Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change To Amend Nasdaq Rule 7023, 26846-26849 [2016-10370]
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Federal Register / Vol. 81, No. 86 / Wednesday, May 4, 2016 / Notices
At any time within 60 days of the
filing of the proposed rule change, the
Commission summarily may
temporarily suspend such rule change if
it appears to the Commission that such
action is: (i) Necessary or appropriate in
the public interest; (ii) for the protection
of investors; or (iii) otherwise in
furtherance of the purposes of the Act.
If the Commission takes such action, the
Commission shall institute proceedings
to determine whether the proposed rule
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:
asabaliauskas on DSK3SPTVN1PROD with NOTICES
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–NASDAQ–2016–060 on the
subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE.,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NASDAQ–2016–060. 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 the
the proposed rule change at least five business days
prior to the date of filing of the proposed rule
change, or such shorter time as designated by the
Commission. The Exchange has satisfied this
requirement.
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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–
NASDAQ–2016–060, and should be
submitted on or before May 25, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.7
Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016–10371 Filed 5–3–16; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–77736; File No. SR–
NASDAQ–2016–058]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing and Immediate Effectiveness of
Proposed Rule Change To Amend
Nasdaq Rule 7023
April 28, 2016.
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 April 18,
2016, The NASDAQ Stock Market LLC
(‘‘Nasdaq’’ or the ‘‘Exchange’’) filed with
the Securities and Exchange
Commission (‘‘SEC’’ or ‘‘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
Nasdaq is proposing to amend Nasdaq
Rule 7023 (NASDAQ Depth-of-Book
Data) to remove free top-of-file (‘‘Top-ofFile’’) data from Nasdaq OpenView.
The text of the proposed rule change
is available at
nasdaq.cchwallstreet.com, at Nasdaq’s
principal office, and at the
Commission’s Public Reference Room.
7 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
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II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission,
Nasdaq included statements concerning
the purpose of, and basis for, the
proposed rule change and discussed any
comments it received on the proposed
rule change. The text of those
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant parts of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend
Nasdaq Rule 7023 (NASDAQ Depth-ofBook Data). Currently, Nasdaq does not
charge a fee for use of Nasdaq
OpenView Top-of-File data that is
created using Nasdaq OpenView. Topof-File data consists of Nasdaq’s
aggregate best bid and offer quotation
for each security listed on an exchange
other than Nasdaq. Vendors can create
Top-of-File data from Nasdaq OpenView
and offer it to both professionals and
non-professionals either for display or
non-display.
The Exchange proposes to keep Topof-File data as part of Nasdaq
OpenView, but to no longer provide for
free the use of this data (e.g., a
subscriber of Nasdaq OpenView may no
longer create a Top-of-File data product
and provide it for free to other market
participants). All market participants
that opt to receive Nasdaq OpenView
and create a Top-of-File data product
from it will be liable for the Nasdaq
OpenView fee rate applicable to NonProfessional Subscribers 3 or
Professional Subscribers,4 as
appropriate. The monthly fee is
3 See Nasdaq Rule 7023(a)(3)(A). This rule defines
a Non-Professional Subscriber as a natural person
who is not: (1) Registered or qualified in any
capacity with the Commission, the Commodity
Futures Trading Commission, any state securities
agency, any securities exchange or association, or
any commodities or futures contract market or
association; (2) engaged as an ‘‘investment adviser’’
as that term is defined in Section 201(11) of the
Investment Advisers Act of 1940 (whether or not
registered or qualified under that Act); or (3)
employed by a bank or other organization exempt
from registration under federal or state securities
laws to perform functions that would require
registration or qualification if such functions were
performed for an organization not so exempt.
4 See Nasdaq Rule 7023(a)(3)(B). This rule defines
a Professional Subscriber as any subscriber other
than a ‘‘Non-Professional Subscriber,’’ as that term
is defined in Nasdaq Rule 7023(a)(3)(A).
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currently $1 for Non-Professional
Subscribers 5 while the monthly fee for
Professional Subscribers is currently $6
each for any display usage, or for nondisplay usage based upon indirect
access.6 Market participants cannot be
charged for both Top-of-File data and
OpenView.
Since no firms currently are utilizing
Nasdaq OpenView Top-of-File data,
there will be no immediate impact on
any subscribers due to the proposed rule
change. However, the proposed rule
change makes clear going forward that
any subscribers creating this data will
not be able to use it for free.
To effectuate this proposed rule
change, the Exchange will eliminate
Nasdaq Rule 7023(b)(3)(C) and
renumber Nasdaq Rule 7023(b)(3)(D) as
Nasdaq Rule 7023(b)(3)(C).
2. Statutory Basis
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The Exchange believes that its
proposal is consistent with Section 6(b)
of the Act,7 in general, and furthers the
objectives of Sections 6(b)(4) and 6(b)(5)
of the Act,8 in particular, in that it
provides for the equitable allocation of
reasonable dues, fees and other charges
among members and issuers and other
persons using its facilities which the
Exchange operates or controls, and is
not designed to permit unfair
discrimination between customers,
issuers, brokers, or dealers.
