Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Notice of Filing of Amendment No. 2 and Order Instituting Proceedings To Determine Whether To Approve or Disapprove a Proposed Rule Change, as Modified by Amendment Nos. 1 and 2, To Adopt the Midpoint Extended Life Order, 52075-52079 [2017-24371]
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Federal Register / Vol. 82, No. 216 / Thursday, November 9, 2017 / Notices
39 U.S.C. 3642, 39 CFR part 3015, and
39 CFR part 3020, subpart B. Comment
deadline(s) for each request appear in
section II.
II. Docketed Proceeding(s)
1. Docket No(s).: CP2016–59; Filing
Title: USPS Notice of Change in Prices
Pursuant to Amendment to Priority Mail
& First-Class Package Service Contract 9:
November 3, 2017; Filing Authority: 39
CFR 3015.5; Public Representative:
Kenneth R. Moeller; Comments Due:
November 14, 2017.
2. Docket No(s).: MC2018–20 and
CP2018–42; Filing Title: USPS Request
to Add Priority Mail Express, Priority
Mail & First-Class Package Service
Contract 25 to Competitive Product List
and Notice of Filing Materials Under
Seal; Filing Acceptance Date: November
3, 2017; Filing Authority: 39 U.S.C. 3642
and 39 CFR 3020.30 et seq.; Public
Representative: Christopher C. Mohr;
Comments Due: November 14, 2017.
3. Docket No(s).: MC2018–21 and
CP2018–43; Filing Title: USPS Request
to Add Priority Mail Contract 372 to
Competitive Product List and Notice of
Filing Materials Under Seal; Filing
Acceptance Date: November 3, 2017;
Filing Authority: 39 U.S.C. 3642 and 39
CFR 3020.30 et seq.; Public
Representative: Christopher C. Mohr;
Comments Due: November 14, 2017.
This notice will be published in the
Federal Register.
Stacy L. Ruble,
Secretary.
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–82013; File No. SR–
NASDAQ–2017–074]
Self-Regulatory Organizations; The
NASDAQ Stock Market LLC; Notice of
Filing of Amendment No. 2 and Order
Instituting Proceedings To Determine
Whether To Approve or Disapprove a
Proposed Rule Change, as Modified by
Amendment Nos. 1 and 2, To Adopt the
Midpoint Extended Life Order
November 3, 2017.
sradovich on DSK3GMQ082PROD with NOTICES
I. Introduction
On July 21, 2017, the NASDAQ Stock
Market LLC (‘‘Exchange’’ or ‘‘Nasdaq’’)
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
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CFR 240.19b–4.
Securities Exchange Act Release No. 81311
(August 3, 2017), 82 FR 37248 (‘‘Notice’’).
4 In Amendment No. 1, the Exchange updated the
proposal to reflect the approval of the proposal by
the Exchange’s Board of Directors on July 21, 2017.
Amendment No. 1 is available at https://
www.sec.gov/comments/sr-nasdaq-2017-074/
nasdaq2017074.htm. Because Amendment No. 1 is
a technical amendment that does not alter the
substance of the proposed rule change, it is not
subject to notice and comment.
5 15 U.S.C. 78s(b)(2).
6 See Securities Exchange Act Release No. 81668,
82 FR 45095 (September 27, 2017). The
Commission designated November 7, 2017 as the
date by which the Commission shall approve or
disapprove, or institute proceedings to determine
whether to approve or disapprove, the proposed
rule change.
7 See Letters to Brent J. Fields, Secretary,
Commission, from Stephen John Berger, Managing
Director, Government & Regulatory Policy, Citadel
Securities, dated August 30, 2017 (‘‘Citadel Letter’’);
Ray Ross, Chief Technology Officer, The Clearpool
Group, dated September 12, 2017 (‘‘Clearpool
Letter’’); and Joanna Mallers, Secretary, FIA
Principal Traders Group, dated September 19, 2017
(‘‘FIA PTG Letter’’).
8 In Amendment No. 2, the Exchange: (1)
Modified the proposal to prevent MELOs from
trading when better-priced non-displayed orders
rest on the Nasdaq book; (2) provided additional
description, clarification, and rationale for certain
aspects of the proposal; and (3) responded to
several concerns raised by commenters on the
proposal. Amendment No. 2 is available at https://
www.sec.gov/comments/sr-nasdaq-2017-074/
nasdaq2017074.htm.
9 15 U.S.C. 78s(b)(2)(B).
3 See
BILLING CODE 7710–FW–P
U.S.C. 78s(b)(1).
II. Description of the Proposal
The Exchange proposed to offer the
MELO order type. A MELO would be a
non-displayed order priced at the
midpoint between the National Best Bid
2 17
[FR Doc. 2017–24412 Filed 11–8–17; 8:45 am]
1 15
19b–4 thereunder,2 a proposed rule
change to adopt the Midpoint Extended
Life Order (‘‘MELO’’). The proposed
rule change was published for comment
in the Federal Register on August 9,
2017.3 On August 9, 2017, the Exchange
filed Amendment No. 1 to the proposed
rule change.4 On September 21, 2017,
pursuant to Section 19(b)(2) of the Act,5
the Commission designated a longer
period within which to approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether to
approve or disapprove the proposed
rule change.6 The Commission has
received three comment letters on the
proposal.7 On October 30, 2017, the
Exchange filed Amendment No. 2 to the
proposed rule change.8 The Commission
is publishing this notice and order to
solicit comments on the proposed rule
change, as modified by Amendment
Nos. 1 and 2, from interested persons
and to institute proceedings pursuant to
Section 19(b)(2)(B) of the Act 9 to
determine whether to approve or
disapprove the proposed rule change, as
modified by Amendment Nos. 1 and 2.
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52075
and Offer (‘‘NBBO’’) and would not be
eligible to execute until a minimum
period of one half of a second (‘‘Holding
Period’’) has passed after acceptance of
the order by the system.10 Once eligible
to trade, MELOs would be ranked in
time priority at the NBBO midpoint
among other MELOs.11 If a limit price is
assigned to a MELO, the order would be:
(1) Eligible for execution in time priority
if upon acceptance of the order by the
system, the midpoint price is within the
limit set by the participant; or (2) held
until the midpoint falls within the limit
set by the participant, at which time the
Holding Period would commence and
thereafter the system would make the
order eligible for execution in time
priority.12
If a MELO is modified by a member
(other than to decrease the size of the
order or to modify the marking of a sell
order as long, short, or short exempt)
during the Holding Period, the system
would restart the Holding Period.13
Similarly, if a MELO is modified by a
member (other than to decrease the size
of the order or to modify the marking of
a sell order as long, short, or short
exempt) after it has become eligible to
execute, the order would have to satisfy
a new Holding Period.14
Movements in the NBBO while a
MELO is in the Holding Period would
not reset the Holding Period, even if, as
a result of the NBBO move, the MELO’s
limit price is less aggressive than the
NBBO midpoint.15 Also, if a MELO has
met the Holding Period, but the NBBO
midpoint is no longer within its limit,
it would nonetheless be ranked in time
priority among other MELOs if the
NBBO later moves such that the
midpoint is within the order’s limit
price (i.e., no new Holding Period).16
MELOs may be entered via any of the
Exchange’s communications protocols
and the type of communications
protocol used would not affect how the
system handles MELOs.17 If there is no
NBB or NBO, the Exchange would
accept MELOs but would not allow
MELO executions until there is an
10 See
proposed Nasdaq Rule 4702(b)(14)(A).
id.
12 See id.
13 See id. The Exchange noted that any change to
a MELO that would result in a change in the order’s
timestamp would result in the MELO being
considered altered, and thus the order would be
subject to a new Holding Period before being
eligible to trade and its priority would be based on
the new timestamp. See Amendment No. 2 at n.16.
