Self-Regulatory Organizations; New York Stock Exchange LLC; NYSE National, Inc.; NYSE Arca, Inc.; NYSE American LLC; Order Granting Approval of a Proposed Rule Change, as Modified by Amendment No. 1, To Amend the Exchanges' Co-Location Services To Offer Co-Location Users Access to the NMS Network, 28671-28675 [2020-10223]
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Federal Register / Vol. 85, No. 93 / Wednesday, May 13, 2020 / Notices
identify eligible orders in the form and
manner determined by the Exchange.
The Exchange believes the proposed
clarifications regarding inactive
nominee fees is reasonable as such
clarifications provide additional
transparency in the Fees Schedule and
alleviate potential confusion, thereby
reducing impediments to, and
perfecting the mechanism of a free and
open market and a national market
system, and, in general, protecting
investors and the public interest. The
Exchange also notes not assessing these
fees is reasonable, equitable and not
unfairly discriminatory as TPHs would
not be subject to such fees and it would
apply uniformly to all nominees and
inactive nominees.
B. Self-Regulatory Organization’s
Statement on Burden on Competition
The Exchange does not believe that
the proposed rule changes will impose
any burden on competition that are not
necessary or appropriate in furtherance
of the purposes of the Act. The
Exchange notes the proposed changes
are not intended to address any
competitive issue, but rather to address
a fee change it believes is reasonable in
the event the trading floor becomes
inoperable, thereby only permitting
electronic participation on the
Exchange. The Exchange does not
believe that the proposed rule change
will impose any burden on intramarket
competition that is not necessary or
appropriate in furtherance of the
purposes of the Act because the
proposed changes apply equally to all
similarly situated market participants.
The Exchange does not believe that the
proposed rule changes will impose any
burden on intermarket competition that
is not necessary or appropriate in
furtherance of the purposes of the Act
because the proposed changes only
affect trading on the Exchange in
limited circumstances.
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
The Exchange neither solicited nor
received comments on the proposed
rule change.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become
effective pursuant to Section 19(b)(3)(A)
of the Act 12 and paragraph (f) of Rule
19b–4 13 thereunder. At any time within
12 15
13 17
U.S.C. 78s(b)(3)(A).
CFR 240.19b–4(f).
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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. If the
Commission takes such action, the
Commission will institute proceedings
to determine whether the proposed rule
change should be approved or
disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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–
CBOE–2020–044 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–CBOE–2020–044. 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 website (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 website 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. Persons
submitting comments are cautioned that
we do not redact or edit personal
identifying information from comment
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28671
submissions. You should submit only
information that you wish to make
available publicly. All submissions
should refer to File Number SR–CBOE–
2020–044, and should be submitted on
or before June 3, 2020.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.14
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–10217 Filed 5–12–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–88837; File Nos. SR–NYSE–
2019–46, SR–NYSENAT–2019–19, SR–
NYSEArca–2019–61, SR–NYSEAMER–2019–
34]
Self-Regulatory Organizations; New
York Stock Exchange LLC; NYSE
National, Inc.; NYSE Arca, Inc.; NYSE
American LLC; Order Granting
Approval of a Proposed Rule Change,
as Modified by Amendment No. 1, To
Amend the Exchanges’ Co-Location
Services To Offer Co-Location Users
Access to the NMS Network
May 7, 2020.
I. Introduction
On August 22, 2019, New York Stock
Exchange LLC, NYSE National, Inc., and
NYSE Arca, Inc. each 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:
(i) Amend their co-location services to
offer co-location Users access to the
‘‘NMS Network’’—a new alternate,
dedicated network providing
connectivity to data feeds for the
National Market System Plans for which
Securities Industry Automation
Corporation (‘‘SIAC’’) is engaged as the
exclusive securities information
processor (‘‘SIP’’); and (ii) establish
associated fees. NYSE American LLC
filed with the Commission a
substantively identical filing on August
23, 2019.3 The proposed rule changes
were published for comment in the
Federal Register on September 10,
14 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 The New York Stock Exchange LLC, NYSE
National, Inc., NYSE Arca, Inc., and NYSE
American, LLC are collectively referred to herein as
‘‘NYSE’’ or the ‘‘Exchanges.’’
1 15
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2019.4 On October 24, 2019, the
Commission extended the time period
within which to approve, disapprove, or
institute proceedings to determine
whether to approve or disapprove the
Original Proposal, to December 9, 2019.5
The Commission received one comment
letter on the Original Proposal, a
response from the Exchanges, and a
second letter from the original
commenter.6 On December 9, 2019, the
Commission instituted proceedings to
determine whether to approve or
disapprove the Original Proposal.7 On
December 23, 2019, the Exchange filed
Amendment No. 1 to the Original
Proposal. Amendment No. 1, which
superseded and replaced the Original
Proposal in its entirety, was published
for comment in the Federal Register on
January 15, 2020.8 The Commission
received one comment letter on the
4 See Securities Exchange Act Release Nos. 86865
(September 4, 2019), 84 FR 47592 (SR–NYSE–2019–
46); 86869 (September 4, 2019), 84 FR 47600 (SR–
NYSENAT–2019–19); 86868 (September 4, 2019),
84 FR 47610 (SR–NYSEArca–2019–61); 86867
(September 4, 2019), 84 FR 47563 (SR–
NYSEAMER–2019–34) (collectively the ‘‘Original
Notice’’ or ‘‘Original Proposal’’). Page citations to
the Original Notice refer to the Notice for SR–
NYSE–2019–46 as published in the Federal
Register.
5 See Securities Exchange Act Release Nos. 87399,
84 FR 58189 (October 30, 2019) (SR–NYSE–2019–
46); 87402, 84 FR 58187 (October 30, 2019) (SR–
NYSENAT–2019–19); 87400, 84 FR 58189 (October
30, 2019) (SR–NYSEArca–2019–61); 87401, 84 FR
58188 (October 30, 2019) (SR–NYSEAMER–2019–
34).
6 See, respectively, letter dated October 24, 2019
from John M. Yetter, Vice President and Senior
Deputy General Counsel, Nasdaq Stock Market LLC
(‘‘Nasdaq’’), to Vanessa Countryman, Secretary,
Commission (‘‘Nasdaq Letter’’); letter dated
November 8, 2019 from Elizabeth K. King, Chief
Regulatory Officer, ICE, General Counsel and
Corporate Secretary, NYSE to Ms. Vanessa
Countryman, Secretary, Commission (‘‘NYSE
Response Letter’’); and letter dated November 25,
2019 from Joan C. Conley, Senior Vice President
and Corporate Secretary, Nasdaq, to Vanessa
Countryman, Secretary, Commission (‘‘Second
Nasdaq Letter’’). All comments received by the
Commission on the proposed rule change are
available on the Commission’s website at: https://
www.sec.gov/comments/sr-nyse-2019-46/
srnyse201946.htm. NYSE filed a comment letter on
behalf of all of the Exchanges.
7 See Securities Exchange Act Release No. 87699
(December 9, 2019), 84 FR 68239 (December 13,
2019) (SR–NYSE–2019–46; SR–NYSENAT–2019–
19; SR–NYSEArca–2019–61; SR–NYSEAMER–
2019–34) (‘‘Order Instituting Proceedings’’ or
‘‘OIP’’).
8 See Securities Exchange Act Releases No. 87927
(January 9, 2020), 85 FR 2468 (SR–NYSE–2019–46);
87930 (January 9, 2020), 85 FR 2459 (SR–
NYSENAT–2019–19); 87929 (January 9, 2020), 85
FR 2453 (SR–NYSEAMER–2019–34); and 87928
(January 9, 2020), 85 FR 2447 (SR–NYSE–2019–61)
(collectively, ‘‘Amendment No. 1’’ or the
‘‘Amended Proposal’’). The Amended Proposal also
is available at https://www.sec.gov/comments/srnyse-2019-46/srnyse201946-6584636-201247.pdf.
Page citations to the Amended Proposal refer to
Amendment No. 1 for SR–NYSE–2019–46 as
published in the Federal Register.
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Amended Proposal and a response from
the Exchanges.9 The Commission is
approving the proposed rule change, as
modified by Amendment No. 1.
