59210.
\28\ See id. at 59211.
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NASDAQ notes that there are several alternatives to using an
Exchange routing strategy.\29\ NASDAQ also notes that it offers
multiple routing options, that each routing option has its own set of
strengths and trade-offs, and that these varying routing strategies are
designed to meet varying market participants' needs.\30\ NASDAQ
believes the RTFY routing option will meet the needs of the retail
order firms that opt to use it based on their routing technology,
business model, or level of retail order flow.\31\
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\29\ See id. For example, the Exchange notes that broker-dealers
and vendors provide customized routing strategies and order
execution algorithms, order flow firms may choose to make their own
routing decisions based on proprietary routing processes, and retail
order firms may use other firms to enhance their routing
capabilities. See id.
\30\ See id.
\31\ See id.
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NASDAQ states that the RTFY routing table will be monitored and
approved by a best execution committee (``Committee'').\32\ NASDAQ
states that the Committee determines how to organize the System routing
table and which trading destinations are included in the routing table
by reviewing various parameters, such as price improvement, fill rate,
latency, interaction rate, experience of the execution venue operator,
and the volume the execution venue handles on a daily basis.\33\ NASDAQ
notes that the parameters considered by the Committee evolve over time;
often resulting in new parameters being considered.\34\
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\32\ See id. at 59212. The Exchange states that the Committee
consists of several internal NASDAQ participants representing
product management, internal audit, economic research, broker-dealer
compliance, and market operations. See id.
\33\ See id.
\34\ See id.
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NASDAQ states that neither the Exchange, nor any of its affiliates,
will accept payment for order flow from any OTC market maker to which
an RTFY order is sent.\35\ If the trading venue pays a standard rebate
for DROs to all of its subscribers or another exchange pays a rebate to
remove liquidity, NASDAQ will accept and retain those rebates.\36\
However, NASDAQ expects that most, if not all, orders routed using the
RTFY routing option will be sent to and executed by an OTC market maker
that may also be a registered NASDAQ market maker.\37\
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\35\ See id.
\36\ See id.
\37\ See id.
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III. Comment Summary and Commission Findings
After careful review, the Commission finds that the proposed rule
change is consistent with the requirements of the Act and the rules and
regulations thereunder applicable to a national securities
exchange.\38\ In particular, the Commission finds that the proposed
rule change is consistent with Section 6(b)(5) of the Act,\39\ which
requires, among other things, that the rules of a national securities
exchange be designed to prevent fraudulent and manipulative acts and
practices, to promote just and equitable principles of trade, to remove
impediments to and perfect the mechanism of a free and open market and
a national market system, and, in general, to protect investors and the
public interest.
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\38\ In approving this proposed rule change, the Commission has
considered the proposed rule's impact on efficiency, competition,
and capital formation. See 15 U.S.C. 78c(f).
\39\ 15 U.S.C. 78f(b)(5).
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The Commission received two comment letters opposing the proposal,
as well as a response and a supplemental response from NASDAQ.\40\
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\40\ See supra notes 4, 5, and 7.
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The commenters express concern that RFTY is designed to allow
leakage of order flow information.\41\ The Commission notes that, in
response, NASDAQ states that this claim is factually incorrect and is
speculation.\42\ NASDAQ reiterates that RTFY is designed to enhance
execution quality and benefit retail investors by providing price
improvement opportunities to retail order flow.\43\ According to
NASDAQ, it will use the Committee to review and determine the structure
and destinations of the System routing table, and if the Committee
observes that a particular destination is not providing sufficient
price improvement, the destination will have to improve or be dropped
from the System routing table.\44\ NASDAQ also notes that RFTY is a
voluntary routing type, and retail orders firms can elect not to use
RTFY if it fails to benefit their clients.\45\ Moreover, NASDAQ notes
that retail investors have a choice when routing their orders and it is
up to them to determine whether they will use a broker-provided router
or send their orders directly to a particular destination.\46\
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\41\ See Themis Letter and Shatto Letter, supra note 4.
\42\ See NASDAQ Response, supra note 5, at 2.
\43\ See id.
\44\ See id.
\45\ See id.
\46\ See id. at 4.
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The commenters also express concerns related to best execution.