The Commission and the courts have
repeatedly expressed their preference
for competition over regulatory
intervention in determining prices,
products, and services in the securities
markets. In Regulation NMS, while
adopting a series of steps to improve the
current market model, the Commission
highlighted the importance of market
forces in determining prices and SRO
revenues and, also, recognized that
current regulation of the market system
‘‘has been remarkably successful in
promoting market competition in its
broader forms that are most important to
investors and listed companies.’’ 9
Likewise, in NetCoalition v. Securities
and Exchange Commission 10
(‘‘NetCoalition’’) the D.C. Circuit upheld
the Commission’s use of a market-based
approach in evaluating the fairness of
market data fees against a challenge
claiming that Congress mandated a cost5 See
Nasdaq Rule 7023(b)(3)(A).
Nasdaq Rule 7023(b)(3)(B).
7 15 U.S.C. 78f(b).
8 15 U.S.C. 78f(b)(4) and (5).
9 Securities Exchange Act Release No. 34–51808
(June 9, 2005) (‘‘Regulation NMS Adopting
Release’’).
10 NetCoalition v. SEC 615 F.3d 525 (D.C. Cir.
2010).
6 See
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based approach.11 As the court
emphasized, the Commission ‘‘intended
in Regulation NMS that ‘market forces,
rather than regulatory requirements’
play a role in determining the market
data . . . to be made available to
investors and at what cost.’’ 12
Further, ‘‘[n]o one disputes that
competition for order flow is ‘fierce.’
. . . As the SEC explained, ‘[i]n the U.S.
national market system, buyers and
sellers of securities, and the brokerdealers that act as their order-routing
agents, have a wide range of choices of
where to route orders for execution’;
[and] ‘no exchange can afford to take its
market share percentages for granted’
because ‘no exchange possesses a
monopoly, regulatory or otherwise, in
the execution of order flow from broker
dealers’. . .’’ 13
Vendors can create Top-of-File data
from Nasdaq OpenView and offer it to
both professionals and nonprofessionals either for display or nondisplay. The Exchange believes that the
proposed rule change to charge all
market participants that opt to receive
Nasdaq OpenView and create a Top-ofFile data product the Nasdaq OpenView
fee rate applicable to Non-Professional
Subscribers or Professional Subscribers,
as appropriate, is reasonable because the
Exchange is entitled to receive a fee
from each subscriber that receives such
data to help offset costs associated with
providing Nasdaq OpenView data to
subscribers. Also, the proposed rule
change is reasonable because a market
participant must use Nasdaq OpenView
data in order to create a Top-of-File data
product and since Nasdaq OpenView is
fee liable, the same should be true of the
resulting Top-of-File data product.
The Exchange also believes that the
proposed rule change is an equitable
allocation of fees and is not unfairly
discriminatory because market
participants cannot be charged for both
Top-of-File data and OpenView and the
proposed rule change applies uniformly
to all market participants since it treats
all similarly situated market
participants the same.
The renumbering of Nasdaq Rule
7023(b)(3)(D) as Nasdaq Rule
7023(b)(3)(C) is reasonable because it is
a technical and clarifying change that is
intended to maintain the coherency and
consistency within the Nasdaq rule
book.
11 Id.
at 534–535.
at 537.
13 Id. at 539 (quoting ArcaBook Order, 73 FR at
74782–74783).
12 Id.
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B. Self-Regulatory Organization’s
Statement on Burden on Competition
The Exchange does not believe that
the proposed rule change will result in
any burden on competition that is not
necessary or appropriate in furtherance
of the purposes of the Act, as amended.
Notwithstanding its determination that
the Commission may rely upon
competition to establish fair and
equitably allocated fees for market data,
the NetCoalition court found that the
Commission had not, in that case,
compiled a record that adequately
supported its conclusion that the market
for the data at issue in the case was
competitive. Nasdaq believes that a
record may readily be established to
demonstrate the competitive nature of
the market in question.
There is intense competition between
trading platforms that provide
transaction execution and routing
services and proprietary data products.
Transaction execution and proprietary
data products are complementary in that
market data is both an input and a
byproduct of the execution service. In
fact, market data and trade execution are
a paradigmatic example of joint
products with joint costs. Data products
are valuable to many end Subscribers
only insofar as they provide information
that end Subscribers expect will assist
them or their customers in making
trading decisions.
The costs of producing market data
include not only the costs of the data
distribution infrastructure, but also the
costs of designing, maintaining, and
operating the exchange’s transaction
execution platform and the cost of
regulating the exchange to ensure its fair
operation and maintain investor
confidence. The total return that a
trading platform earns reflects the
revenues it receives from both products
and the joint costs it incurs.