II. Description of the Proposed Rule
Change, as Modified by Amendment
No. 1
A. Background
The Exchanges’ affiliate, SIAC, is
currently engaged as the exclusive SIP
for three National Market System Plans:
(1) The Consolidated Trade Association
(‘‘CTA’’) Plan; (2) the Consolidated
Quotation (‘‘CQ’’) Plan; and (3) the
Options Price Reporting Authority
(‘‘OPRA’’) Plan.10 SIAC operates in the
same data center (‘‘Data Center’’) in
Mahwah, New Jersey from which the
Exchanges operate and offer co-location
services to co-location ‘‘Users.’’ 11 A colocation ‘‘User’’ is any market
participant that requests to receive colocation services directly from the
Exchange for fees set forth on price lists
filed with the Commission.12
Currently, Users can connect to the
CTA Plan, CQ Plan, and OPRA Plan
data feeds (the ‘‘NMS Feeds’’)
disseminated by the SIP using either of
the co-location local area networks in
the Data Center, which include the
Liquidity Center Network (‘‘LCN’’) and
IP network.13 Currently, a User would
need to purchase a service that includes
either a 10 Gb or 40 Gb connection to
access the LCN and/or IP network and
connect to the NMS feeds.14 Users do
not pay an additional or separate charge
to connect to the NMS Feeds via the
LCN or IP network, but rather pay for
the bandwidth they determine will meet
their needs in co-location.15
9 See, respectively, letter dated February 5, 2020
from Joan C. Conley, Senior Vice President and
Corporate Secretary, Nasdaq, to Vanessa
Countryman, Secretary, Commission (‘‘Nasdaq
Letter III’’) and letter dated February 25, 2020 from
Elizabeth K. King, Chief Regulatory Officer, ICE,
General Counsel and Corporate Secretary, NYSE to
Ms. Vanessa Countryman, Secretary, Commission
(‘‘NYSE Response Letter II’’). All comments
received by the Commission on the proposed rule
change are available on the Commission’s website
at: https://www.sec.gov/comments/sr-nyse-2019-46/
srnyse201946.htm. NYSE filed a comment letter on
behalf of all of the Exchanges.
10 See Amended Proposal, supra note 8, at n. 16.
11 See Amended Proposal, supra note 8, 85 FR at
2469.
12 See Amended Proposal, supra note 8, at n. 10.
As stated in the price list of each of the Exchanges,
a User that incurs co-location fees for a particular
co-location service is not subject to co-location fees
for the same co-location service charged by another
of the Exchanges. See id.
13 See id, 85 FR at 2469.
14 Id.
15 Currently, a User that purchases access to the
LCN or IP network also receives the ability to access
the trading and execution systems of the Exchanges,
and the trading and execution systems of OTC
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B. Original Proposal and Order
Instituting Proceedings
As more fully set forth in the Original
Notice, the Exchanges initially proposed
to offer access to the new NMS Network
and establish associated fees. The NMS
Network would be an alternate,
dedicated network from which colocation Users could access and connect
to the NMS Feeds. The NMS Network
would have an anticipated benefit of a
one-way reduction in latency, as
compared to the IP network and/or LCN,
of over 140 microseconds. The
Exchanges explained that SIAC
continually assesses the services it
provides and had been working with the
operating committees of the NMS Plans
and the industry-based advisory
committee to the CTA/CQ Plans to
identify potential performance
enhancements for the SIP, including one
that would address concerns that access
to the NMS Feeds (required to traverse
over the IP network), were subject to an
additional layer of latency because the
IP network was not designed as a lowlatency network.16
Under the Original Proposal, a User
would have been permitted to connect
to the NMS Feeds via the newly
established NMS Network at no
additional charge subject to certain
conditions. Specifically, if a User
purchased 10Gb or 40Gb access to the
LCN or IP network and requested a
connection to the NMS Network, that
User and its Affiliates,17 taken together,
would not have been charged for up to
eight corresponding NMS Network
connections (each a ‘‘No Additional Fee
NMS Network Connection’’), if:
(i) Such User, together with its
Affiliates, designated no more than four
No Additional Fee NMS Network
Connections as corresponding to the
LCN connections of the User, together
with its Affiliates, on a one-to-one basis;
(ii) such User, together with its
Affiliates, designated no more than four
Global, an alternative trading system (‘‘ATS’’),
subject, in each case, to authorization by the
relevant entity; as well as connectivity to market
data products that a User selects from a list of
Included Data Products, subject to technical
provisioning requirements and authorization from
the provider of the data feed. The Included Data
Products are the NMS Feeds and the proprietary
feeds of the Exchanges and its affiliate, NYSE
Chicago. Id.
16 See Original Notice, supra note 4, 84 FR at
47594.
17 See Original Notice, supra note 4, at n. 17,
noting that ‘‘Affiliate’’ of a User is defined in the
price list as ‘‘any other User or Hosted Customer
that is under 50% or greater common ownership or
control of the first User;’’ that a ‘‘Hosted Customer’’
is a customer of a Hosting User that is hosted in
a Hosting User’s co-location space; and a ‘‘Hosting
User’’ is a User of colocation services that hosts a
Hosted Customer in the User’s co-location space.
Hosting Users are subject to Hosting fees.
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No Additional Fee NMS Network
Connections as corresponding to the IP
network connections of the User,
together with its Affiliates, on a one-toone basis;
(iii) such User, together with its
Affiliates, did not use the LCN or IP
network connections that correspond to
the No Additional Fee NMS Network
Connections to access the NMS Feeds; 18
and
(iv) each of the No Additional Fee
NMS Network Connections was of equal
size or smaller than the associated LCN
or IP network connection purchased by
it or its Affiliates.19
In contrast, a User that did not satisfy
these conditions would have been
subject to an additional or separate
charge to access the NMS Network.20
Those seeking an NMS Network
connection that did not qualify as a No
Additional Fee NMS Network
Connection would have been assessed:
(i) $10,000 per connection initial charge
and $11,000/month for a 10 Gb
connection; or (ii) $10,000 per
connection initial charge and $18,000/
month for a 40 Gb connection (the same
fee assessed for the same-sized 10 Gb or
40 Gb IP network connection).21
The Commission received one
comment letter on the Original Proposal
from Nasdaq, a response from the
Exchanges, and a second letter from
Nasdaq.22 In its initial comment letter,
Nasdaq observed that the Exchanges’
proposal would permit market
participants who separately pay the
Exchanges to connect to their trading
venue(s) to receive up to eight free
connections to the faster NMS Network;
whereas market participants who elect a
stand-alone connection to the NMS
Feeds would be charged.23 Nasdaq
expressed concern that the
‘‘commingling,’’ or bundling, of pricing
for NMS Network connectivity with
18 Users would still have had the option to
connect to the NMS Feeds using their LCN or IP
network connections, but would have been charged
the proposed fee for the NMS Network connection.
19 See Original Notice, supra note 4, 84 FR at
47594. Accordingly, a User’s access to a 1 Gb
connection would not entitle a User to a No
Additional Fee NMS Network Connection.
20 See id. at 47595. According to the Exchanges,
Users would typically be charged separately for
access to the NMS Network in circumstances where
they (i) would like to purchase access to the NMS
Network and have not purchased a 10 Gb or 40 Gb
LCN or IP network connection; (ii) have purchased
an LCN or IP connection but would like NMS
Network connections in excess of permitted number
of corresponding No Additional Fee NMS Network
Connections; and/or (iii) would like to use their
LCN and IP connections to continue to access the
NMS Feeds.
21 See id.
22 See Nasdaq Letter, NYSE Response Letter, and
Second Nasdaq Letter, supra note 6.