Specifically, one commenter questions whether retail investors will
forgo their marketable orders interacting with the NBBO at NASDAQ for
``meaningless'' price improvement at OTC market makers.\47\ This
commenter expresses concern that RTFY could result in a failure to
obtain best execution, specifically in situations where NASDAQ was at
the NBBO when a marketable retail order that has elected the RTFY
routing option was received, NASDAQ routes the marketable retail order
away but the order does not execute on the away destinations, and by
the time the order comes back to NASDAQ, the NBBO has moved so that the
retail order is no longer marketable and posts to the book instead of
executing.\48\ In addition, both commenters express concerns regarding
the transparency of the RTFY routing
[[Page 80849]]
table and the effectiveness of the Committee.\49\
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\47\ See Themis Letter, supra note 4.
\48\ See id.
\49\ See Themis Letter and Shatto Letter, supra note 4.
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In response, NASDAQ states its belief that providing additional
price improvement opportunities for retail investors is a ``critical
component of its best execution obligations.'' \50\ In its supplemental
response letter, NASDAQ states that, in all routing of orders, when one
routing destination is chosen over another, there is always a
possibility that an execution will be missed.\51\ The Commission notes,
however, that NASDAQ believes that any chance of an RTFY order missing
a better price at the Exchange is ``miniscule.'' \52\ The Commission
notes that, according to NASDAQ, some routing destinations agree to a
guaranteed minimum price improvement per share for RTFY orders, some
focus more on the average price improvement, and others are unsure of
what the level of price improvement will be, but provide assurances
that they will compete vigorously with their execution quality.\53\
Consequently, NASDAQ believes that the competition for RTFY orders, and
thus the resulting execution quality, will be better than what is
experienced today.\54\
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\50\ See NASDAQ Response, supra note 5, at 4. Moreover, NASDAQ
reiterates that it will not accept any negotiated payment for order
flow. See NASDAQ Supplemental Response, supra note 7, at 1-2.
\51\ See NASDAQ Supplemental Response, supra note 7, at 2.
\52\ See id. at 3.
\53\ See id. at 2.
\54\ See id.
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The Commission notes that, with respect to commenters' concerns
regarding the RTFY routing table and the Committee, NASDAQ states
that--as with all other routing options, other than Directed Orders--
the RTFY routing table will be monitored and approved by the
Committee.\55\ According to NASDAQ, the use of a best execution
committee is not novel, and such committees are widely-used at many
broker-dealers.\56\ In addition, the Committee is subject to FINRA
oversight, as well as oversight by NASDAQ Inc.'s internal audit group,
which reports to the audit committee of the Board of Directors of
NASDAQ Inc.\57\ According to NASDAQ, the Committee reviews the
performance of routing destinations on a regular basis for all routing
and the same will be true for RTFY.\58\ If the Committee determines
that a particular routing destination is underperforming based on the
various parameters, such as price improvement, fill rate, and latency,
the Committee may either remove that destination altogether or lower
its priority within the routing table.\59\ According to NASDAQ, this
process ensures that these
destinations will compete aggressively with each other in order to
receive RTFY orders.\60\
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\55\ See NASDAQ Response, supra note 5, at 3. NASDAQ notes that
many factors are weighed when making best execution determinations,
and that price improvement opportunities for retail investors are an
``integral component of such decisions by both the Committee and by
retail order firms.'' See id.
\56\ See id.
\57\ See id. at 3-4.
\58\ See NASDAQ Supplemental Response, supra note 7, at 2.
\59\ See id. NASDAQ notes that missed executions often may be
due to latency in away destinations systems. See id. at 3. According
to NASDAQ, because latency is one of the parameters that the
Committee considers in its regular reviews of routing destinations,
destinations causing undue latency that may lead to missed
executions or inferior execution prices would lose their priority
within the routing table or be removed altogether. See id. NASDAQ
also notes that, if the Committee determines that a particular
routing destination is not providing sufficient price improvement
opportunities, then that destination will likely be removed from the
RTFY routing table. See NASDAQ Response, supra note 5, at 4.
\60\ See NASDAQ Supplemental Response, supra note 7, at 2.
NASDAQ states that, in the past, the Committee has moved venues down
within the routing table due, in part, to unsatisfactory fill rate,
unsatisfactory price improvement, and/or unsatisfactory latency
profile. See id.
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Based on the foregoing, the Commission believes that the proposed
rule change is consistent with the Act.
IV. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\61\ that the proposed rule change (SR-NASDAQ-2015-112) be and
hereby is approved.
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\61\ 15 U.S.C. 78s(b)(2).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\62\
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\62\ 17 CFR 200.30-3(a)(12).
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Brent J. Fields,
Secretary.
[FR Doc. 2015-32527 Filed 12-24-15; 8:45 am]
BILLING CODE 8011-01-P