Moreover, an exchange’s customers
view the costs of transaction executions
and of data as a unified cost of doing
business with the exchange. A brokerdealer (‘‘BD’’) will direct orders to a
particular exchange only if the expected
revenues from executing trades on the
exchange exceed net transaction
execution costs and the cost of data that
the BD chooses to buy to support its
trading decisions (or those of its
customers). The choice of data products
is, in turn, a product of the value of the
products in making profitable trading
decisions. If the cost of the product
exceeds its expected value, the BD will
choose not to buy it. Moreover, as a BD
chooses to direct fewer orders to a
particular exchange, the value of the
product to that BD decreases, for two
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reasons. First, the product will contain
less information, because executions of
the BD’s orders will not be reflected in
it. Second, and perhaps more important,
the product will be less valuable to that
BD because it does not provide
information about the venue to which it
is directing its orders. Data from the
competing venue to which the BD is
directing orders will become
correspondingly more valuable.
Thus, an increase in the fees charged
for either transactions or data has the
potential to impair revenues from both
products. ‘‘No one disputes that
competition for order flow is ‘fierce’.’’ 14
However, the existence of fierce
competition for order flow implies a
high degree of price sensitivity on the
part of BDs with order flow, since they
may readily reduce costs by directing
orders toward the lowest-cost trading
venues. A BD that shifted its order flow
from one platform to another in
response to order execution price
differentials would both reduce the
value of that platform’s market data and
reduce its own need to consume data
from the disfavored platform. Similarly,
if a platform increases its market data
fees, the change will affect the overall
cost of doing business with the
platform, and affected BDs will assess
whether they can lower their trading
costs by directing orders elsewhere and
thereby lessening the need for the more
expensive data.
Analyzing the cost of market data
distribution in isolation from the cost of
all of the inputs supporting the creation
of market data will inevitably
underestimate the cost of the data. Thus,
because it is impossible to create data
without a fast, technologically robust,
and well-regulated execution system,
system costs and regulatory costs affect
the price of market data. It would be
equally misleading, however, to
attribute all of the exchange’s costs to
the market data portion of an exchange’s
joint product. Rather, all of the
exchange’s costs are incurred for the
unified purposes of attracting order
flow, executing and/or routing orders,
and generating and selling data about
market activity. The total return that an
exchange earns reflects the revenues it
receives from the joint products and the
total costs of the joint products.
Competition among trading platforms
can be expected to constrain the
aggregate return each platform earns
from the sale of its joint products, but
different platforms may choose from a
range of possible, and equally
reasonable, pricing strategies as the
means of recovering total costs. Nasdaq
14 Id.
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pays rebates to attract orders, charges
relatively low prices for market
information and charges relatively high
prices for accessing posted liquidity.
Other platforms may choose a strategy
of paying lower liquidity rebates to
attract orders, setting relatively low
prices for accessing posted liquidity,
and setting relatively high prices for
market information. Still others may
provide most data free of charge and
rely exclusively on transaction fees to
recover their costs. Finally, some
platforms may incentivize use by
providing opportunities for equity
ownership, which may allow them to
charge lower direct fees for executions
and data.
In this environment, there is no
economic basis for regulating maximum
prices for one of the joint products in an
industry in which suppliers face
competitive constraints with regard to
the joint offering. Such regulation is
unnecessary because an ‘‘excessive’’
price for one of the joint products will
ultimately have to be reflected in lower
prices for other products sold by the
firm, or otherwise the firm will
experience a loss in the volume of its
sales that will be adverse to its overall
profitability. In other words, an increase
in the price of data will ultimately have
to be accompanied by a decrease in the
cost of executions, or the volume of both
data and executions will fall.
The level of competition and
contestability in the market is evident in
the numerous alternative venues that
compete for order flow, including
eleven SRO markets, as well as
internalizing BDs and various forms of
alternative trading systems (‘‘ATSs’’),
including dark pools and electronic
communication networks (‘‘ECNs’’).
Each SRO market competes to produce
transaction reports via trade executions,
and two FINRA-regulated TRFs compete
to attract internalized transaction
reports. It is common for BDs to further
and exploit this competition by sending
their order flow and transaction reports
to multiple markets, rather than
providing them all to a single market.
Competitive markets for order flow,
executions, and transaction reports
provide pricing discipline for the inputs
of proprietary data products.
The large number of SROs, TRFs, BDs,
and ATSs that currently produce
proprietary data or are currently capable
of producing it provides further pricing
discipline for proprietary data products.
Each SRO, TRF, ATS, and BD is
currently permitted to produce
proprietary data products, and many
currently do or have announced plans to
do so, including NASDAQ, NYSE,
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NYSE MKT, NYSE Arca, and BATS/
Direct Edge.
Any ATS or BD can combine with any
other ATS, BD, or multiple ATSs or BDs
to produce joint proprietary data
products. Additionally, order routers
and market data vendors can facilitate
single or multiple BDs’ production of
proprietary data products. The potential
sources of proprietary products are
virtually limitless. Notably, the
potential sources of data include the
BDs that submit trade reports to TRFs
and that have the ability to consolidate
and distribute their data without the
involvement of FINRA or an exchangeoperated TRF.
The fact that proprietary data from
ATSs, BDs, and vendors can by-pass
SROs is significant in two respects.