23 See Nasdaq Letter at 1.
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connectivity to the NYSE venues,
including access to NYSE proprietary
data feeds, would create a burden on
intermarket competition and hinder
potential providers from competing to
serve as network processor in place of
SIAC.24 In Nasdaq’s view, ‘‘[a]ny change
to the current processor would increase
costs to market participants that would
purchase a subset of NMS Network
Connections from the new provider and
continue to pay the bundled price to
NYSE to connect and transact business
on NYSE.’’ 25 Nasdaq also believed that
NYSE’s failure to offer market
participants the opportunity to acquire
NMS Network connections individually
hindered competition.26 Finally, Nasdaq
took the position that the Exchanges’
proposal would burden intermarket
competition because other exchanges
would be unable to couple their pricing
for connectivity to their trading venues
with NMS Network connections.27
The Exchanges responded by noting
that Section 6(b)(8) of the Act requires
that the rules of an exchange not impose
any burden on competition that is not
necessary or appropriate in furtherance
of the Exchange Act.28 With respect to
Nasdaq’s first argument, the Exchanges
took the position that the bidding
process to be the exclusive SIP for an
NMS Plan is a commercial competition
that is not intermarket competition as
contemplated by the Exchange Act, and
that how (and how much) a bidder
chose to charge for connectivity to its
SIP would be part of its bid.29 The
Exchanges characterized Nasdaq’s
second argument as ‘‘baseless’’ because
market participants would in fact be
able to purchase a stand-alone NMS
Network connection.30 The Exchanges
expressed the view that Nasdaq’s final
argument was unfounded because there
inherently is no competition to provide
connectivity to an exclusive SIP.31 The
Exchanges further stated that while the
NMS Network would be offered at no
additional cost to current Users, the
only way to address Nasdaq’s concerns
would be to increase fees currently
charged to Users to connect to the
Exchanges.32 In this regard, the
Exchanges observed that Nasdaq’s
24 Id.
25 Id.
at 1–2.
at 2.
26 Id.
27 Id.
28 See NYSE Response Letter, supra note 6, at 3.
They added that NYSE sought and received
approval from both the CTA Operating Committee
and OPRA Management Committee (both of which
include Nasdaq as a member) on the Original
Proposal. Id.
29 Id. at 4.
30 Id. at 5.
31 Id.
32 Id. at 5–7.
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28673
approach to managing its own fees for
connectivity to the UTP SIP Feed
(defined below) is similar to the
approach proposed by the Exchanges in
that both parties seek to leverage their
existing exchange connectivity fees to
keep costs down for providing
connectivity to the relevant SIPs.33
In a second comment letter, Nasdaq
stated its general support for the
proposed NMS Network, but reiterated
its view that the Exchanges’ proposed
fee structure would hamper competitors
from bidding to replace SIAC as the
SIP.34 According to Nasdaq, if another
exchange or third party became the SIP
for one of the three NMS Feeds, market
participants would need to separately
connect to two separate environments to
obtain all three NMS Feeds, at increased
costs.35 Nasdaq urged that NMS
Network connectivity should be priced
separately from exchange connectivity,
and offered examples of how this could
be accomplished without an increase in
NYSE’s fees.36
The Commission issued an Order
Instituting Proceedings, requesting
comment on the NMS Network fee
structure set forth in the Original
Proposal.37 The Commission
highlighted that the Exchanges
proposed to make the NMS Network
available at no additional charge to
Users that satisfied certain conditions
(as described above) and to impose a
substantial charge on Users seeking
access to the NMS Network that did not
satisfy the proposed conditions.38 In
particular, the Commission questioned
the basis for the level of the proposed
fee for a charged NMS connection
($10,000 initially and $11,000 or
$18,000 monthly for a 10 Gb or 40 Gb
connection, respectively), as well as
whether it was reasonable, equitable,
and not unfairly discriminatory for only
certain Users to receive NMS Network
Connections at no additional charge.39
The Commission also solicited comment
on whether the revised fee structure for
the NMS Network set forth in the
Original Proposal would impose an
33 Id. In making this statement, the Exchanges
also acknowledge that the specific way in which
Nasdaq seeks to effect this outcome is different from
what the Exchanges propose (i.e., Nasdaq offers
UTP NMS Plan customers two free connections and
additional connections for $100 per month).
34 See Second Nasdaq Letter, supra note 6, at 1–
2.
35 Id. at 2.
36 More specifically, Nasdaq suggested that the
Exchanges could: (i) Separately price NMS Network
connectivity and NYSE connectivity; (ii) price each
NMS Feed connection separately; or (iii) separate
OPRA NMS Feed connectivity from CTA and CQ
NMS Feed connectivity. See id. at 3.
37 See OIP, supra note 7.
38 Id.
39 Id.
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undue burden on competition that is not
necessary or appropriate under the
Act.40
C. Amendment No. 1
Following the OIP, the Exchanges
filed Amendment No. 1. As more fully
set forth in Amendment No. 1, the
Exchanges propose to eliminate the fee
changes associated with the proposed
new NMS Network service.41 In lieu of
establishing conditions for No
Additional Fee NMS Network
Connections and proposing separate
charged NMS Network connections, the
Exchanges instead propose to offer colocation Users access to the NMS
Network as a new service with no
associated fee changes. To effect this
change, the Exchanges propose to
amend the services available to colocation Users to provide that if a User
purchases a service that includes a 10
Gb or 40 Gb IP or LCN network
connection, that purchase would
include an NMS Network connection of
the same size.42 For co-location Users,
the option of receiving connectivity to
the NMS Feeds in co-location would
therefore continue to be included when
a User purchases a 10 Gb or 40 Gb
network IP or LCN circuit.43 Access to
the NMS Network would thus be offered
as a service upgrade, designed to
provide co-location Users a one-way
reduction in latency for the NMS Feeds
of over 140 microseconds, as compared
to the IP network and LCN, at no
additional cost.44
III. Summary of Comments on
Amendment No. 1 and Exchanges’
Response
Nasdaq submitted a comment letter
on Amendment No. 1, objecting that the
Amended Proposal continues to
integrate access to the Exchanges’
proprietary products with access to the
NMS Feeds in an improper manner that
would impose a burden on competition
that is neither necessary nor appropriate
under the Act.45 According to Nasdaq,
market participants currently paying for
connectivity to NYSE proprietary data
40 Id.
41 See
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42 See
Amended Proposal, supra note 8.
Amended Proposal, supra note 8, 85 FR at
2470.
43 Id. More specifically, the Exchanges propose to
amend the sections of the price lists that set forth
the services offering the 10 Gb and 40 Gb LCN
connection and the 10 Gb and 40 Gb IP connection
and their prices to include an NMS Network
connection as part of each service and to include
a note for each service stating that the connection
offered as part of the service and the NMS Network
connection are together considered to be one
connection, so Users are not subject to two initial
or two monthly charges. Id.
44 Id.
45 See Nasdaq Letter III, supra note 9, at 1.
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feeds can receive NMS Network
connectivity at no additional cost, but
are forced to pay for this connectivity
within the bundled price, and new
market participants that only want to
receive NMS Feeds are effectively
forced to pay the bundled fees.46 In
addition, Nasdaq took the position that,
because the OPRA feed is so large, the
bundling with OPRA has the effect of
steering all market participants to
consume larger bandwidths at higher
cost.47
In response, the Exchanges state that
they do not propose to change any fee
or the availability of any current
connectivity option; rather they propose
only to add NMS Network connectivity
as a service provided to co-location
Users.48 They further state that Nasdaq
focuses on whether existing fees for
connectivity to the NMS Feeds are a
burden on competition, but note that
that issue is not before the
Commission.49 Instead, in the
Exchanges’ view, their proposal would
simply add a new service and provide
more choice to Users, allowing them to
opt to use the low-latency NMS
Network to connect to NMS feeds.50 In
addition, the Exchanges take the
position that Nasdaq’s claim that such
Users are forced to purchase larger
bandwidth has no basis, as there are
multiple reasons why a User would
purchase a larger connection, and the
additional capacity provided by the
NMS Network should reduce demand
for those larger connections.51
IV. Discussion and Commission
Findings
The Commission finds that the
proposed rule change, as modified by
Amendment No. 1, is consistent with
the requirements of the Act and the
rules and regulations thereunder
applicable to a national securities
exchange. In particular, the Commission
finds that the proposed rule change, as
46 Id. at 2. The Exchanges responded that all
direct recipients of the NMS Feeds in co-location
also connect to one or more of the Exchanges for
trading purposes. See NYSE Response Letter II,
supra note 9, at 3.
47 Id. at 3.
48 See NYSE Response Letter II, supra note 9, at
2.