14 See proposed Nasdaq Rule 4702(b)(14)(A).
15 See Amendment No. 2 at n.11.
16 See proposed Nasdaq Rule 4702(b)(14)(A);
Amendment No. 2 at n.15.
17 See Amendment No. 2 at n.10.
11 See
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NBBO.18 MELOs would be eligible to
trade if the NBBO is locked.19 If the
NBBO is crossed, MELOs would be held
by the system until such time that the
NBBO is no longer crossed, at which
time they would be eligible to trade.20
MELOs may be cancelled at any time,
including during the Holding Period.21
MELOs would be active only during
Market Hours.22 MELOs entered during
Pre-Market Hours would be held by the
system in time priority until Market
Hours.23 MELOs entered during PostMarket Hours would not be accepted by
the system, and MELOs remaining
unexecuted after 4:00 p.m. ET would be
cancelled by the system.24 MELOs
would not be eligible for the Nasdaq
opening, halt, and closing crosses.25
MELOs must be entered with a size of
at least one round lot, and any shares of
a MELO remaining after an execution
that are less than one round lot would
be cancelled.26 MELOs may have a
minimum quantity order attribute.27
MELOs may not be designated with a
time-in-force of immediate or cancel
(‘‘IOC’’) and are ineligible for routing.28
They also may not have the discretion,
reserve size, attribution, intermarket
sweep order, display, or trade now order
attributes.29
18 See id. at 12. If there is no NBB or NBO upon
entry of a MELO, the system would hold the order
in time priority, together with any other MELOs
received while there is no NBB or NBO. See id.
Once there is an NBBO, the Holding Period would
begin for the held MELOs based on time priority.
See id.
19 See id. at 12–13.
20 See id. at 13.
21 See proposed Nasdaq Rule 4702(b)(14)(A).
22 See proposed Nasdaq Rule 4702(b)(14)(B).
Market Hours begin after the completion of the
Nasdaq Opening Cross (or at 9:30 a.m. ET in the
case of a security for which no Nasdaq Opening
Cross occurs). See Nasdaq Rule 4703(a).
23 See proposed Nasdaq Rule 4702(b)(14)(B).
‘‘Pre-Market Hours’’ means the period of time
beginning at 4:00 a.m. ET and ending immediately
prior to the commencement of Market Hours. See
Nasdaq Rule 4701(g). A MELO entered during PreMarket Hours would be held by the system until the
completion of the Opening Cross (or 9:30 a.m. ET
if no Opening Cross occurs), ranked in the time that
it was received by the Nasdaq book upon
satisfaction of the Holding Period. See Amendment
No. 2 at 11–12.
24 See proposed Nasdaq Rule 4702(b)(14)(B).
‘‘Post-Market Hours’’ means the period of time
beginning immediately after the end of Market
Hours and ending at 8:00 p.m. ET. See Nasdaq Rule
4701(g).
25 See proposed Nasdaq Rule 4703(l);
Amendment No. 2 at 12. MELOs in existence at the
time a halt is initiated would be ineligible to
execute and held by the system until trading has
resumed and the NBBO has been received by
Nasdaq. See proposed Nasdaq Rule 4702(b)(14)(A).
26 See proposed Nasdaq Rule 4702(b)(14)(B).
27 See id.
28 See id.; see also Amendment No. 2 at 11 and
13.
29 See Amendment No. 2 at 13–14.
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Once a MELO becomes eligible to
execute by existing unchanged for the
Holding Period, the MELO may only
execute against other eligible MELOs.30
MELOs would not execute if there is a
resting non-displayed order priced more
aggressively than the NBBO midpoint,
and they instead would be held until
the resting non-displayed order is no
longer on the Nasdaq book or the NBBO
midpoint matches the price of the
resting non-displayed order.31 MELO
executions would be reported to
Securities Information Processors and
provided to Nasdaq’s proprietary data
feeds without any new or special
indication.32
As proposed, MELOs would be
subject to real-time surveillance to
determine if the order type is being
abused by market participants.33 In
addition, the Exchange intends to
implement a process, at the same time
as the implementation of MELOs, to
monitor the use of MELOs with the
intent to apply additional measures, as
necessary, to ensure their usage is
appropriately tied to the intent of the
order type.34 The Exchange stated that
this process may include metrics tied to
participant behavior, such as the
percentage of MELOs that are cancelled
prior to the completion of the Holding
Period, the average duration of MELOs,
and the percentage of MELOs where the
NBBO midpoint is within the limit price
when received.35 The Exchange stated
that it is committed to determining
whether there is opportunity or
prevalence of behavior that is
inconsistent with normal risk
management behavior.36 According to
the Exchange, manipulative abuse is
subject to potential disciplinary action
under the Exchange’s rules, and other
behavior that is not necessarily
manipulative but nonetheless frustrates
the purposes of the MELO order type
may be subject to penalties or other
participant requirements to discourage
such behavior, should it occur.37
The Exchange stated that it plans to
implement MELO within thirty days
after Commission approval of the
proposal.38 The Exchange would make
MELOs available to all members and to
all securities upon implementation, and
would announce the implementation
date by Equity Trader Alert.39
30 See
proposed Nasdaq Rule 4702(b)(14)(A).
id; see also Amendment No. 2 at 9.
32 See Amendment No. 2 at 15.
33 See id. at 22.
34 See id.
35 See id.
36 See id. at 22–23.
37 See id. at 23.
38 See id. at 16.
39 See id.
31 See
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Fmt 4703
Sfmt 4703
III. Summary of Comments and the
Exchange’s Response
The Commission received one
comment letter that expressed support
for the proposal 40 and two comment
letters that expressed concerns about the
proposal.41
One commenter stated its belief that
MELOs could provide a valuable tool for
investors, and particularly institutional
investors, seeking to execute in large
size.42 This commenter also stated its
belief that MELOs have the potential to
attract longer-term market participants
to Nasdaq, and would provide an
additional method to allow investors to
effectively implement their investment
strategies on an exchange.43 The
commenter observed that, because
MELOs would be on an exchange, they
would be available to all Exchange
participants, which the commenter
asserted is a fairer and more transparent
way for markets to operate as compared
to off-exchange trading venues.44
Two commenters expressed concern
with the degree of order segmentation
presented by the proposal.45 They
expressed the view that MELOs would
create a separate order book within the
Nasdaq matching system where only
MELOs could interact with each other.46
One of these commenters stated that the
proposal represents an unprecedented
level of exchange-based order flow
segmentation.47 This commenter
acknowledged the existence of limited
exchange-based mechanisms that have
the effect of restricting some order flow
interaction, but contended that the
proposal goes significantly beyond any
such existing restrictions.48 This
commenter noted that the use of MELOs
would result in two orders failing to
interact even if they are of the same size
and have prices that cross each other,
and suggested that the Commission
consider carefully whether this is
consistent with the definition and
purpose of an exchange.49
40 See
Clearpool Letter.
Citadel Letter and FIA PTG Letter.
42 See Clearpool Letter at 1–3.
43 See id. at 2.
44 See id.
45 See Citadel Letter at 1–3; FIA PTG Letter at 2.
One of these commenters also expressed the
concern that the costs of approving the MELO order
type would far outweigh the potential benefits. See
FIA PTG Letter at 2. This commenter asserted that
artificially introducing latency negatively impacts
the price discovery and formation functions of the
exchange. See id. This commenter also expressed
broad concerns about complexity in today’s equity
market structure, which are outside the scope of the
Exchange’s proposal. See id.