First, non-SROs can compete directly
with SROs for the production and sale
of proprietary data products, as BATS
and NYSE Arca did before registering as
exchanges by publishing proprietary
book data on the internet. Second,
because a single order or transaction
report can appear in a core data product,
an SRO proprietary product, and/or a
non-SRO proprietary product, the data
available in proprietary products is
exponentially greater than the actual
number of orders and transaction
reports that exist in the marketplace.
In addition to the competition and
price discipline described above, the
market for proprietary data products is
also highly contestable because market
entry is rapid, inexpensive, and
profitable. The history of electronic
trading is replete with examples of
entrants that swiftly grew into some of
the largest electronic trading platforms
and proprietary data producers:
Archipelago, Bloomberg Tradebook,
Island, RediBook, Attain, TracECN,
BATS Trading and BATS/Direct Edge. A
proliferation of dark pools and other
ATSs operate profitably with
fragmentary shares of consolidated
market volume.
Regulation NMS, by deregulating the
market for proprietary data, has
increased the contestability of that
market. While BDs have previously
published their proprietary data
individually, Regulation NMS
encourages market data vendors and
BDs to produce proprietary products
cooperatively in a manner never before
possible. Multiple market data vendors
already have the capability to aggregate
data and disseminate it on a profitable
scale, including Bloomberg and
Thomson Reuters. In Europe, Cinnober
aggregates and disseminates data from
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over 40 brokers and multilateral trading
facilities.15
In the case of TRFs, the rapid entry of
several exchanges into this space in
2006–2007 following the development
and Commission approval of the TRF
structure demonstrates the
contestability of this aspect of the
market.16 Given the demand for trade
reporting services that is itself a byproduct of the fierce competition for
transaction executions—characterized
notably by a proliferation of ATSs and
BDs offering internalization—any supracompetitive increase in the fees
associated with trade reporting or TRF
data would shift trade report volumes
from one of the existing TRFs to the
other 17 and create incentives for other
TRF operators to enter the space.
Alternatively, because BDs reporting to
TRFs are themselves free to consolidate
the market data that they report, the
market for over-the-counter data itself,
separate and apart from the markets for
execution and trade reporting services—
is fully contestable.
Moreover, consolidated data provides
two additional measures of pricing
discipline for proprietary data products
that are a subset of the consolidated data
stream. First, the consolidated data is
widely available in real-time at $1 per
month for non-professional users.
Second, consolidated data is also
available at no cost with a 15- or 20minute delay. Because consolidated
data contains marketwide information,
it effectively places a cap on the fees
assessed for proprietary data (such as
last sale data) that is simply a subset of
the consolidated data. The mere
availability of low-cost or free
consolidated data provides a powerful
form of pricing discipline for
proprietary data products that contain
data elements that are a subset of the
consolidated data, by highlighting the
optional nature of proprietary products.
In this instance, the proposed rule
change to charge all market participants
that create a Top-of-File product using
Nasdaq OpenView data the fee rate
applicable to Non-Professional
Subscribers or Professional Subscribers,
as appropriate, by eliminating current
rule text in Nasdaq Rule 7023(b)(3)(C),
does not impose a burden on
competition because no firms currently
15 See https://www.cinnober.com/boat-tradereporting.
16 The low cost exit of two TRFs from the market
is also evidence of a contestable market, because
new entrants are reluctant to enter a market where
exit may involve substantial shut-down costs.
17 It should be noted that the FINRA/NYSE TRF
has, in recent weeks, received reports for almost
10% of all over-the-counter volume in NMS stocks.
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are utilizing this data so there will be no
immediate impact on any subscribers.
In sum, if the rule change proposed
herein is unattractive to market
participants, it is likely that the
Exchange will lose market share as a
result. Accordingly, the Exchange does
not believe that the proposed change
will impair the ability of members or
competing order execution venues to
maintain their competitive standing in
the financial markets.
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants or Others
Written comments were neither
solicited nor received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing change has become
effective pursuant to Section
19(b)(3)(A)(ii) of the Act.18 At any time
within 60 days of the filing of the
proposed rule change, the Commission
summarily may temporarily suspend
such rule change if it appears to the
Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of the Act.
26849
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–
NASDAQ–2016–058, and should be
submitted on or before May 25, 2016.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.19
Robert W. Errett,
Deputy Secretary.
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:
[FR Doc. 2016–10370 Filed 5–3–16; 8:45 am]
Electronic Comments
• Use the Commission’s Internet
comment form (https://www.sec.gov/
rules/sro.shtml); or
• Send an email to rule-comments@
sec.gov. Please include File Number SR–
NASDAQ–2016–058 on the subject line.
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of FOIA Services,
100 F Street NE., Washington, DC
20549–2736
Paper Comments
• Send paper comments in triplicate
to Brent J. Fields, Secretary, Securities
and Exchange Commission, 100 F Street
NE., Washington, DC 20549–1090.
All submissions should refer to File
Number SR–NASDAQ–2016–058. 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/
18 15
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U.S.C. 78s(b)(3)(A)(ii).