49 Id. at 2–3. The Exchanges further note that
Nasdaq’s objections to the Exchanges bundled fee
structure would not be resolved by approval or
disapproval of the Amended Proposal.
50 Id. at 3.
51 Id. at 3. Specifically, the Exchanges state that
the additional capacity provided by the NMS
Network will reduce demand for 40 Gb connections
and permit some Users to instead consume NYSE
Exchanges’ data over a 10 Gb local area network
connection and NMS Feeds over the
complementary 10 Gb NMS Network connection.
Id. at n. 5.
PO 00000
Frm 00076
Fmt 4703
Sfmt 4703
modified by Amendment No. 1, is
consistent with Section 6(b)(5) of the
Act,52 which requires that the rules of
an exchange be designed, among other
things, to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, to remove impediments to and
perfect the mechanism of a free and
open market and a national market
system and, in general, to protect
investors and the public interest, and
not be designed to permit unfair
discrimination between customers,
issuers, brokers or dealers; and Section
6(b)(8) of the Act,53 which prohibits any
exchange rule from imposing any
burden on competition that is not
necessary or appropriate in furtherance
of the Act.54
In the Amended Proposal, the
Exchanges propose to augment how colocation Users may connect to the NMS
Feeds in the Data Center by offering
them access to the ‘‘NMS Network,’’ an
upgraded alternative local area network,
and to do so without the associated fee
changes that were part of the Original
Proposal. As discussed above, Nasdaq
takes the position that, because the
Exchanges’ proposal does not separate
pricing for connectivity to the NMS
Feeds from pricing for connectivity to
the Exchanges’ proprietary products, the
proposal imposes an unnecessary or
inappropriate burden on competition
that is inconsistent with the Act. The
Exchanges respond that they simply
propose to offer a new connectivity
option for co-location Users without any
fee change and that, regardless,
Nasdaq’s arguments that the existing fee
structure burdens competition in a
manner inconsistent with the Act are
without merit.
The Commission believes that the
Amended Proposal is responsive to the
issues identified in the Order Instituting
Proceedings, and that the Amended
Proposal is consistent with the Act.
Under the Amended Proposal, the
Exchanges remove the proposed limits
on No Additional Fee NMS Network
Connections. Accordingly, under the
Amended Proposal, the Exchanges
would provide co-location Users the
option to access consolidated market
52 15
U.S.C. 78f(b)(5).
U.S.C. 78f(b)(8).
54 In approving this proposed rule change, as
modified by Amendment No. 1, the Commission
has considered the proposed rule’s impact on
efficiency, competition, and capital formation. See
15 U.S.C. 78c(f). See discussion below in this
Section IV stating the reasons why the Commission
believes that the Amended Proposal, to provide colocation Users access to the new NMS Network
without associated fee changes, does not impose a
burden on competition that is not necessary or
appropriate in furtherance of the Act.
53 15
E:\FR\FM\13MYN1.SGM
13MYN1
Federal Register / Vol. 85, No. 93 / Wednesday, May 13, 2020 / Notices
data more efficiently through the NMS
Network, a new dedicated low-latency
connectivity service, at no additional
charge. The Commission believes that
providing market participants the ability
to obtain consolidated market data in a
more timely manner in these
circumstances would enhance the
utility of this critical component of the
national market system for the benefit of
market participants and investors that
rely upon access to consolidated market
data to effectuate trades and otherwise
have confidence in the efficiency and
integrity of that system. Thus, the
Commission finds the proposal would
protect investors and the public interest
and otherwise is consistent with Section
6(b)(5) of the Act.55
With regard to competition, Nasdaq
takes the position that the Amended
Proposal inappropriately burdens
competition because the Exchanges
would bundle fees for connectivity to
the NMS Feeds with fees for
connectivity to the Exchanges’
proprietary products for co-location
Users. In Nasdaq’s view, this pricing
structure for co-location services
hinders potential competitors from
replacing SIAC as processor for the
NMS Feeds, and inappropriately
burdens market participants that may
seek connectivity only to the NMS
Feeds or to the Exchanges’ proprietary
products, or to some subset thereof, in
the Exchanges’ co-location facilities.
Nasdaq also states that there are
alternative ways the Exchanges could
structure the proposal such that
connectivity to the NMS Feeds could be
priced separately from exchange
connectivity, and offered examples of
how this could be accomplished
without an increase in NYSE’s fees.56
As an initial matter, the Commission
notes that the proposed rule change
under consideration would not modify
the existing fees of the Exchanges;
instead the Exchanges are proposing to
offer co-location Users an enhanced
connectivity option for consolidated
market data through the NMS Feeds at
no additional charge. Nonetheless, with
respect to Nasdaq’s position that the
Exchanges’ existing pricing structure
jbell on DSKJLSW7X2PROD with NOTICES
55 The
Commission also believes that the
proposed enhancements to the provision of
consolidated market data are consistent with past
Commission statements that the widespread
availability of timely market information promotes
fair and efficient markets. See, e.g., Securities
Exchange Act Release No. 42208 (Dec. 9, 1999), 64
FR 70613, 70614 (Dec. 17, 1999) (Market
Information Concept Release); Concept Release on
Equity Market Structure, Securities Exchange Act
Release No. 61358 (Jan. 14, 2010), 75 FR 3593, 3600
(Jan. 21, 2010) (Equity Market Structure Concept
Release).
56 See note 36 supra.
VerDate Sep<11>2014
19:53 May 12, 2020
Jkt 250001
hinders potential competitors from
replacing SIAC as processor for the
NMS Feeds, and is therefore a burden
on intermarket competition, the
Commission does not believe in these
circumstances that potential
competitors who are also exchanges,
such as Nasdaq, are inappropriately
constrained from offering connectivity
to the NMS Feeds to co-location Users
at prices competitive with the
Exchanges. As noted above, Nasdaq, like
the Exchanges, provides connectivity to
a consolidated market data feed (the
‘‘UTP SIP Feed’’),57 as well as its own
proprietary products, at its co-location
facility. Whether connectivity services
at co-location facilities are offered for
multiple products or a single product,
co-location customers generally are
charged for connectivity by the
Exchanges and Nasdaq based on the
number of connections received and the
bandwidth thereof.58 Thus, the
Commission believes that Nasdaq could
propose a comparable pricing structure
that would allow it to compete with the
Exchanges.59 For the same reasons, the
Commission is also not persuaded that
the Exchanges choosing not to propose
the alternative pricing approaches
suggested by Nasdaq renders the
proposed rule change an inappropriate
or unnecessary burden on intermarket
competition and thus inconsistent with
the Act. Further, the Commission does
not believe that Nasdaq’s argument is
persuasive with respect to an entity that
may not be an exchange but that wishes
to compete for the exclusive SIP
contracts currently held by SIAC. While
it is possible that the changes proposed
by the Exchanges could place greater
pressure on these would-be competitors,
it does not appear that any such
pressure would force users to pay higher
prices than they currently do or that
there would be a loss of desirable
alternative bidders for the exclusive SIP
contract. In sum, the Commission does
not believe that any such competitive
pressure creates an inappropriate or
57 The UTP SIP Feed is comprised of a UTP Quote
Data Feed (‘‘UQDF’’) and a UTP Trade Data Feed
(‘‘UTDF’’). The UQDF provides continuous
quotations from all market centers trading Nasdaqlisted securities. The UTDF provides continuous
last sale information from all market centers trading
Nasdaq-listed securities. See https://
www.utpplan.com/.
58 See e.g., NYSE Price List and Nasdaq Price
Lists, available, respectively, at: https://
www.nyse.com/publicdocs/nyse/markets/nyse/
NYSE_Price_List.pdf; and https://
listingcenter.nasdaq.com/rulebook/nasdaq/rules/
nasdaq-general-8.
59 Nasdaq today offers its co-location customers
two free connections to the UTP SIP Feed and
additional connections for a nominal fee. See
https://listingcenter.nasdaq.com/rulebook/nasdaq/
rules/nasdaq-general-8.
PO 00000
Frm 00077
Fmt 4703
Sfmt 4703
28675
unnecessary burden on the competitive
landscape in the context of this
proposal.