46 See Citadel Letter at 1–3; FIA PTG Letter at 2.
47 See Citadel Letter at 1.
48 See id. at 3.
49 See id.
41 See
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In addition, one commenter remarked
that market participants with
marketable held orders or resting orders
seeking to execute against marketable
held order flow would be unlikely to
utilize MELOs because marketable held
orders are typically required to be
executed fully and promptly.50
According to the commenter, as use of
the ‘‘MELO order book’’ increases,
liquidity in the ‘‘legacy Nasdaq order
book’’ could be negatively impacted to
the detriment of retail investors.51
Moreover, the commenter stated that
investors submitting resting MELOs
would not be able to interact with
marketable held order flow.52 The
commenter suggested that the Exchange
could partially mitigate the negative
impacts of MELO order segmentation by
revising its proposal to allow any order
to immediately interact with a resting
MELO as long as it is priced beyond the
midpoint.53
In contrast, one commenter stated that
allowing MELOs to interact with nonMELOs would defeat the purpose of the
MELO order type.54 This commenter
also stated that it does not believe that
the proposal would negatively impact
liquidity or price discovery on the
Nasdaq market because the MELO order
type should have little to no detrimental
effect on participants using other order
types.55 According to this commenter,
to the extent that the MELO order type
would provide incentives for order flow
to be directed to a fair access exchange
and away from private market centers,
price discovery for the broader markets
might improve.56
In Amendment No. 2, the Exchange
stated that although MELOs may forgo
the opportunity to interact with other
liquidity on the Exchange, users of
MELOs accepted this possibility in
return for the ability to interact with
other market participants with the same
time horizon.57 The Exchange also
50 See
id. at 1–2.
id. at 2.
id.
53 See id.
54 See Clearpool Letter at 3.
55 See id.
56 See id.
57 See Amendment No. 2 at 19. The Exchange also
compared MELOs to the minimum quantity order
attribute, as well as the retail price improvement
orders available on Nasdaq BX, Inc. See id. The
Exchange stated that both of these types of orders
provide the opportunity to interact with orders
meeting certain characteristics, and consequently
may miss the opportunity to receive an execution
if the contra-side order does not meet the specified
characteristics. See id. In addition, the Exchange
compared its proposal to the Nasdaq Crossing
Network, which created a series of intra-day crosses
at the NBBO midpoint. See id. at 20. The Exchange
stated that Nasdaq Crossing Network eligible orders
were not available for execution against orders
resting on the Nasdaq book. See id. at 20–21.
51 See
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52 See
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Jkt 244001
stated its belief that it is not unfair or
discriminatory that non-displayed
orders resting on Nasdaq that are priced
more aggressively than the NBBO
midpoint would not participate in
MELO executions.58 According to the
Exchange, the use of resting nondisplayed orders and MELOs would be
available to all participants, and
participants would simply need to
evaluate which order type best serves
their investment needs.59 Moreover, the
Exchange stated that it has conducted a
pro forma study of the effect of applying
MELOs to the current market: It
reviewed all executions occurring on
Nasdaq in August 2017 and found that
only 0.37% of resting non-displayed
orders traded at a price better than the
prevailing midpoint at the time of
execution.60 According to the Exchange,
consequently, the number of situations
in which a participant would have to
consider the trade-offs between posting
a non-displayed buy (sell) order at a
higher (lower) price as compared to
submitting a MELO is minimal.61 In
addition, the Exchange reiterated that
all members may use MELOs and thus
have access to MELO liquidity.62
Finally, in Amendment No. 2, the
Exchange amended the proposal to
provide that MELOs would not execute
if there is a resting non-displayed order
priced more aggressively than the NBBO
midpoint; instead, MELOs would be
held until the resting non-displayed
order is no longer on the Nasdaq book
or the NBBO midpoint matches the
price of the resting non-displayed
order.63
One commenter raised the concern
that, under the proposal, MELO
executions would be reported to the
Securities Information Processors and
provided on Nasdaq’s proprietary data
feed in the same manner as all other
transactions on Nasdaq.64 This
commenter stated that this approach
likely would raise concerns about
market fairness and introduce
significant complexity for investors,
broker-dealers, and regulators when
attempting to analyze market activity
and assess execution quality.65 This
commenter noted, by way of example,
that investors may see their orders
executed on Nasdaq at worse prices
than other contemporaneous executions
on Nasdaq and that, without Nasdaq
58 See
id. at 20.
id.
60 See id. at 21.
61 See id.
62 See id.
63 See proposed Nasdaq Rule 4702(b)(14)(A).
64 See Citadel Letter at 3.
65 See id.
59 See
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Sfmt 4703
52077
labeling MELO executions as such,
investors may not know why this has
occurred.66 This commenter also
asserted that, without labeling MELO
executions differently than other
executions on Nasdaq, broker-dealer
routing logic may be influenced by
liquidity that is not actually accessible,
and regulators may experience
difficulties in accurately filtering market
data when evaluating compliance with
regulatory requirements such as best
execution.67 This commenter urged the
Commission to require that executions
resulting from MELOs be marked as
such on the tape.68 Alternatively, the
commenter suggested that Nasdaq offer
the MELO order type on a separate
exchange.69
By contrast, one commenter stated
that it does not believe that the lack of
specific identification of MELOs in
trade reports would result in any
difficulties for the markets, or
complexity for investors or other market
participants when assessing execution
quality.70 According to this commenter,
users of the MELO order type would be
provided with anonymity and
confidentiality, which the commenter
asserted are critical tools in preventing
potentially predatory counterparties
from determining intention and using
that information to generate short-term
profits at the expense of longer-term
investors.71 In addition, this commenter
stated that Nasdaq and all other
exchanges currently offer many order
types that when executed do not
provide specific indicators showing
exactly which order types were used,
and professed not to see how allowing
an exchange to add another order type
without such trade reporting disclosure
would harm market participants’ ability
to measure market quality, as they do
not currently have that ability.72
In Amendment No. 2, the Exchange
stated that it currently does not identify
on data feeds in real time the order
types and attributes that resulted in an
execution (e.g., reserve order
attribute).73 According to the Exchange,
not identifying MELOs is important to
ensure that investors are protected from
market participants that would
66 See
id.
id.
68 See id.
69 See id.
70 See Clearpool Letter at 2.
71 See id.
72 See id.
73 See Amendment No. 2 at n.34. The Exchange
also noted that there is no real-time transparency
regarding which destination or broker matched a
buyer and seller when transactions are reported to
a trade reporting facility. See id. at 25–26. Instead,
there are delayed reports that identify where the
executions occurred. See id. at 26.
67 See
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sradovich on DSK3GMQ082PROD with NOTICES
otherwise take advantage of such
knowledge and undermine the
usefulness of the order type.74 In
addition, the Exchange stated that, like
any of the order types or attributes
provided by the Exchange, members
must assess which ones would provide
them with the best execution in
achieving their investment goals.75
Lastly, one commenter asserted that
allowing MELOs to be cancelled at any
time during the Holding Period does not
appear to be consistent with the
intended use of the order type.76
Instead, according to this commenter, a
MELO should only be permitted to be
cancelled after the Holding Period has
expired and the order has been placed
in the order book.77 Another
commenter, by contrast, did not have an
issue with providing market
participants the ability to cancel MELOs
during the Holding Period.78 This
commenter stated that it believes this
would be an important feature of the
MELO order type because many firms
use algorithms to source liquidity
simultaneously from multiple venues.79
According to the commenter, to the
extent that liquidity is found elsewhere
than Nasdaq within the Holding Period,
it would be critically important that the
firm be able to cancel its orders from
Nasdaq and re-allocate those shares to
other venues.80 This commenter stated
that it does not believe any market
participants would be gamed or harmed
in such a circumstance.81
In Amendment No. 2, the Exchange
stated that MELOs may be cancelled at
any time, including during the Holding
Period, in order to allow members to
effectively manage risk.82 The Exchange
also acknowledged that the potential
exists for some participants to use
MELOs in a way that conflicts with the
stated intention of the order type to
allow longer term investors the
74 See id. at 25. According to the Exchange, MELO
is designed to increase access to, and participation
on, Nasdaq for investors that are less concerned
with the time to execution, but rather are looking
to source liquidity, often in greater size, at the
NBBO midpoint against a counterparty order that
has the same objectives. See id. at 17. The Exchange
noted that the proposal is designed to help ensure
that members with MELOs are not disadvantaged by
other order types entered by participants that have
the benefit of knowing, and reacting to, rapid
changes in the market. See id. at 9.