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SECURITIES AND EXCHANGE
COMMISSION
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extension of the previously approved
collection of information provided for in
Rule 6h–1 (17 CFR 240.6h–1) under the
Securities Exchange Act of 1934, as
amended (‘‘Act’’) (15 U.S.C. 78a et seq.).
Section 6(h) of the Act (15 U.S.C.
78f(h)) requires national securities
19 17
E:\FR\FM\04MYN1.SGM
CFR 200.30–3(a)(12).
04MYN1
Agencies
[Federal Register Volume 81, Number 86 (Wednesday, May 4, 2016)]
[Notices]
[Pages 26846-26849]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2016-10370]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-77736; File No. SR-NASDAQ-2016-058]
Self-Regulatory Organizations; The NASDAQ Stock Market LLC;
Notice of Filing and Immediate Effectiveness of Proposed Rule Change To
Amend Nasdaq Rule 7023
April 28, 2016.
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 April 18, 2016, The NASDAQ Stock Market LLC (``Nasdaq'' or the
``Exchange'') filed with the Securities and Exchange Commission
(``SEC'' or ``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.
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
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I. Self-Regulatory Organization's Statement of the Terms of Substance
of the Proposed Rule Change
Nasdaq is proposing to amend Nasdaq Rule 7023 (NASDAQ Depth-of-Book
Data) to remove free top-of-file (``Top-of-File'') data from Nasdaq
OpenView.
The text of the proposed rule change is available at
nasdaq.cchwallstreet.com, at Nasdaq'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, Nasdaq included statements
concerning the purpose of, and basis for, the proposed rule change and
discussed any comments it received on the proposed rule change. The
text of those statements may be examined at the places specified in
Item IV below. The Exchange has prepared summaries, set forth in
sections A, B, and C below, of the most significant parts of such
statements.
A. Self-Regulatory Organization's Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule Change
1. Purpose
The Exchange proposes to amend Nasdaq Rule 7023 (NASDAQ Depth-of-
Book Data). Currently, Nasdaq does not charge a fee for use of Nasdaq
OpenView Top-of-File data that is created using Nasdaq OpenView. Top-
of-File data consists of Nasdaq's aggregate best bid and offer
quotation for each security listed on an exchange other than Nasdaq.
Vendors can create Top-of-File data from Nasdaq OpenView and offer it
to both professionals and non-professionals either for display or non-
display.
The Exchange proposes to keep Top-of-File data as part of Nasdaq
OpenView, but to no longer provide for free the use of this data (e.g.,
a subscriber of Nasdaq OpenView may no longer create a Top-of-File data
product and provide it for free to other market participants). All
market participants that opt to receive Nasdaq OpenView and create a
Top-of-File data product from it will be liable for the Nasdaq OpenView
fee rate applicable to Non-Professional Subscribers \3\ or Professional
Subscribers,\4\ as appropriate. The monthly fee is
[[Page 26847]]
currently $1 for Non-Professional Subscribers \5\ while the monthly fee
for Professional Subscribers is currently $6 each for any display
usage, or for non-display usage based upon indirect access.\6\ Market
participants cannot be charged for both Top-of-File data and OpenView.
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\3\ See Nasdaq Rule 7023(a)(3)(A). This rule defines a Non-
Professional Subscriber as a natural person who is not: (1)
Registered or qualified in any capacity with the Commission, the
Commodity Futures Trading Commission, any state securities agency,
any securities exchange or association, or any commodities or
futures contract market or association; (2) engaged as an
``investment adviser'' as that term is defined in Section 201(11) of
the Investment Advisers Act of 1940 (whether or not registered or
qualified under that Act); or (3) employed by a bank or other
organization exempt from registration under federal or state
securities laws to perform functions that would require registration
or qualification if such functions were performed for an
organization not so exempt.
\4\ See Nasdaq Rule 7023(a)(3)(B). This rule defines a
Professional Subscriber as any subscriber other than a ``Non-
Professional Subscriber,'' as that term is defined in Nasdaq Rule
7023(a)(3)(A).
\5\ See Nasdaq Rule 7023(b)(3)(A).
\6\ See Nasdaq Rule 7023(b)(3)(B).
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Since no firms currently are utilizing Nasdaq OpenView Top-of-File
data, there will be no immediate impact on any subscribers due to the
proposed rule change. However, the proposed rule change makes clear
going forward that any subscribers creating this data will not be able
to use it for free.
To effectuate this proposed rule change, the Exchange will
eliminate Nasdaq Rule 7023(b)(3)(C) and renumber Nasdaq Rule
7023(b)(3)(D) as Nasdaq Rule 7023(b)(3)(C).
2. Statutory Basis
The Exchange believes that its proposal is consistent with Section
6(b) of the Act,\7\ in general, and furthers the objectives of Sections
6(b)(4) and 6(b)(5) of the Act,\8\ in particular, in that it provides
for the equitable allocation of reasonable dues, fees and other charges
among members and issuers and other persons using its facilities which
the Exchange operates or controls, and is not designed to permit unfair
discrimination between customers, issuers, brokers, or dealers.