The Commission also does not believe
that the Exchanges’ existing pricing
structure inappropriately burdens either
those market participants that may seek
connectivity only to a subset of market
data products, or those that would
otherwise be forced into using the NMS
Network connectivity to access OPRA.
This is because co-location Users that
desire a small number of market data
products are likely to require fewer
connections or less bandwidth, and
therefore pay lower connectivity fees,
whereas those that require more
connections or more bandwidth are
likely to pay comparatively higher
connectivity fees, and the Exchanges are
not proposing to charge an additional
fee for access to the new NMS Network.
For all of the foregoing reasons, the
Commission finds that the Amended
Proposal, to provide co-location Users
access to the new NMS Network
without associated fee changes, is
consistent with Section 6(b)(8) of the
Act, which prohibits any exchange rule
from imposing any burden on
competition that is not necessary or
appropriate in furtherance of the Act.
V. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,60 that the
proposed rule change (SR–NYSE–2019–
46, SR–NYSENAT–2019–19, SR–
NYSEArca–2019–61, SR–NYSEAMER–
2019–34), as modified by Amendment
No. 1, be, and hereby is approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.61
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–10223 Filed 5–12–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[SEC File No. 270–40, OMB Control No.
3235–0313]
Proposed Collection; Comment
Request
Upon Written Request, Copies Available
From: Securities and Exchange
Commission, Office of FOIA Services,
100 F Street NE, Washington, DC
20549–2736
Extension:
Rule 203–2 and Form ADV–W
60 See
61 17
E:\FR\FM\13MYN1.SGM
id.
CFR 200.30–3(a)(12).
13MYN1
Agencies
[Federal Register Volume 85, Number 93 (Wednesday, May 13, 2020)]
[Notices]
[Pages 28671-28675]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-10223]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-88837; File Nos. SR-NYSE-2019-46, SR-NYSENAT-2019-19,
SR-NYSEArca-2019-61, SR-NYSEAMER-2019-34]
Self-Regulatory Organizations; New York Stock Exchange LLC; NYSE
National, Inc.; NYSE Arca, Inc.; NYSE American LLC; Order Granting
Approval of a Proposed Rule Change, as Modified by Amendment No. 1, To
Amend the Exchanges' Co-Location Services To Offer Co-Location Users
Access to the NMS Network
May 7, 2020.
I. Introduction
On August 22, 2019, New York Stock Exchange LLC, NYSE National,
Inc., and NYSE Arca, Inc. each 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: (i) Amend their co-location
services to offer co-location Users access to the ``NMS Network''--a
new alternate, dedicated network providing connectivity to data feeds
for the National Market System Plans for which Securities Industry
Automation Corporation (``SIAC'') is engaged as the exclusive
securities information processor (``SIP''); and (ii) establish
associated fees. NYSE American LLC filed with the Commission a
substantively identical filing on August 23, 2019.\3\ The proposed rule
changes were published for comment in the Federal Register on September
10,
[[Page 28672]]
2019.\4\ On October 24, 2019, the Commission extended the time period
within which to approve, disapprove, or institute proceedings to
determine whether to approve or disapprove the Original Proposal, to
December 9, 2019.\5\ The Commission received one comment letter on the
Original Proposal, a response from the Exchanges, and a second letter
from the original commenter.\6\ On December 9, 2019, the Commission
instituted proceedings to determine whether to approve or disapprove
the Original Proposal.\7\ On December 23, 2019, the Exchange filed
Amendment No. 1 to the Original Proposal. Amendment No. 1, which
superseded and replaced the Original Proposal in its entirety, was
published for comment in the Federal Register on January 15, 2020.\8\
The Commission received one comment letter on the Amended Proposal and
a response from the Exchanges.\9\ The Commission is approving the
proposed rule change, as modified by Amendment No. 1.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ The New York Stock Exchange LLC, NYSE National, Inc., NYSE
Arca, Inc., and NYSE American, LLC are collectively referred to
herein as ``NYSE'' or the ``Exchanges.''
\4\ See Securities Exchange Act Release Nos. 86865 (September 4,
2019), 84 FR 47592 (SR-NYSE-2019-46); 86869 (September 4, 2019), 84
FR 47600 (SR-NYSENAT-2019-19); 86868 (September 4, 2019), 84 FR
47610 (SR-NYSEArca-2019-61); 86867 (September 4, 2019), 84 FR 47563
(SR-NYSEAMER-2019-34) (collectively the ``Original Notice'' or
``Original Proposal''). Page citations to the Original Notice refer
to the Notice for SR-NYSE-2019-46 as published in the Federal
Register.
\5\ See Securities Exchange Act Release Nos. 87399, 84 FR 58189
(October 30, 2019) (SR-NYSE-2019-46); 87402, 84 FR 58187 (October
30, 2019) (SR-NYSENAT-2019-19); 87400, 84 FR 58189 (October 30,
2019) (SR-NYSEArca-2019-61); 87401, 84 FR 58188 (October 30, 2019)
(SR-NYSEAMER-2019-34).
\6\ See, respectively, letter dated October 24, 2019 from John
M. Yetter, Vice President and Senior Deputy General Counsel, Nasdaq
Stock Market LLC (``Nasdaq''), to Vanessa Countryman, Secretary,
Commission (``Nasdaq Letter''); letter dated November 8, 2019 from
Elizabeth K. King, Chief Regulatory Officer, ICE, General Counsel
and Corporate Secretary, NYSE to Ms. Vanessa Countryman, Secretary,
Commission (``NYSE Response Letter''); and letter dated November 25,
2019 from Joan C. Conley, Senior Vice President and Corporate
Secretary, Nasdaq, to Vanessa Countryman, Secretary, Commission
(``Second Nasdaq Letter''). All comments received by the Commission
on the proposed rule change are available on the Commission's
website at: https://www.sec.gov/comments/sr-nyse-2019-46/srnyse201946.htm. NYSE filed a comment letter on behalf of all of
the Exchanges.
\7\ See Securities Exchange Act Release No. 87699 (December 9,
2019), 84 FR 68239 (December 13, 2019) (SR-NYSE-2019-46; SR-NYSENAT-
2019-19; SR-NYSEArca-2019-61; SR-NYSEAMER-2019-34) (``Order
Instituting Proceedings'' or ``OIP'').
\8\ See Securities Exchange Act Releases No. 87927 (January 9,
2020), 85 FR 2468 (SR-NYSE-2019-46); 87930 (January 9, 2020), 85 FR
2459 (SR-NYSENAT-2019-19); 87929 (January 9, 2020), 85 FR 2453 (SR-
NYSEAMER-2019-34); and 87928 (January 9, 2020), 85 FR 2447 (SR-NYSE-
2019-61) (collectively, ``Amendment No. 1'' or the ``Amended
Proposal''). The Amended Proposal also is available at https://www.sec.gov/comments/sr-nyse-2019-46/srnyse201946-6584636-201247.pdf. Page citations to the Amended Proposal refer to
Amendment No. 1 for SR-NYSE-2019-46 as published in the Federal
Register.
\9\ See, respectively, letter dated February 5, 2020 from Joan
C. Conley, Senior Vice President and Corporate Secretary, Nasdaq, to
Vanessa Countryman, Secretary, Commission (``Nasdaq Letter III'')
and letter dated February 25, 2020 from Elizabeth K. King, Chief
Regulatory Officer, ICE, General Counsel and Corporate Secretary,
NYSE to Ms. Vanessa Countryman, Secretary, Commission (``NYSE
Response Letter II''). All comments received by the Commission on
the proposed rule change are available on the Commission's website
at: https://www.sec.gov/comments/sr-nyse-2019-46/srnyse201946.htm.
NYSE filed a comment letter on behalf of all of the Exchanges.
---------------------------------------------------------------------------
II. Description of the Proposed Rule Change, as Modified by Amendment
No. 1
A. Background
The Exchanges' affiliate, SIAC, is currently engaged as the
exclusive SIP for three National Market System Plans: (1) The
Consolidated Trade Association (``CTA'') Plan; (2) the Consolidated
Quotation (``CQ'') Plan; and (3) the Options Price Reporting Authority
(``OPRA'') Plan.\10\ SIAC operates in the same data center (``Data
Center'') in Mahwah, New Jersey from which the Exchanges operate and
offer co-location services to co-location ``Users.'' \11\ A co-location
``User'' is any market participant that requests to receive co-location
services directly from the Exchange for fees set forth on price lists
filed with the Commission.\12\
---------------------------------------------------------------------------
\10\ See Amended Proposal, supra note 8, at n. 16.