75 See id. at 25.
76 See Citadel Letter at 4.
77 See id. This commenter also suggested that the
Exchange should clarify that MELOs cannot be
designated IOC, see id., but the Commission notes
that that fact is already stated in the proposal, see
supra note 28 and accompanying text.
78 See Clearpool Letter at 3.
79 See id.
80 See id.
81 See id.
82 See Amendment No. 2 at 8.
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opportunity to safely find like-minded
counterparties at the midpoint on
Nasdaq.83 For this reason, the Exchange
represented that MELOs would be
subject to real-time surveillance to
determine if the order type is being
abused by market participants.84 The
Exchange also stated that it plans to
implement a process, at the same time
as the implementation of MELOs, to
monitor the use of MELOs, with the
intent to apply additional measures, as
necessary, to ensure their usage is
appropriately tied to the intent of the
order type.85 According to the
Exchange, manipulative abuse is subject
to potential disciplinary action under
the Exchange’s rules, and other behavior
that is not necessarily manipulative but
nonetheless frustrates the purposes of
the MELO order type may be subject to
penalties or other participant
requirements to discourage such
behavior, should it occur.86
V. Proceedings To Determine Whether
To Approve or Disapprove SR–
NASDAQ–2017–074, as Modified by
Amendment Nos. 1 and 2, and Grounds
for Disapproval Under Consideration
The Commission is instituting
proceedings pursuant to Section
19(b)(2)(B) of the Act 87 to determine
whether the proposed rule change, as
modified by Amendment Nos. 1 and 2,
should be approved or disapproved.
Institution of proceedings is appropriate
at this time in view of the legal and
policy issues raised by the proposal, as
discussed below. Institution of
proceedings does not indicate that the
Commission has reached any
conclusions with respect to any of the
issues involved. Rather, as described
below, the Commission seeks and
encourages interested persons to
provide additional comment on the
proposed rule change, as modified by
Amendment Nos. 1 and 2.
Pursuant to Section 19(b)(2)(B) of the
Act,88 the Commission is providing
notice of the grounds for disapproval
under consideration. As discussed
above, the Exchange has proposed to
83 See
id. at 22.
id.
85 See id. According to the Exchange, this process
may include metrics tied to participant behavior,
such as the percentage of MELOs cancelled prior to
completion of the Holding Period, the average
duration of MELOs, and the percentage of MELOs
where the NBBO midpoint is within the limit price
when received. See id.
86 See id. at 23. The Exchange stated that punitive
fees or other prerequisite requirements tied to
MELO usage would be implemented by rule filing
under Section 19(b) of the Act, should the Exchange
determine that they are necessary to maintain a fair
and orderly market. See id.
87 15 U.S.C. 78s(b)(2)(B).
88 Id.
84 See
PO 00000
Frm 00041
Fmt 4703
Sfmt 4703
offer a new MELO order type, which
would be non-displayed, pegged to the
NBBO midpoint, and eligible for
execution only after a half-second
Holding Period has completed following
the acceptance of the MELO by the
Exchange system (although MELOs
could be cancelled at any time,
including during the Holding Period). In
addition, MELOs would be eligible to
execute only against other MELOs and
would not be eligible to execute against
any other trading interest on the Nasdaq
book, including resting contra-side
orders that are priced more aggressively
than the NBBO midpoint.
The Commission is instituting
proceedings to allow for additional
analysis of, and input from commenters
with respect to, the consistency of the
proposal with Sections 6(b)(5) 89 and
6(b)(8) 90 of the Act. Section 6(b)(5) of
the Act requires that the rules of a
national securities exchange be
designed, among other things, 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, and
not be designed to permit unfair
discrimination between customers,
issuers, brokers, or dealers. Section
6(b)(8) of the Act requires that the rules
of a national securities exchange not
impose any burden on competition that
is not necessary or appropriate in
furtherance of the purposes of the Act.
V. Procedure: Request for Written
Comments
The Commission requests that
interested persons provide written
submissions of their data, views, and
arguments with respect to the issues
identified above, as well as any other
concerns they may have with the
proposal. In particular, the Commission
invites the written views of interested
persons concerning whether the
proposed rule change, as modified by
Amendment Nos. 1 and 2, is consistent
with Section 6(b)(5), 6(b)(8), or any
other provision of the Act, or rules and
regulations thereunder. Although there
does not appear to be any issues
relevant to approval or disapproval
which would be facilitated by an oral
presentation of data, views, and
arguments, the Commission will
consider, pursuant to Rule 19b–4 under
the Act,91 any request for an
89 15
U.S.C. 78f(b)(5).
U.S.C. 78f(b)(8).
91 17 CFR 240.19b–4.
90 15
E:\FR\FM\09NON1.SGM
09NON1
Federal Register / Vol. 82, No. 216 / Thursday, November 9, 2017 / Notices
opportunity to make an oral
presentation.92
Interested persons are invited to
submit written data, views, and
arguments regarding whether the
proposed rule change, as modified by
Amendment Nos. 1 and 2, should be
approved or disapproved by November
30, 2017. Any person who wishes to file
a rebuttal to any other person’s
submission must file that rebuttal by
December 14, 2017. 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 No. SR–
NASDAQ–2017–074 on the subject line.
sradovich on DSK3GMQ082PROD with NOTICES
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 No.
SR–NASDAQ–2017–074. The 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
filing also will be available for
inspection and copying at the principal
office of the Exchange. All comments
received will be posted without change.
92 Section 19(b)(2) of the Act, as amended by the
Securities Acts Amendments of 1975, Public Law
94–29 (June 4, 1975), grants to the Commission
flexibility to determine what type of proceeding—
either oral or notice and opportunity for written
comments—is appropriate for consideration of a
particular proposal by a self-regulatory
organization. See Securities Acts Amendments of
1975, Senate Comm. on Banking, Housing & Urban
Affairs, S. Rep. No. 75, 94th Cong., 1st Sess. 30
(1975).
VerDate Sep<11>2014
17:32 Nov 08, 2017
Jkt 244001
52079
Persons submitting comments are
cautioned that we do not redact or edit
personal identifying information from
comment submissions. You should
submit only information that you wish
to make available publicly. All
submissions should refer to File No.
SR–NASDAQ–2017–074 and should be
submitted by November 30, 2017.
Rebuttal comments should be submitted
by December 14, 2017.
are reviewed for continued sufficiency
not less than annually.3 The Collateral
Risk Management Policy is included as
confidential Exhibit 5 of the filing.
The proposed rule change does not
require any changes to the text of OCC’s
By-Laws or Rules. All terms with initial
capitalization that are not otherwise
defined herein have the same meaning
as set forth in the OCC By-Laws and
Rules.4
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.93
Eduardo A. Aleman,
Assistant Secretary.
II. Clearing Agency’s Statement of the
Purpose of, and Statutory Basis for, the
Proposed Rule Change
In its filing with the Commission,
OCC 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. OCC has prepared
summaries, set forth in sections (A), (B),
and (C) below, of the most significant
aspects of these statements.