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\7\ 15 U.S.C. 78f(b).
\8\ 15 U.S.C. 78f(b)(4) and (5).
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The Commission and the courts have repeatedly expressed their
preference for competition over regulatory intervention in determining
prices, products, and services in the securities markets. In Regulation
NMS, while adopting a series of steps to improve the current market
model, the Commission highlighted the importance of market forces in
determining prices and SRO revenues and, also, recognized that current
regulation of the market system ``has been remarkably successful in
promoting market competition in its broader forms that are most
important to investors and listed companies.'' \9\
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\9\ Securities Exchange Act Release No. 34-51808 (June 9, 2005)
(``Regulation NMS Adopting Release'').
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Likewise, in NetCoalition v. Securities and Exchange Commission
\10\ (``NetCoalition'') the D.C. Circuit upheld the Commission's use of
a market-based approach in evaluating the fairness of market data fees
against a challenge claiming that Congress mandated a cost-based
approach.\11\ As the court emphasized, the Commission ``intended in
Regulation NMS that `market forces, rather than regulatory
requirements' play a role in determining the market data . . . to be
made available to investors and at what cost.'' \12\
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\10\ NetCoalition v. SEC 615 F.3d 525 (D.C. Cir. 2010).
\11\ Id. at 534-535.
\12\ Id. at 537.
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Further, ``[n]o one disputes that competition for order flow is
`fierce.' . . . As the SEC explained, `[i]n the U.S. national market
system, buyers and sellers of securities, and the broker-dealers that
act as their order-routing agents, have a wide range of choices of
where to route orders for execution'; [and] `no exchange can afford to
take its market share percentages for granted' because `no exchange
possesses a monopoly, regulatory or otherwise, in the execution of
order flow from broker dealers'. . .'' \13\
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\13\ Id. at 539 (quoting ArcaBook Order, 73 FR at 74782-74783).
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Vendors can create Top-of-File data from Nasdaq OpenView and offer
it to both professionals and non-professionals either for display or
non-display. The Exchange believes that the proposed rule change to
charge all market participants that opt to receive Nasdaq OpenView and
create a Top-of-File data product the Nasdaq OpenView fee rate
applicable to Non-Professional Subscribers or Professional Subscribers,
as appropriate, is reasonable because the Exchange is entitled to
receive a fee from each subscriber that receives such data to help
offset costs associated with providing Nasdaq OpenView data to
subscribers. Also, the proposed rule change is reasonable because a
market participant must use Nasdaq OpenView data in order to create a
Top-of-File data product and since Nasdaq OpenView is fee liable, the
same should be true of the resulting Top-of-File data product.
The Exchange also believes that the proposed rule change is an
equitable allocation of fees and is not unfairly discriminatory because
market participants cannot be charged for both Top-of-File data and
OpenView and the proposed rule change applies uniformly to all market
participants since it treats all similarly situated market participants
the same.
The renumbering of Nasdaq Rule 7023(b)(3)(D) as Nasdaq Rule
7023(b)(3)(C) is reasonable because it is a technical and clarifying
change that is intended to maintain the coherency and consistency
within the Nasdaq rule book.
B. Self-Regulatory Organization's Statement on Burden on Competition
The Exchange does not believe that the proposed rule change will
result in any burden on competition that is not necessary or
appropriate in furtherance of the purposes of the Act, as amended.
Notwithstanding its determination that the Commission may rely upon
competition to establish fair and equitably allocated fees for market
data, the NetCoalition court found that the Commission had not, in that
case, compiled a record that adequately supported its conclusion that
the market for the data at issue in the case was competitive. Nasdaq
believes that a record may readily be established to demonstrate the
competitive nature of the market in question.
There is intense competition between trading platforms that provide
transaction execution and routing services and proprietary data
products. Transaction execution and proprietary data products are
complementary in that market data is both an input and a byproduct of
the execution service. In fact, market data and trade execution are a
paradigmatic example of joint products with joint costs. Data products
are valuable to many end Subscribers only insofar as they provide
information that end Subscribers expect will assist them or their
customers in making trading decisions.
The costs of producing market data include not only the costs of
the data distribution infrastructure, but also the costs of designing,
maintaining, and operating the exchange's transaction execution
platform and the cost of regulating the exchange to ensure its fair
operation and maintain investor confidence. The total return that a
trading platform earns reflects the revenues it receives from both
products and the joint costs it incurs.
Moreover, an exchange's customers view the costs of transaction
executions and of data as a unified cost of doing business with the
exchange. A broker-dealer (``BD'') will direct orders to a particular
exchange only if the expected revenues from executing trades on the
exchange exceed net transaction execution costs and the cost of data
that the BD chooses to buy to support its trading decisions (or those
of its customers). The choice of data products is, in turn, a product
of the value of the products in making profitable trading decisions. If
the cost of the product exceeds its expected value, the BD will choose
not to buy it. Moreover, as a BD chooses to direct fewer orders to a
particular exchange, the value of the product to that BD decreases, for
two
[[Page 26848]]
reasons. First, the product will contain less information, because
executions of the BD's orders will not be reflected in it. Second, and
perhaps more important, the product will be less valuable to that BD
because it does not provide information about the venue to which it is
directing its orders. Data from the competing venue to which the BD is
directing orders will become correspondingly more valuable.