\11\ See Amended Proposal, supra note 8, 85 FR at 2469.
\12\ See Amended Proposal, supra note 8, at n. 10. As stated in
the price list of each of the Exchanges, a User that incurs co-
location fees for a particular co-location service is not subject to
co-location fees for the same co-location service charged by another
of the Exchanges. See id.
---------------------------------------------------------------------------
Currently, Users can connect to the CTA Plan, CQ Plan, and OPRA
Plan data feeds (the ``NMS Feeds'') disseminated by the SIP using
either of the co-location local area networks in the Data Center, which
include the Liquidity Center Network (``LCN'') and IP network.\13\
Currently, a User would need to purchase a service that includes either
a 10 Gb or 40 Gb connection to access the LCN and/or IP network and
connect to the NMS feeds.\14\ Users do not pay an additional or
separate charge to connect to the NMS Feeds via the LCN or IP network,
but rather pay for the bandwidth they determine will meet their needs
in co-location.\15\
---------------------------------------------------------------------------
\13\ See id, 85 FR at 2469.
\14\ Id.
\15\ Currently, a User that purchases access to the LCN or IP
network also receives the ability to access the trading and
execution systems of the Exchanges, and the trading and execution
systems of OTC Global, an alternative trading system (``ATS''),
subject, in each case, to authorization by the relevant entity; as
well as connectivity to market data products that a User selects
from a list of Included Data Products, subject to technical
provisioning requirements and authorization from the provider of the
data feed. The Included Data Products are the NMS Feeds and the
proprietary feeds of the Exchanges and its affiliate, NYSE Chicago.
Id.
---------------------------------------------------------------------------
B. Original Proposal and Order Instituting Proceedings
As more fully set forth in the Original Notice, the Exchanges
initially proposed to offer access to the new NMS Network and establish
associated fees. The NMS Network would be an alternate, dedicated
network from which co-location Users could access and connect to the
NMS Feeds. The NMS Network would have an anticipated benefit of a one-
way reduction in latency, as compared to the IP network and/or LCN, of
over 140 microseconds. The Exchanges explained that SIAC continually
assesses the services it provides and had been working with the
operating committees of the NMS Plans and the industry-based advisory
committee to the CTA/CQ Plans to identify potential performance
enhancements for the SIP, including one that would address concerns
that access to the NMS Feeds (required to traverse over the IP
network), were subject to an additional layer of latency because the IP
network was not designed as a low-latency network.\16\
---------------------------------------------------------------------------
\16\ See Original Notice, supra note 4, 84 FR at 47594.
---------------------------------------------------------------------------
Under the Original Proposal, a User would have been permitted to
connect to the NMS Feeds via the newly established NMS Network at no
additional charge subject to certain conditions. Specifically, if a
User purchased 10Gb or 40Gb access to the LCN or IP network and
requested a connection to the NMS Network, that User and its
Affiliates,\17\ taken together, would not have been charged for up to
eight corresponding NMS Network connections (each a ``No Additional Fee
NMS Network Connection''), if:
---------------------------------------------------------------------------
\17\ See Original Notice, supra note 4, at n. 17, noting that
``Affiliate'' of a User is defined in the price list as ``any other
User or Hosted Customer that is under 50% or greater common
ownership or control of the first User;'' that a ``Hosted Customer''
is a customer of a Hosting User that is hosted in a Hosting User's
co-location space; and a ``Hosting User'' is a User of colocation
services that hosts a Hosted Customer in the User's co-location
space. Hosting Users are subject to Hosting fees.
---------------------------------------------------------------------------
(i) Such User, together with its Affiliates, designated no more
than four No Additional Fee NMS Network Connections as corresponding to
the LCN connections of the User, together with its Affiliates, on a
one-to-one basis;
(ii) such User, together with its Affiliates, designated no more
than four
[[Page 28673]]
No Additional Fee NMS Network Connections as corresponding to the IP
network connections of the User, together with its Affiliates, on a
one-to-one basis;
(iii) such User, together with its Affiliates, did not use the LCN
or IP network connections that correspond to the No Additional Fee NMS
Network Connections to access the NMS Feeds; \18\ and
---------------------------------------------------------------------------
\18\ Users would still have had the option to connect to the NMS
Feeds using their LCN or IP network connections, but would have been
charged the proposed fee for the NMS Network connection.
---------------------------------------------------------------------------
(iv) each of the No Additional Fee NMS Network Connections was of
equal size or smaller than the associated LCN or IP network connection
purchased by it or its Affiliates.\19\
---------------------------------------------------------------------------
\19\ See Original Notice, supra note 4, 84 FR at 47594.
Accordingly, a User's access to a 1 Gb connection would not entitle
a User to a No Additional Fee NMS Network Connection.
---------------------------------------------------------------------------
In contrast, a User that did not satisfy these conditions would
have been subject to an additional or separate charge to access the NMS
Network.\20\ Those seeking an NMS Network connection that did not
qualify as a No Additional Fee NMS Network Connection would have been
assessed: (i) $10,000 per connection initial charge and $11,000/month
for a 10 Gb connection; or (ii) $10,000 per connection initial charge
and $18,000/month for a 40 Gb connection (the same fee assessed for the
same-sized 10 Gb or 40 Gb IP network connection).\21\
---------------------------------------------------------------------------
\20\ See id. at 47595. According to the Exchanges, Users would
typically be charged separately for access to the NMS Network in
circumstances where they (i) would like to purchase access to the
NMS Network and have not purchased a 10 Gb or 40 Gb LCN or IP
network connection; (ii) have purchased an LCN or IP connection but
would like NMS Network connections in excess of permitted number of
corresponding No Additional Fee NMS Network Connections; and/or
(iii) would like to use their LCN and IP connections to continue to
access the NMS Feeds.
\21\ See id.
---------------------------------------------------------------------------
The Commission received one comment letter on the Original Proposal
from Nasdaq, a response from the Exchanges, and a second letter from
Nasdaq.\22\ In its initial comment letter, Nasdaq observed that the
Exchanges' proposal would permit market participants who separately pay
the Exchanges to connect to their trading venue(s) to receive up to
eight free connections to the faster NMS Network; whereas market
participants who elect a stand-alone connection to the NMS Feeds would
be charged.\23\ Nasdaq expressed concern that the ``commingling,'' or
bundling, of pricing for NMS Network connectivity with connectivity to
the NYSE venues, including access to NYSE proprietary data feeds, would
create a burden on intermarket competition and hinder potential
providers from competing to serve as network processor in place of
SIAC.\24\ In Nasdaq's view, ``[a]ny change to the current processor
would increase costs to market participants that would purchase a
subset of NMS Network Connections from the new provider and continue to
pay the bundled price to NYSE to connect and transact business on
NYSE.'' \25\ Nasdaq also believed that NYSE's failure to offer market
participants the opportunity to acquire NMS Network connections
individually hindered competition.\26\ Finally, Nasdaq took the
position that the Exchanges' proposal would burden intermarket
competition because other exchanges would be unable to couple their
pricing for connectivity to their trading venues with NMS Network
connections.\27\
---------------------------------------------------------------------------
\22\ See Nasdaq Letter, NYSE Response Letter, and Second Nasdaq
Letter, supra note 6.
\23\ See Nasdaq Letter at 1.
\24\ Id. at 1-2.
\25\ Id. at 2.
\26\ Id.
\27\ Id.