[FR Doc. 2017–24371 Filed 11–8–17; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–82009; File No. SR–OCC–
2017–008]
Self-Regulatory Organizations; The
Options Clearing Corporation; Notice
of Filing of Proposed Rule Change
Related to The Options Clearing
Corporation’s Collateral Risk
Management Policy
November 3, 2017.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934,1 and
Rule 19b–4 thereunder,2 notice is
hereby given that on October 27, 2017,
The Options Clearing Corporation
(‘‘OCC’’) filed with the Securities and
Exchange Commission (‘‘Commission’’)
the proposed rule change as described
in Items I, II, and III below, which Items
have been prepared by OCC. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
I. Clearing Agency’s Statement of the
Terms of Substance of the Proposed
Rule Change
This proposed rule change by The
Options Clearing Corporation (‘‘OCC’’)
would formalize and update OCC’s
Collateral Risk Management Policy
(‘‘CRM Policy’’). This policy would
promote compliance with Rule 17Ad–
22(e)(5), which generally requires a
covered clearing agency to have policies
and procedures reasonably designed to,
among other things, limit the assets it
accepts as collateral to those with low
credit, liquidity, and market risks and
subject such assets to appropriate
haircuts and concentration limits that
93 17 CFR 200.30–3(a)(12); 17 CFR 200.30–
3(a)(57).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
PO 00000
Frm 00042
Fmt 4703
Sfmt 4703
(A) Clearing Agency’s Statement of the
Purpose of, and Statutory Basis for, the
Proposed Rule Change
(1) Purpose
Background
On September 28, 2016, the
Commission adopted amendments to
Rule 17Ad–22 5 and added new Rule
17Ab2–2 6 pursuant to Section 17A of
the Securities Exchange Act of 1934, as
amended, (‘‘Act’’) 7 and the Payment,
Clearing, and Settlement Supervision
Act of 2010 (‘‘Payment, Clearing and
Settlement Supervision Act’’) 8 to
establish enhanced standards for the
operation and governance of those
clearing agencies registered with the
Commission that meet the definition of
a ‘‘covered clearing agency,’’ as defined
by Rule 17Ad–22(a)(5) 9 (collectively,
the new and amended rules are herein
referred to as ‘‘CCA’’ rules). The CCA
rules require that a covered clearing
agency, among other things, establish,
implement, maintain, and enforce
written policies and procedures
reasonably designed to:
‘‘[l]imit the assets it accepts as collateral to
those with low credit, liquidity, and market
risks, and set and enforce appropriately
conservative haircuts and concentration
limits if the covered clearing agency requires
3 17
CFR 240.17Ad–22(e)(5).
By-Laws and Rules can be found on
OCC’s public Web site: https://optionsclearing.com/
about/publications/bylaws.jsp.
5 17 CFR 240.17Ad–22.
6 17 CFR 240.17Ab2–2.
7 15 U.S.C. 78q–1.
8 12 U.S.C. 5461 et seq.
9 17 CFR 240.17Ad–22(a)(5).
4 OCC’s
E:\FR\FM\09NON1.SGM
09NON1
Agencies
[Federal Register Volume 82, Number 216 (Thursday, November 9, 2017)]
[Notices]
[Pages 52075-52079]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-24371]
=======================================================================
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-82013; File No. SR-NASDAQ-2017-074]
Self-Regulatory Organizations; The NASDAQ Stock Market LLC;
Notice of Filing of Amendment No. 2 and Order Instituting Proceedings
To Determine Whether To Approve or Disapprove a Proposed Rule Change,
as Modified by Amendment Nos. 1 and 2, To Adopt the Midpoint Extended
Life Order
November 3, 2017.
I. Introduction
On July 21, 2017, the NASDAQ Stock Market LLC (``Exchange'' or
``Nasdaq'') 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 the Midpoint Extended Life Order
(``MELO''). The proposed rule change was published for comment in the
Federal Register on August 9, 2017.\3\ On August 9, 2017, the Exchange
filed Amendment No. 1 to the proposed rule change.\4\ On September 21,
2017, pursuant to Section 19(b)(2) of the Act,\5\ the Commission
designated a longer period within which to approve the proposed rule
change, disapprove the proposed rule change, or institute proceedings
to determine whether to approve or disapprove the proposed rule
change.\6\ The Commission has received three comment letters on the
proposal.\7\ On October 30, 2017, the Exchange filed Amendment No. 2 to
the proposed rule change.\8\ The Commission is publishing this notice
and order to solicit comments on the proposed rule change, as modified
by Amendment Nos. 1 and 2, from interested persons and to institute
proceedings pursuant to Section 19(b)(2)(B) of the Act \9\ to determine
whether to approve or disapprove the proposed rule change, as modified
by Amendment Nos. 1 and 2.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 81311 (August 3,
2017), 82 FR 37248 (``Notice'').
\4\ In Amendment No. 1, the Exchange updated the proposal to
reflect the approval of the proposal by the Exchange's Board of
Directors on July 21, 2017. Amendment No. 1 is available at https://www.sec.gov/comments/sr-nasdaq-2017-074/nasdaq2017074.htm. Because
Amendment No. 1 is a technical amendment that does not alter the
substance of the proposed rule change, it is not subject to notice
and comment.
\5\ 15 U.S.C. 78s(b)(2).
\6\ See Securities Exchange Act Release No. 81668, 82 FR 45095
(September 27, 2017). The Commission designated November 7, 2017 as
the date by which the Commission shall approve or disapprove, or
institute proceedings to determine whether to approve or disapprove,
the proposed rule change.
\7\ See Letters to Brent J. Fields, Secretary, Commission, from
Stephen John Berger, Managing Director, Government & Regulatory
Policy, Citadel Securities, dated August 30, 2017 (``Citadel
Letter''); Ray Ross, Chief Technology Officer, The Clearpool Group,
dated September 12, 2017 (``Clearpool Letter''); and Joanna Mallers,
Secretary, FIA Principal Traders Group, dated September 19, 2017
(``FIA PTG Letter'').
\8\ In Amendment No. 2, the Exchange: (1) Modified the proposal
to prevent MELOs from trading when better-priced non-displayed
orders rest on the Nasdaq book; (2) provided additional description,
clarification, and rationale for certain aspects of the proposal;
and (3) responded to several concerns raised by commenters on the
proposal. Amendment No. 2 is available at https://www.sec.gov/comments/sr-nasdaq-2017-074/nasdaq2017074.htm.
\9\ 15 U.S.C. 78s(b)(2)(B).
---------------------------------------------------------------------------
II. Description of the Proposal
The Exchange proposed to offer the MELO order type. A MELO would be
a non-displayed order priced at the midpoint between the National Best
Bid and Offer (``NBBO'') and would not be eligible to execute until a
minimum period of one half of a second (``Holding Period'') has passed
after acceptance of the order by the system.\10\ Once eligible to
trade, MELOs would be ranked in time priority at the NBBO midpoint
among other MELOs.\11\ If a limit price is assigned to a MELO, the
order would be: (1) Eligible for execution in time priority if upon
acceptance of the order by the system, the midpoint price is within the
limit set by the participant; or (2) held until the midpoint falls
within the limit set by the participant, at which time the Holding
Period would commence and thereafter the system would make the order
eligible for execution in time priority.\12\
---------------------------------------------------------------------------
\10\ See proposed Nasdaq Rule 4702(b)(14)(A).
\11\ See id.
\12\ See id.
---------------------------------------------------------------------------
If a MELO is modified by a member (other than to decrease the size
of the order or to modify the marking of a sell order as long, short,
or short exempt) during the Holding Period, the system would restart
the Holding Period.\13\ Similarly, if a MELO is modified by a member
(other than to decrease the size of the order or to modify the marking
of a sell order as long, short, or short exempt) after it has become
eligible to execute, the order would have to satisfy a new Holding
Period.\14\
---------------------------------------------------------------------------
\13\ See id. The Exchange noted that any change to a MELO that
would result in a change in the order's timestamp would result in
the MELO being considered altered, and thus the order would be
subject to a new Holding Period before being eligible to trade and
its priority would be based on the new timestamp. See Amendment No.
2 at n.16.
\14\ See proposed Nasdaq Rule 4702(b)(14)(A).