Thus, an increase in the fees charged for either transactions or
data has the potential to impair revenues from both products. ``No one
disputes that competition for order flow is `fierce'.'' \14\ However,
the existence of fierce competition for order flow implies a high
degree of price sensitivity on the part of BDs with order flow, since
they may readily reduce costs by directing orders toward the lowest-
cost trading venues. A BD that shifted its order flow from one platform
to another in response to order execution price differentials would
both reduce the value of that platform's market data and reduce its own
need to consume data from the disfavored platform. Similarly, if a
platform increases its market data fees, the change will affect the
overall cost of doing business with the platform, and affected BDs will
assess whether they can lower their trading costs by directing orders
elsewhere and thereby lessening the need for the more expensive data.
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\14\ Id.
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Analyzing the cost of market data distribution in isolation from
the cost of all of the inputs supporting the creation of market data
will inevitably underestimate the cost of the data. Thus, because it is
impossible to create data without a fast, technologically robust, and
well-regulated execution system, system costs and regulatory costs
affect the price of market data. It would be equally misleading,
however, to attribute all of the exchange's costs to the market data
portion of an exchange's joint product. Rather, all of the exchange's
costs are incurred for the unified purposes of attracting order flow,
executing and/or routing orders, and generating and selling data about
market activity. The total return that an exchange earns reflects the
revenues it receives from the joint products and the total costs of the
joint products.
Competition among trading platforms can be expected to constrain
the aggregate return each platform earns from the sale of its joint
products, but different platforms may choose from a range of possible,
and equally reasonable, pricing strategies as the means of recovering
total costs. Nasdaq pays rebates to attract orders, charges relatively
low prices for market information and charges relatively high prices
for accessing posted liquidity. Other platforms may choose a strategy
of paying lower liquidity rebates to attract orders, setting relatively
low prices for accessing posted liquidity, and setting relatively high
prices for market information. Still others may provide most data free
of charge and rely exclusively on transaction fees to recover their
costs. Finally, some platforms may incentivize use by providing
opportunities for equity ownership, which may allow them to charge
lower direct fees for executions and data.
In this environment, there is no economic basis for regulating
maximum prices for one of the joint products in an industry in which
suppliers face competitive constraints with regard to the joint
offering. Such regulation is unnecessary because an ``excessive'' price
for one of the joint products will ultimately have to be reflected in
lower prices for other products sold by the firm, or otherwise the firm
will experience a loss in the volume of its sales that will be adverse
to its overall profitability. In other words, an increase in the price
of data will ultimately have to be accompanied by a decrease in the
cost of executions, or the volume of both data and executions will
fall.
The level of competition and contestability in the market is
evident in the numerous alternative venues that compete for order flow,
including eleven SRO markets, as well as internalizing BDs and various
forms of alternative trading systems (``ATSs''), including dark pools
and electronic communication networks (``ECNs''). Each SRO market
competes to produce transaction reports via trade executions, and two
FINRA-regulated TRFs compete to attract internalized transaction
reports. It is common for BDs to further and exploit this competition
by sending their order flow and transaction reports to multiple
markets, rather than providing them all to a single market. Competitive
markets for order flow, executions, and transaction reports provide
pricing discipline for the inputs of proprietary data products.
The large number of SROs, TRFs, BDs, and ATSs that currently
produce proprietary data or are currently capable of producing it
provides further pricing discipline for proprietary data products. Each
SRO, TRF, ATS, and BD is currently permitted to produce proprietary
data products, and many currently do or have announced plans to do so,
including NASDAQ, NYSE, NYSE MKT, NYSE Arca, and BATS/Direct Edge.
Any ATS or BD can combine with any other ATS, BD, or multiple ATSs
or BDs to produce joint proprietary data products. Additionally, order
routers and market data vendors can facilitate single or multiple BDs'
production of proprietary data products. The potential sources of
proprietary products are virtually limitless. Notably, the potential
sources of data include the BDs that submit trade reports to TRFs and
that have the ability to consolidate and distribute their data without
the involvement of FINRA or an exchange-operated TRF.
The fact that proprietary data from ATSs, BDs, and vendors can by-
pass SROs is significant in two respects. First, non-SROs can compete
directly with SROs for the production and sale of proprietary data
products, as BATS and NYSE Arca did before registering as exchanges by
publishing proprietary book data on the internet. Second, because a
single order or transaction report can appear in a core data product,
an SRO proprietary product, and/or a non-SRO proprietary product, the
data available in proprietary products is exponentially greater than
the actual number of orders and transaction reports that exist in the
marketplace.