---------------------------------------------------------------------------
The Exchanges responded by noting that Section 6(b)(8) of the Act
requires that the rules of an exchange not impose any burden on
competition that is not necessary or appropriate in furtherance of the
Exchange Act.\28\ With respect to Nasdaq's first argument, the
Exchanges took the position that the bidding process to be the
exclusive SIP for an NMS Plan is a commercial competition that is not
intermarket competition as contemplated by the Exchange Act, and that
how (and how much) a bidder chose to charge for connectivity to its SIP
would be part of its bid.\29\ The Exchanges characterized Nasdaq's
second argument as ``baseless'' because market participants would in
fact be able to purchase a stand-alone NMS Network connection.\30\ The
Exchanges expressed the view that Nasdaq's final argument was unfounded
because there inherently is no competition to provide connectivity to
an exclusive SIP.\31\ The Exchanges further stated that while the NMS
Network would be offered at no additional cost to current Users, the
only way to address Nasdaq's concerns would be to increase fees
currently charged to Users to connect to the Exchanges.\32\ In this
regard, the Exchanges observed that Nasdaq's approach to managing its
own fees for connectivity to the UTP SIP Feed (defined below) is
similar to the approach proposed by the Exchanges in that both parties
seek to leverage their existing exchange connectivity fees to keep
costs down for providing connectivity to the relevant SIPs.\33\
---------------------------------------------------------------------------
\28\ See NYSE Response Letter, supra note 6, at 3. They added
that NYSE sought and received approval from both the CTA Operating
Committee and OPRA Management Committee (both of which include
Nasdaq as a member) on the Original Proposal. Id.
\29\ Id. at 4.
\30\ Id. at 5.
\31\ Id.
\32\ Id. at 5-7.
\33\ Id. In making this statement, the Exchanges also
acknowledge that the specific way in which Nasdaq seeks to effect
this outcome is different from what the Exchanges propose (i.e.,
Nasdaq offers UTP NMS Plan customers two free connections and
additional connections for $100 per month).
---------------------------------------------------------------------------
In a second comment letter, Nasdaq stated its general support for
the proposed NMS Network, but reiterated its view that the Exchanges'
proposed fee structure would hamper competitors from bidding to replace
SIAC as the SIP.\34\ According to Nasdaq, if another exchange or third
party became the SIP for one of the three NMS Feeds, market
participants would need to separately connect to two separate
environments to obtain all three NMS Feeds, at increased costs.\35\
Nasdaq urged that NMS Network connectivity should be priced separately
from exchange connectivity, and offered examples of how this could be
accomplished without an increase in NYSE's fees.\36\
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\34\ See Second Nasdaq Letter, supra note 6, at 1-2.
\35\ Id. at 2.
\36\ More specifically, Nasdaq suggested that the Exchanges
could: (i) Separately price NMS Network connectivity and NYSE
connectivity; (ii) price each NMS Feed connection separately; or
(iii) separate OPRA NMS Feed connectivity from CTA and CQ NMS Feed
connectivity. See id. at 3.
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The Commission issued an Order Instituting Proceedings, requesting
comment on the NMS Network fee structure set forth in the Original
Proposal.\37\ The Commission highlighted that the Exchanges proposed to
make the NMS Network available at no additional charge to Users that
satisfied certain conditions (as described above) and to impose a
substantial charge on Users seeking access to the NMS Network that did
not satisfy the proposed conditions.\38\ In particular, the Commission
questioned the basis for the level of the proposed fee for a charged
NMS connection ($10,000 initially and $11,000 or $18,000 monthly for a
10 Gb or 40 Gb connection, respectively), as well as whether it was
reasonable, equitable, and not unfairly discriminatory for only certain
Users to receive NMS Network Connections at no additional charge.\39\
The Commission also solicited comment on whether the revised fee
structure for the NMS Network set forth in the Original Proposal would
impose an
[[Page 28674]]
undue burden on competition that is not necessary or appropriate under
the Act.\40\
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\37\ See OIP, supra note 7.
\38\ Id.
\39\ Id.
\40\ Id.
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C. Amendment No. 1
Following the OIP, the Exchanges filed Amendment No. 1. As more
fully set forth in Amendment No. 1, the Exchanges propose to eliminate
the fee changes associated with the proposed new NMS Network
service.\41\ In lieu of establishing conditions for No Additional Fee
NMS Network Connections and proposing separate charged NMS Network
connections, the Exchanges instead propose to offer co-location Users
access to the NMS Network as a new service with no associated fee
changes. To effect this change, the Exchanges propose to amend the
services available to co-location Users to provide that if a User
purchases a service that includes a 10 Gb or 40 Gb IP or LCN network
connection, that purchase would include an NMS Network connection of
the same size.\42\ For co-location Users, the option of receiving
connectivity to the NMS Feeds in co-location would therefore continue
to be included when a User purchases a 10 Gb or 40 Gb network IP or LCN
circuit.\43\ Access to the NMS Network would thus be offered as a
service upgrade, designed to provide co-location Users a one-way
reduction in latency for the NMS Feeds of over 140 microseconds, as
compared to the IP network and LCN, at no additional cost.\44\
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\41\ See Amended Proposal, supra note 8.
\42\ See Amended Proposal, supra note 8, 85 FR at 2470.
\43\ Id. More specifically, the Exchanges propose to amend the
sections of the price lists that set forth the services offering the
10 Gb and 40 Gb LCN connection and the 10 Gb and 40 Gb IP connection
and their prices to include an NMS Network connection as part of
each service and to include a note for each service stating that the
connection offered as part of the service and the NMS Network
connection are together considered to be one connection, so Users
are not subject to two initial or two monthly charges. Id.
\44\ Id.
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III. Summary of Comments on Amendment No. 1 and Exchanges' Response
Nasdaq submitted a comment letter on Amendment No. 1, objecting
that the Amended Proposal continues to integrate access to the
Exchanges' proprietary products with access to the NMS Feeds in an
improper manner that would impose a burden on competition that is
neither necessary nor appropriate under the Act.\45\ According to
Nasdaq, market participants currently paying for connectivity to NYSE
proprietary data feeds can receive NMS Network connectivity at no
additional cost, but are forced to pay for this connectivity within the
bundled price, and new market participants that only want to receive
NMS Feeds are effectively forced to pay the bundled fees.\46\ In
addition, Nasdaq took the position that, because the OPRA feed is so
large, the bundling with OPRA has the effect of steering all market
participants to consume larger bandwidths at higher cost.\47\
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\45\ See Nasdaq Letter III, supra note 9, at 1.
\46\ Id. at 2. The Exchanges responded that all direct
recipients of the NMS Feeds in co-location also connect to one or
more of the Exchanges for trading purposes. See NYSE Response Letter
II, supra note 9, at 3.
\47\ Id. at 3.
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In response, the Exchanges state that they do not propose to change
any fee or the availability of any current connectivity option; rather
they propose only to add NMS Network connectivity as a service provided
to co-location Users.\48\ They further state that Nasdaq focuses on
whether existing fees for connectivity to the NMS Feeds are a burden on
competition, but note that that issue is not before the Commission.\49\
Instead, in the Exchanges' view, their proposal would simply add a new
service and provide more choice to Users, allowing them to opt to use
the low-latency NMS Network to connect to NMS feeds.\50\ In addition,
the Exchanges take the position that Nasdaq's claim that such Users are
forced to purchase larger bandwidth has no basis, as there are multiple
reasons why a User would purchase a larger connection, and the
additional capacity provided by the NMS Network should reduce demand
for those larger connections.\51\
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\48\ See NYSE Response Letter II, supra note 9, at 2.
\49\ Id. at 2-3. The Exchanges further note that Nasdaq's
objections to the Exchanges bundled fee structure would not be
resolved by approval or disapproval of the Amended Proposal.
\50\ Id. at 3.
\51\ Id. at 3. Specifically, the Exchanges state that the
additional capacity provided by the NMS Network will reduce demand
for 40 Gb connections and permit some Users to instead consume NYSE
Exchanges' data over a 10 Gb local area network connection and NMS
Feeds over the complementary 10 Gb NMS Network connection. Id. at n.
5.