---------------------------------------------------------------------------
Movements in the NBBO while a MELO is in the Holding Period would
not reset the Holding Period, even if, as a result of the NBBO move,
the MELO's limit price is less aggressive than the NBBO midpoint.\15\
Also, if a MELO has met the Holding Period, but the NBBO midpoint is no
longer within its limit, it would nonetheless be ranked in time
priority among other MELOs if the NBBO later moves such that the
midpoint is within the order's limit price (i.e., no new Holding
Period).\16\
---------------------------------------------------------------------------
\15\ See Amendment No. 2 at n.11.
\16\ See proposed Nasdaq Rule 4702(b)(14)(A); Amendment No. 2 at
n.15.
---------------------------------------------------------------------------
MELOs may be entered via any of the Exchange's communications
protocols and the type of communications protocol used would not affect
how the system handles MELOs.\17\ If there is no NBB or NBO, the
Exchange would accept MELOs but would not allow MELO executions until
there is an
[[Page 52076]]
NBBO.\18\ MELOs would be eligible to trade if the NBBO is locked.\19\
If the NBBO is crossed, MELOs would be held by the system until such
time that the NBBO is no longer crossed, at which time they would be
eligible to trade.\20\ MELOs may be cancelled at any time, including
during the Holding Period.\21\
---------------------------------------------------------------------------
\17\ See Amendment No. 2 at n.10.
\18\ See id. at 12. If there is no NBB or NBO upon entry of a
MELO, the system would hold the order in time priority, together
with any other MELOs received while there is no NBB or NBO. See id.
Once there is an NBBO, the Holding Period would begin for the held
MELOs based on time priority. See id.
\19\ See id. at 12-13.
\20\ See id. at 13.
\21\ See proposed Nasdaq Rule 4702(b)(14)(A).
---------------------------------------------------------------------------
MELOs would be active only during Market Hours.\22\ MELOs entered
during Pre-Market Hours would be held by the system in time priority
until Market Hours.\23\ MELOs entered during Post-Market Hours would
not be accepted by the system, and MELOs remaining unexecuted after
4:00 p.m. ET would be cancelled by the system.\24\ MELOs would not be
eligible for the Nasdaq opening, halt, and closing crosses.\25\
---------------------------------------------------------------------------
\22\ See proposed Nasdaq Rule 4702(b)(14)(B). Market Hours begin
after the completion of the Nasdaq Opening Cross (or at 9:30 a.m. ET
in the case of a security for which no Nasdaq Opening Cross occurs).
See Nasdaq Rule 4703(a).
\23\ See proposed Nasdaq Rule 4702(b)(14)(B). ``Pre-Market
Hours'' means the period of time beginning at 4:00 a.m. ET and
ending immediately prior to the commencement of Market Hours. See
Nasdaq Rule 4701(g). A MELO entered during Pre-Market Hours would be
held by the system until the completion of the Opening Cross (or
9:30 a.m. ET if no Opening Cross occurs), ranked in the time that it
was received by the Nasdaq book upon satisfaction of the Holding
Period. See Amendment No. 2 at 11-12.
\24\ See proposed Nasdaq Rule 4702(b)(14)(B). ``Post-Market
Hours'' means the period of time beginning immediately after the end
of Market Hours and ending at 8:00 p.m. ET. See Nasdaq Rule 4701(g).
\25\ See proposed Nasdaq Rule 4703(l); Amendment No. 2 at 12.
MELOs in existence at the time a halt is initiated would be
ineligible to execute and held by the system until trading has
resumed and the NBBO has been received by Nasdaq. See proposed
Nasdaq Rule 4702(b)(14)(A).
---------------------------------------------------------------------------
MELOs must be entered with a size of at least one round lot, and
any shares of a MELO remaining after an execution that are less than
one round lot would be cancelled.\26\ MELOs may have a minimum quantity
order attribute.\27\ MELOs may not be designated with a time-in-force
of immediate or cancel (``IOC'') and are ineligible for routing.\28\
They also may not have the discretion, reserve size, attribution,
intermarket sweep order, display, or trade now order attributes.\29\
---------------------------------------------------------------------------
\26\ See proposed Nasdaq Rule 4702(b)(14)(B).
\27\ See id.
\28\ See id.; see also Amendment No. 2 at 11 and 13.
\29\ See Amendment No. 2 at 13-14.
---------------------------------------------------------------------------
Once a MELO becomes eligible to execute by existing unchanged for
the Holding Period, the MELO may only execute against other eligible
MELOs.\30\ MELOs would not execute if there is a resting non-displayed
order priced more aggressively than the NBBO midpoint, and they instead
would be held until the resting non-displayed order is no longer on the
Nasdaq book or the NBBO midpoint matches the price of the resting non-
displayed order.\31\ MELO executions would be reported to Securities
Information Processors and provided to Nasdaq's proprietary data feeds
without any new or special indication.\32\
---------------------------------------------------------------------------
\30\ See proposed Nasdaq Rule 4702(b)(14)(A).
\31\ See id; see also Amendment No. 2 at 9.
\32\ See Amendment No. 2 at 15.
---------------------------------------------------------------------------
As proposed, MELOs would be subject to real-time surveillance to
determine if the order type is being abused by market participants.\33\
In addition, the Exchange intends to implement a process, at the same
time as the implementation of MELOs, to monitor the use of MELOs with
the intent to apply additional measures, as necessary, to ensure their
usage is appropriately tied to the intent of the order type.\34\ The
Exchange stated that this process may include metrics tied to
participant behavior, such as the percentage of MELOs that are
cancelled prior to the completion of the Holding Period, the average
duration of MELOs, and the percentage of MELOs where the NBBO midpoint
is within the limit price when received.\35\ The Exchange stated that
it is committed to determining whether there is opportunity or
prevalence of behavior that is inconsistent with normal risk management
behavior.\36\ According to the Exchange, manipulative abuse is subject
to potential disciplinary action under the Exchange's rules, and other
behavior that is not necessarily manipulative but nonetheless
frustrates the purposes of the MELO order type may be subject to
penalties or other participant requirements to discourage such
behavior, should it occur.\37\
---------------------------------------------------------------------------
\33\ See id. at 22.
\34\ See id.
\35\ See id.
\36\ See id. at 22-23.
\37\ See id. at 23.
---------------------------------------------------------------------------
The Exchange stated that it plans to implement MELO within thirty
days after Commission approval of the proposal.\38\ The Exchange would
make MELOs available to all members and to all securities upon
implementation, and would announce the implementation date by Equity
Trader Alert.\39\
---------------------------------------------------------------------------
\38\ See id. at 16.
\39\ See id.
---------------------------------------------------------------------------
III. Summary of Comments and the Exchange's Response
The Commission received one comment letter that expressed support
for the proposal \40\ and two comment letters that expressed concerns
about the proposal.\41\
---------------------------------------------------------------------------
\40\ See Clearpool Letter.
\41\ See Citadel Letter and FIA PTG Letter.
---------------------------------------------------------------------------
One commenter stated its belief that MELOs could provide a valuable
tool for investors, and particularly institutional investors, seeking
to execute in large size.\42\ This commenter also stated its belief
that MELOs have the potential to attract longer-term market
participants to Nasdaq, and would provide an additional method to allow
investors to effectively implement their investment strategies on an
exchange.\43\ The commenter observed that, because MELOs would be on an
exchange, they would be available to all Exchange participants, which
the commenter asserted is a fairer and more transparent way for markets
to operate as compared to off-exchange trading venues.\44\
---------------------------------------------------------------------------
\42\ See Clearpool Letter at 1-3.
\43\ See id. at 2.
\44\ See id.