In addition to the competition and price discipline described
above, the market for proprietary data products is also highly
contestable because market entry is rapid, inexpensive, and profitable.
The history of electronic trading is replete with examples of entrants
that swiftly grew into some of the largest electronic trading platforms
and proprietary data producers: Archipelago, Bloomberg Tradebook,
Island, RediBook, Attain, TracECN, BATS Trading and BATS/Direct Edge. A
proliferation of dark pools and other ATSs operate profitably with
fragmentary shares of consolidated market volume.
Regulation NMS, by deregulating the market for proprietary data,
has increased the contestability of that market. While BDs have
previously published their proprietary data individually, Regulation
NMS encourages market data vendors and BDs to produce proprietary
products cooperatively in a manner never before possible. Multiple
market data vendors already have the capability to aggregate data and
disseminate it on a profitable scale, including Bloomberg and Thomson
Reuters. In Europe, Cinnober aggregates and disseminates data from
[[Page 26849]]
over 40 brokers and multilateral trading facilities.\15\
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\15\ See https://www.cinnober.com/boat-trade-reporting.
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In the case of TRFs, the rapid entry of several exchanges into this
space in 2006-2007 following the development and Commission approval of
the TRF structure demonstrates the contestability of this aspect of the
market.\16\ Given the demand for trade reporting services that is
itself a by-product of the fierce competition for transaction
executions--characterized notably by a proliferation of ATSs and BDs
offering internalization--any supra-competitive increase in the fees
associated with trade reporting or TRF data would shift trade report
volumes from one of the existing TRFs to the other \17\ and create
incentives for other TRF operators to enter the space. Alternatively,
because BDs reporting to TRFs are themselves free to consolidate the
market data that they report, the market for over-the-counter data
itself, separate and apart from the markets for execution and trade
reporting services--is fully contestable.
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\16\ The low cost exit of two TRFs from the market is also
evidence of a contestable market, because new entrants are reluctant
to enter a market where exit may involve substantial shut-down
costs.
\17\ It should be noted that the FINRA/NYSE TRF has, in recent
weeks, received reports for almost 10% of all over-the-counter
volume in NMS stocks.
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Moreover, consolidated data provides two additional measures of
pricing discipline for proprietary data products that are a subset of
the consolidated data stream. First, the consolidated data is widely
available in real-time at $1 per month for non-professional users.
Second, consolidated data is also available at no cost with a 15- or
20- minute delay. Because consolidated data contains marketwide
information, it effectively places a cap on the fees assessed for
proprietary data (such as last sale data) that is simply a subset of
the consolidated data. The mere availability of low-cost or free
consolidated data provides a powerful form of pricing discipline for
proprietary data products that contain data elements that are a subset
of the consolidated data, by highlighting the optional nature of
proprietary products.
In this instance, the proposed rule change to charge all market
participants that create a Top-of-File product using Nasdaq OpenView
data the fee rate applicable to Non-Professional Subscribers or
Professional Subscribers, as appropriate, by eliminating current rule
text in Nasdaq Rule 7023(b)(3)(C), does not impose a burden on
competition because no firms currently are utilizing this data so there
will be no immediate impact on any subscribers.
In sum, if the rule change proposed herein is unattractive to
market participants, it is likely that the Exchange will lose market
share as a result. Accordingly, the Exchange does not believe that the
proposed change will impair the ability of members or competing order
execution venues to maintain their competitive standing in the
financial markets.
C. Self-Regulatory Organization's Statement on Comments on the Proposed
Rule Change Received From Members, Participants or Others
Written comments were neither solicited nor received.
III. Date of Effectiveness of the Proposed Rule Change and Timing for
Commission Action
The foregoing change has become effective pursuant to Section
19(b)(3)(A)(ii) of the Act.\18\ At any time within 60 days of the
filing of the proposed rule change, the Commission summarily may
temporarily suspend such rule change if it appears to the Commission
that such action is necessary or appropriate in the public interest,
for the protection of investors, or otherwise in furtherance of the
purposes of the Act.
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\18\ 15 U.S.C. 78s(b)(3)(A)(ii).
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IV. Solicitation of Comments
Interested persons are invited to submit written data, views, and
arguments concerning the foregoing, including whether the proposed rule
change is consistent with the Act. Comments may be submitted by any of
the following methods:
Electronic Comments
Use the Commission's Internet comment form (https://www.sec.gov/rules/sro.shtml); or
Send an email to rule-comments@sec.gov. Please include
File Number SR-NASDAQ-2016-058 on the subject line.
Paper Comments
Send paper comments in triplicate to Brent J. Fields,
Secretary, Securities and Exchange Commission, 100 F Street NE.,
Washington, DC 20549-1090.
All submissions should refer to File Number SR-NASDAQ-2016-058. 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-NASDAQ-2016-058, and should
be submitted on or before May 25, 2016.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\19\
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\19\ 17 CFR 200.30-3(a)(12).
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Robert W. Errett,
Deputy Secretary.
[FR Doc. 2016-10370 Filed 5-3-16; 8:45 am]
BILLING CODE 8011-01-P