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IV. Discussion and Commission Findings
The Commission finds that the proposed rule change, as modified by
Amendment No. 1, is consistent with the requirements of the Act and the
rules and regulations thereunder applicable to a national securities
exchange. In particular, the Commission finds that the proposed rule
change, as modified by Amendment No. 1, is consistent with Section
6(b)(5) of the Act,\52\ which requires that the rules of an exchange be
designed, among other things, to prevent fraudulent and manipulative
acts and practices, to promote just and equitable principles of trade,
to remove impediments to and perfect the mechanism of a free and open
market and a national market system and, in general, to protect
investors and the public interest, and not be designed to permit unfair
discrimination between customers, issuers, brokers or dealers; and
Section 6(b)(8) of the Act,\53\ which prohibits any exchange rule from
imposing any burden on competition that is not necessary or appropriate
in furtherance of the Act.\54\
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\52\ 15 U.S.C. 78f(b)(5).
\53\ 15 U.S.C. 78f(b)(8).
\54\ In approving this proposed rule change, as modified by
Amendment No. 1, the Commission has considered the proposed rule's
impact on efficiency, competition, and capital formation. See 15
U.S.C. 78c(f). See discussion below in this Section IV stating the
reasons why the Commission believes that the Amended Proposal, to
provide co-location Users access to the new NMS Network without
associated fee changes, does not impose a burden on competition that
is not necessary or appropriate in furtherance of the Act.
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In the Amended Proposal, the Exchanges propose to augment how co-
location Users may connect to the NMS Feeds in the Data Center by
offering them access to the ``NMS Network,'' an upgraded alternative
local area network, and to do so without the associated fee changes
that were part of the Original Proposal. As discussed above, Nasdaq
takes the position that, because the Exchanges' proposal does not
separate pricing for connectivity to the NMS Feeds from pricing for
connectivity to the Exchanges' proprietary products, the proposal
imposes an unnecessary or inappropriate burden on competition that is
inconsistent with the Act. The Exchanges respond that they simply
propose to offer a new connectivity option for co-location Users
without any fee change and that, regardless, Nasdaq's arguments that
the existing fee structure burdens competition in a manner inconsistent
with the Act are without merit.
The Commission believes that the Amended Proposal is responsive to
the issues identified in the Order Instituting Proceedings, and that
the Amended Proposal is consistent with the Act. Under the Amended
Proposal, the Exchanges remove the proposed limits on No Additional Fee
NMS Network Connections. Accordingly, under the Amended Proposal, the
Exchanges would provide co-location Users the option to access
consolidated market
[[Page 28675]]
data more efficiently through the NMS Network, a new dedicated low-
latency connectivity service, at no additional charge. The Commission
believes that providing market participants the ability to obtain
consolidated market data in a more timely manner in these circumstances
would enhance the utility of this critical component of the national
market system for the benefit of market participants and investors that
rely upon access to consolidated market data to effectuate trades and
otherwise have confidence in the efficiency and integrity of that
system. Thus, the Commission finds the proposal would protect investors
and the public interest and otherwise is consistent with Section
6(b)(5) of the Act.\55\
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\55\ The Commission also believes that the proposed enhancements
to the provision of consolidated market data are consistent with
past Commission statements that the widespread availability of
timely market information promotes fair and efficient markets. See,
e.g., Securities Exchange Act Release No. 42208 (Dec. 9, 1999), 64
FR 70613, 70614 (Dec. 17, 1999) (Market Information Concept
Release); Concept Release on Equity Market Structure, Securities
Exchange Act Release No. 61358 (Jan. 14, 2010), 75 FR 3593, 3600
(Jan. 21, 2010) (Equity Market Structure Concept Release).
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With regard to competition, Nasdaq takes the position that the
Amended Proposal inappropriately burdens competition because the
Exchanges would bundle fees for connectivity to the NMS Feeds with fees
for connectivity to the Exchanges' proprietary products for co-location
Users. In Nasdaq's view, this pricing structure for co-location
services hinders potential competitors from replacing SIAC as processor
for the NMS Feeds, and inappropriately burdens market participants that
may seek connectivity only to the NMS Feeds or to the Exchanges'
proprietary products, or to some subset thereof, in the Exchanges' co-
location facilities. Nasdaq also states that there are alternative ways
the Exchanges could structure the proposal such that connectivity to
the NMS Feeds could be priced separately from exchange connectivity,
and offered examples of how this could be accomplished without an
increase in NYSE's fees.\56\
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\56\ See note 36 supra.
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As an initial matter, the Commission notes that the proposed rule
change under consideration would not modify the existing fees of the
Exchanges; instead the Exchanges are proposing to offer co-location
Users an enhanced connectivity option for consolidated market data
through the NMS Feeds at no additional charge. Nonetheless, with
respect to Nasdaq's position that the Exchanges' existing pricing
structure hinders potential competitors from replacing SIAC as
processor for the NMS Feeds, and is therefore a burden on intermarket
competition, the Commission does not believe in these circumstances
that potential competitors who are also exchanges, such as Nasdaq, are
inappropriately constrained from offering connectivity to the NMS Feeds
to co-location Users at prices competitive with the Exchanges. As noted
above, Nasdaq, like the Exchanges, provides connectivity to a
consolidated market data feed (the ``UTP SIP Feed''),\57\ as well as
its own proprietary products, at its co-location facility. Whether
connectivity services at co-location facilities are offered for
multiple products or a single product, co-location customers generally
are charged for connectivity by the Exchanges and Nasdaq based on the
number of connections received and the bandwidth thereof.\58\ Thus, the
Commission believes that Nasdaq could propose a comparable pricing
structure that would allow it to compete with the Exchanges.\59\ For
the same reasons, the Commission is also not persuaded that the
Exchanges choosing not to propose the alternative pricing approaches
suggested by Nasdaq renders the proposed rule change an inappropriate
or unnecessary burden on intermarket competition and thus inconsistent
with the Act. Further, the Commission does not believe that Nasdaq's
argument is persuasive with respect to an entity that may not be an
exchange but that wishes to compete for the exclusive SIP contracts
currently held by SIAC. While it is possible that the changes proposed
by the Exchanges could place greater pressure on these would-be
competitors, it does not appear that any such pressure would force
users to pay higher prices than they currently do or that there would
be a loss of desirable alternative bidders for the exclusive SIP
contract. In sum, the Commission does not believe that any such
competitive pressure creates an inappropriate or unnecessary burden on
the competitive landscape in the context of this proposal.
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\57\ The UTP SIP Feed is comprised of a UTP Quote Data Feed
(``UQDF'') and a UTP Trade Data Feed (``UTDF''). The UQDF provides
continuous quotations from all market centers trading Nasdaq-listed
securities. The UTDF provides continuous last sale information from
all market centers trading Nasdaq-listed securities. See https://www.utpplan.com/.
\58\ See e.g., NYSE Price List and Nasdaq Price Lists,
available, respectively, at: https://www.nyse.com/publicdocs/nyse/markets/nyse/NYSE_Price_List.pdf; and https://listingcenter.nasdaq.com/rulebook/nasdaq/rules/nasdaq-general-8.
\59\ Nasdaq today offers its co-location customers two free
connections to the UTP SIP Feed and additional connections for a
nominal fee. See https://listingcenter.nasdaq.com/rulebook/nasdaq/rules/nasdaq-general-8.
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The Commission also does not believe that the Exchanges' existing
pricing structure inappropriately burdens either those market
participants that may seek connectivity only to a subset of market data
products, or those that would otherwise be forced into using the NMS
Network connectivity to access OPRA. This is because co-location Users
that desire a small number of market data products are likely to
require fewer connections or less bandwidth, and therefore pay lower
connectivity fees, whereas those that require more connections or more
bandwidth are likely to pay comparatively higher connectivity fees, and
the Exchanges are not proposing to charge an additional fee for access
to the new NMS Network. For all of the foregoing reasons, the
Commission finds that the Amended Proposal, to provide co-location
Users access to the new NMS Network without associated fee changes, is
consistent with Section 6(b)(8) of the Act, which prohibits any
exchange rule from imposing any burden on competition that is not
necessary or appropriate in furtherance of the Act.
V. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\60\ that the proposed rule change (SR-NYSE-2019-46, SR-NYSENAT-
2019-19, SR-NYSEArca-2019-61, SR-NYSEAMER-2019-34), as modified by
Amendment No. 1, be, and hereby is approved.
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\60\ See id.
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\61\
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\61\ 17 CFR 200.30-3(a)(12).
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J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020-10223 Filed 5-12-20; 8:45 am]
BILLING CODE 8011-01-P