---------------------------------------------------------------------------
Two commenters expressed concern with the degree of order
segmentation presented by the proposal.\45\ They expressed the view
that MELOs would create a separate order book within the Nasdaq
matching system where only MELOs could interact with each other.\46\
One of these commenters stated that the proposal represents an
unprecedented level of exchange-based order flow segmentation.\47\ This
commenter acknowledged the existence of limited exchange-based
mechanisms that have the effect of restricting some order flow
interaction, but contended that the proposal goes significantly beyond
any such existing restrictions.\48\ This commenter noted that the use
of MELOs would result in two orders failing to interact even if they
are of the same size and have prices that cross each other, and
suggested that the Commission consider carefully whether this is
consistent with the definition and purpose of an exchange.\49\
---------------------------------------------------------------------------
\45\ See Citadel Letter at 1-3; FIA PTG Letter at 2. One of
these commenters also expressed the concern that the costs of
approving the MELO order type would far outweigh the potential
benefits. See FIA PTG Letter at 2. This commenter asserted that
artificially introducing latency negatively impacts the price
discovery and formation functions of the exchange. See id. This
commenter also expressed broad concerns about complexity in today's
equity market structure, which are outside the scope of the
Exchange's proposal. See id.
\46\ See Citadel Letter at 1-3; FIA PTG Letter at 2.
\47\ See Citadel Letter at 1.
\48\ See id. at 3.
\49\ See id.
---------------------------------------------------------------------------
[[Page 52077]]
In addition, one commenter remarked that market participants with
marketable held orders or resting orders seeking to execute against
marketable held order flow would be unlikely to utilize MELOs because
marketable held orders are typically required to be executed fully and
promptly.\50\ According to the commenter, as use of the ``MELO order
book'' increases, liquidity in the ``legacy Nasdaq order book'' could
be negatively impacted to the detriment of retail investors.\51\
Moreover, the commenter stated that investors submitting resting MELOs
would not be able to interact with marketable held order flow.\52\ The
commenter suggested that the Exchange could partially mitigate the
negative impacts of MELO order segmentation by revising its proposal to
allow any order to immediately interact with a resting MELO as long as
it is priced beyond the midpoint.\53\
---------------------------------------------------------------------------
\50\ See id. at 1-2.
\51\ See id. at 2.
\52\ See id.
\53\ See id.
---------------------------------------------------------------------------
In contrast, one commenter stated that allowing MELOs to interact
with non-MELOs would defeat the purpose of the MELO order type.\54\
This commenter also stated that it does not believe that the proposal
would negatively impact liquidity or price discovery on the Nasdaq
market because the MELO order type should have little to no detrimental
effect on participants using other order types.\55\ According to this
commenter, to the extent that the MELO order type would provide
incentives for order flow to be directed to a fair access exchange and
away from private market centers, price discovery for the broader
markets might improve.\56\
---------------------------------------------------------------------------
\54\ See Clearpool Letter at 3.
\55\ See id.
\56\ See id.
---------------------------------------------------------------------------
In Amendment No. 2, the Exchange stated that although MELOs may
forgo the opportunity to interact with other liquidity on the Exchange,
users of MELOs accepted this possibility in return for the ability to
interact with other market participants with the same time horizon.\57\
The Exchange also stated its belief that it is not unfair or
discriminatory that non-displayed orders resting on Nasdaq that are
priced more aggressively than the NBBO midpoint would not participate
in MELO executions.\58\ According to the Exchange, the use of resting
non-displayed orders and MELOs would be available to all participants,
and participants would simply need to evaluate which order type best
serves their investment needs.\59\ Moreover, the Exchange stated that
it has conducted a pro forma study of the effect of applying MELOs to
the current market: It reviewed all executions occurring on Nasdaq in
August 2017 and found that only 0.37% of resting non-displayed orders
traded at a price better than the prevailing midpoint at the time of
execution.\60\ According to the Exchange, consequently, the number of
situations in which a participant would have to consider the trade-offs
between posting a non-displayed buy (sell) order at a higher (lower)
price as compared to submitting a MELO is minimal.\61\ In addition, the
Exchange reiterated that all members may use MELOs and thus have access
to MELO liquidity.\62\ Finally, in Amendment No. 2, the Exchange
amended the proposal to provide that MELOs would not execute if there
is a resting non-displayed order priced more aggressively than the NBBO
midpoint; instead, MELOs would be held until the resting non-displayed
order is no longer on the Nasdaq book or the NBBO midpoint matches the
price of the resting non-displayed order.\63\
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\57\ See Amendment No. 2 at 19. The Exchange also compared MELOs
to the minimum quantity order attribute, as well as the retail price
improvement orders available on Nasdaq BX, Inc. See id. The Exchange
stated that both of these types of orders provide the opportunity to
interact with orders meeting certain characteristics, and
consequently may miss the opportunity to receive an execution if the
contra-side order does not meet the specified characteristics. See
id. In addition, the Exchange compared its proposal to the Nasdaq
Crossing Network, which created a series of intra-day crosses at the
NBBO midpoint. See id. at 20. The Exchange stated that Nasdaq
Crossing Network eligible orders were not available for execution
against orders resting on the Nasdaq book. See id. at 20-21.
\58\ See id. at 20.
\59\ See id.
\60\ See id. at 21.
\61\ See id.
\62\ See id.
\63\ See proposed Nasdaq Rule 4702(b)(14)(A).
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One commenter raised the concern that, under the proposal, MELO
executions would be reported to the Securities Information Processors
and provided on Nasdaq's proprietary data feed in the same manner as
all other transactions on Nasdaq.\64\ This commenter stated that this
approach likely would raise concerns about market fairness and
introduce significant complexity for investors, broker-dealers, and
regulators when attempting to analyze market activity and assess
execution quality.\65\ This commenter noted, by way of example, that
investors may see their orders executed on Nasdaq at worse prices than
other contemporaneous executions on Nasdaq and that, without Nasdaq
labeling MELO executions as such, investors may not know why this has
occurred.\66\ This commenter also asserted that, without labeling MELO
executions differently than other executions on Nasdaq, broker-dealer
routing logic may be influenced by liquidity that is not actually
accessible, and regulators may experience difficulties in accurately
filtering market data when evaluating compliance with regulatory
requirements such as best execution.\67\ This commenter urged the
Commission to require that executions resulting from MELOs be marked as
such on the tape.\68\ Alternatively, the commenter suggested that
Nasdaq offer the MELO order type on a separate exchange.\69\
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\64\ See Citadel Letter at 3.
\65\ See id.
\66\ See id.
\67\ See id.
\68\ See id.
\69\ See id.
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By contrast, one commenter stated that it does not believe that the
lack of specific identification of MELOs in trade reports would result
in any difficulties for the markets, or complexity for investors or
other market participants when assessing execution quality.\70\
According to this commenter, users of the MELO order type would be
provided with anonymity and confidentiality, which the commenter
asserted are critical tools in preventing potentially predatory
counterparties from determining intention and using that information to
generate short-term profits at the expense of longer-term
investors.\71\ In addition, this commenter stated that Nasdaq and all
other exchanges currently offer many order types that when executed do
not provide specific indicators showing exactly which order types were
used, and professed not to see how allowing an exchange to add another
order type without such trade reporting disclosure would harm market
participants' ability to measure market quality, as they do not
currently have that ability.\72\
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\70\ See Clearpool Letter at 2.
\71\ See id.
\72\ See id.
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In Amendment No. 2, the Exchange stated that it currently does not
identify on data feeds in real time the order types and attributes that
resulted in an execution (e.g., reserve order attribute).\73\ According
to the Exchange, not identifying MELOs is important to ensure that
investors are protected from market participants that would
[[Page 52078]]
otherwise take advantage of such knowledge and undermine the usefulness
of the order type.\74\ In addition, the Exchange stated that, like any
of the order types or attributes provided by the Exchange, members must
assess which ones would provide them with the best execution in
achieving their investment goals.\75\
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\73\ See Amendment No. 2 at n.34. The Exchange also noted that
there is no real-time transparency regarding which destination or
broker matched a buyer and seller when transactions are reported to
a trade reporting facility. See id. at 25-26. Instead, there are
delayed reports that identify where the executions occurred. See id.
at 26.
\74\ See id. at 25. According to the Exchange, MELO is designed
to increase access to, and participation on, Nasdaq for investors
that are less concerned with the time to execution, but rather are
looking to source liquidity, often in greater size, at the NBBO
midpoint against a counterparty order that has the same objectives.
See id. at 17. The Exchange noted that the proposal is designed to
help ensure that members with MELOs are not disadvantaged by other
order types entered by participants that have the benefit of
knowing, and reacting to, rapid changes in the market. See id. at 9.
\75\ See id. at 25.
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Lastly, one commenter asserted that allowing MELOs to be cancelled
at any time during the Holding Period does not appear to be consistent
with the intended use of the order type.\76\ Instead, according to this
commenter, a MELO should only be permitted to be cancelled after the
Holding Period has expired and the order has been placed in the order
book.\77\ Another commenter, by contrast, did not have an issue with
providing market participants the ability to cancel MELOs during the
Holding Period.\78\ This commenter stated that it believes this would
be an important feature of the MELO order type because many firms use
algorithms to source liquidity simultaneously from multiple venues.\79\
According to the commenter, to the extent that liquidity is found
elsewhere than Nasdaq within the Holding Period, it would be critically
important that the firm be able to cancel its orders from Nasdaq and
re-allocate those shares to other venues.\80\ This commenter stated
that it does not believe any market participants would be gamed or
harmed in such a circumstance.\81\
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\76\ See Citadel Letter at 4.
\77\ See id. This commenter also suggested that the Exchange
should clarify that MELOs cannot be designated IOC, see id., but the
Commission notes that that fact is already stated in the proposal,
see supra note 28 and accompanying text.
\78\ See Clearpool Letter at 3.
\79\ See id.
\80\ See id.
\81\ See id.
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In Amendment No. 2, the Exchange stated that MELOs may be cancelled
at any time, including during the Holding Period, in order to allow
members to effectively manage risk.\82\ The Exchange also acknowledged
that the potential exists for some participants to use MELOs in a way
that conflicts with the stated intention of the order type to allow
longer term investors the opportunity to safely find like-minded
counterparties at the midpoint on Nasdaq.\83\ For this reason, the
Exchange represented that MELOs would be subject to real-time
surveillance to determine if the order type is being abused by market
participants.\84\ The Exchange also stated that it plans to implement a
process, at the same time as the implementation of MELOs, to monitor
the use of MELOs, with the intent to apply additional measures, as
necessary, to ensure their usage is appropriately tied to the intent of
the order type.\85\ According to the Exchange, manipulative abuse is
subject to potential disciplinary action under the Exchange's rules,
and other behavior that is not necessarily manipulative but nonetheless
frustrates the purposes of the MELO order type may be subject to
penalties or other participant requirements to discourage such
behavior, should it occur.\86\
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\82\ See Amendment No. 2 at 8.
\83\ See id. at 22.
\84\ See id.
\85\ See id. According to the Exchange, this process may include
metrics tied to participant behavior, such as the percentage of
MELOs cancelled prior to completion of the Holding Period, the
average duration of MELOs, and the percentage of MELOs where the
NBBO midpoint is within the limit price when received. See id.
\86\ See id. at 23. The Exchange stated that punitive fees or
other prerequisite requirements tied to MELO usage would be
implemented by rule filing under Section 19(b) of the Act, should
the Exchange determine that they are necessary to maintain a fair
and orderly market. See id.
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V. Proceedings To Determine Whether To Approve or Disapprove SR-NASDAQ-
2017-074, as Modified by Amendment Nos. 1 and 2, and Grounds for
Disapproval Under Consideration
The Commission is instituting proceedings pursuant to Section
19(b)(2)(B) of the Act \87\ to determine whether the proposed rule
change, as modified by Amendment Nos. 1 and 2, should be approved or
disapproved. Institution of proceedings is appropriate at this time in
view of the legal and policy issues raised by the proposal, as
discussed below. Institution of proceedings does not indicate that the
Commission has reached any conclusions with respect to any of the
issues involved. Rather, as described below, the Commission seeks and
encourages interested persons to provide additional comment on the
proposed rule change, as modified by Amendment Nos. 1 and 2.
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\87\ 15 U.S.C. 78s(b)(2)(B).
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Pursuant to Section 19(b)(2)(B) of the Act,\88\ the Commission is
providing notice of the grounds for disapproval under consideration. As
discussed above, the Exchange has proposed to offer a new MELO order
type, which would be non-displayed, pegged to the NBBO midpoint, and
eligible for execution only after a half-second Holding Period has
completed following the acceptance of the MELO by the Exchange system
(although MELOs could be cancelled at any time, including during the
Holding Period). In addition, MELOs would be eligible to execute only
against other MELOs and would not be eligible to execute against any
other trading interest on the Nasdaq book, including resting contra-
side orders that are priced more aggressively than the NBBO midpoint.
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\88\ Id.
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The Commission is instituting proceedings to allow for additional
analysis of, and input from commenters with respect to, the consistency
of the proposal with Sections 6(b)(5) \89\ and 6(b)(8) \90\ of the Act.
Section 6(b)(5) of the Act requires that the rules of a national
securities exchange be designed, among other things, 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, and not
be designed to permit unfair discrimination between customers, issuers,
brokers, or dealers. Section 6(b)(8) of the Act requires that the rules
of a national securities exchange not impose any burden on competition
that is not necessary or appropriate in furtherance of the purposes of
the Act.
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\89\ 15 U.S.C. 78f(b)(5).
\90\ 15 U.S.C. 78f(b)(8).
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V. Procedure: Request for Written Comments
The Commission requests that interested persons provide written
submissions of their data, views, and arguments with respect to the
issues identified above, as well as any other concerns they may have
with the proposal. In particular, the Commission invites the written
views of interested persons concerning whether the proposed rule
change, as modified by Amendment Nos. 1 and 2, is consistent with
Section 6(b)(5), 6(b)(8), or any other provision of the Act, or rules
and regulations thereunder. Although there does not appear to be any
issues relevant to approval or disapproval which would be facilitated
by an oral presentation of data, views, and arguments, the Commission
will consider, pursuant to Rule 19b-4 under the Act,\91\ any request
for an
[[Page 52079]]
opportunity to make an oral presentation.\92\
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\91\ 17 CFR 240.19b-4.
\92\ Section 19(b)(2) of the Act, as amended by the Securities
Acts Amendments of 1975, Public Law 94-29 (June 4, 1975), grants to
the Commission flexibility to determine what type of proceeding--
either oral or notice and opportunity for written comments--is
appropriate for consideration of a particular proposal by a self-
regulatory organization. See Securities Acts Amendments of 1975,
Senate Comm. on Banking, Housing & Urban Affairs, S. Rep. No. 75,
94th Cong., 1st Sess. 30 (1975).
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Interested persons are invited to submit written data, views, and
arguments regarding whether the proposed rule change, as modified by
Amendment Nos. 1 and 2, should be approved or disapproved by November
30, 2017. Any person who wishes to file a rebuttal to any other
person's submission must file that rebuttal by December 14, 2017.
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 No. SR-NASDAQ-2017-074 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 No. SR-NASDAQ-2017-074. The 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 filing also will be available
for inspection and copying at the principal office of the Exchange. All
comments received will be posted without change. Persons submitting
comments are cautioned that we do not redact or edit personal
identifying information from comment submissions. You should submit
only information that you wish to make available publicly. All
submissions should refer to File No. SR-NASDAQ-2017-074 and should be
submitted by November 30, 2017. Rebuttal comments should be submitted
by December 14, 2017.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\93\
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\93\ 17 CFR 200.30-3(a)(12); 17 CFR 200.30-3(a)(57).
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Eduardo A. Aleman,
Assistant Secretary.
[FR Doc. 2017-24371 Filed 11-8-17; 8:45 am]
BILLING CODE 8011-01-P