Order Granting a Temporary Conditional Exemption Pursuant to Section 36 of the Securities Exchange Act of 1934 (“Exchange Act”) and Rule 608(e) of Regulation NMS Under the Exchange Act, Relating to the Reporting of Certain Activities on the Floor of National Securities Exchanges and Certain Activities by Industry Members Off Exchange Floors, as Required by Section 6.4(d) of the National Market System Plan Governing the Consolidated Audit Trail, 73544-73548 [2020-25393]
Download as PDF
73544
Federal Register / Vol. 85, No. 223 / Wednesday, November 18, 2020 / Notices
implementation date. This schedule
appears reasonably designed to afford
members sufficient time to come into
compliance with the proposed rule
change while adhering to the conditions
set forth in the Facility Data Exemption
Order.
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,33 that the
proposed rule change (SR–FINRA–
2020–029) is approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.34
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–25381 Filed 11–17–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[SEC File No. 270–385, OMB Control No.
3235–0441]
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
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Extension:
Rule 18f–3
Notice is hereby given that, pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501 et seq.) (‘‘Paperwork
Reduction Act’’), the Securities and
Exchange Commission (the
‘‘Commission’’) is soliciting comments
on the collection of information
summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget (‘‘OMB’’) for
extension and approval.
Rule 18f–3 (17 CFR 270.18f–3) under
the Investment Company Act of 1940
(15 U.S.C. 80a–1 et seq.) exempts from
section 18(f)(1) a fund that issues
multiple classes of shares representing
interests in the same portfolio of
securities (a ‘‘multiple class fund’’) if
the fund satisfies the conditions of the
rule. In general, each class must differ
in its arrangement for shareholder
services or distribution or both, and
must pay the related expenses of that
different arrangement. The rule includes
one requirement for the collection of
information. A multiple class fund must
prepare, and fund directors must
33 15
34 17
1 3 hours per registrant per year × 1,045
registrants = 3,135 hours per year.
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
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17:59 Nov 17, 2020
approve, a written plan setting forth the
separate arrangement and expense
allocation of each class, and any related
conversion features or exchange
privileges (‘‘rule 18f–3 plan’’). Approval
of the plan must occur before the fund
issues any shares of multiple classes
and whenever the fund materially
amends the plan. In approving the plan,
the fund board, including a majority of
the independent directors, must
determine that the plan is in the best
interests of each class and the fund as
a whole.
The requirement that the fund prepare
and directors approve a written rule
18f–3 plan is intended to ensure that the
fund compiles information relevant to
the fairness of the separate arrangement
and expense allocation for each class,
and that directors review and approve
the information. Without a blueprint
that highlights material differences
among classes, directors might not
perceive potential conflicts of interests
when they determine whether the plan
is in the best interests of each class and
the fund. In addition, the plan may be
useful to Commission staff in reviewing
the fund’s compliance with the rule.
Based on an analysis of fund filings,
the Commission estimates that there are
approximately 7,293 multiple class
funds offered by 990 registrants. The
Commission estimates that each of the
990 registrants will make an average of
0.5 responses annually to prepare and
approve a written 18f–3 plan. The
Commission estimates each response
will take 6 hours, requiring a total of 3
hours per registrant per year. Thus the
total annual hour burden associated
with these requirements of the rule is
approximately 2,970 hours.1
Estimates of average burden hours are
made solely for the purposes of the
Paperwork Reduction Act and are not
derived from a comprehensive or even
a representative survey or study of the
costs of Commission rules and forms.
The collection of information under rule
18f–3 is mandatory. The information
provided under rule 18f–3 will not be
kept confidential. An agency may not
conduct or sponsor, and a person is not
required to respond to, a collection of
information unless it displays a
currently valid OMB control number.
Written comments are invited on: (a)
Whether the collections of information
are necessary for the proper
performance of the functions of the
Commission, including whether the
information has practical utility; (b) the
accuracy of the Commission’s estimate
of the burdens of the collections of
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information; (c) ways to enhance the
quality, utility, and clarity of the
information collected; and (d) ways to
minimize the burdens of the collections
of information on respondents,
including through the use of automated
collection techniques or other forms of
information technology. Consideration
will be given to comments and
suggestions submitted in writing within
60 days of this publication.
Please direct your written comments
to David Bottom, Director/Chief
Information Officer, Securities and
Exchange Commission, C/O Cynthia
Roscoe, 100 F Street NE, Washington,
DC 20549; or send an email to: PRA_
Mailbox@sec.gov.
Dated: November 12, 2020.
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–25352 Filed 11–17–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–90405]
Order Granting a Temporary
Conditional Exemption Pursuant to
Section 36 of the Securities Exchange
Act of 1934 (‘‘Exchange Act’’) and Rule
608(e) of Regulation NMS Under the
Exchange Act, Relating to the
Reporting of Certain Activities on the
Floor of National Securities Exchanges
and Certain Activities by Industry
Members Off Exchange Floors, as
Required by Section 6.4(d) of the
National Market System Plan
Governing the Consolidated Audit Trail
November 12, 2020.
I. Introduction
By letter dated July 1, 2020, BOX
Exchange LLC (‘‘BOX’’), Cboe BYX
Exchange, Inc., Cboe BZX Exchange,
Inc., Cboe EDGA Exchange, Inc., Cboe
EDGX Exchange, Inc., Cboe C2
Exchange, Inc., Cboe Exchange, Inc.
(‘‘CBOE’’), Financial Industry
Regulatory Authority, Inc. (‘‘FINRA’’),
Investors Exchange LLC, Miami
International Securities Exchange LLC,
MIAX Emerald, LLC, MIAX PEARL,
LLC, NASDAQ BX, LLC, Nasdaq GEMX,
LLC, Nasdaq ISE, LLC, Nasdaq MRX,
LLC, NASDAQ PHLX LLC (‘‘PHLX’’),
The NASDAQ Stock Market LLC, New
York Stock Exchange LLC (‘‘NYSE’’),
NYSE American LLC (‘‘NYSE
American’’), NYSE Arca, Inc. (‘‘NYSE
Arca’’), NYSE Chicago, Inc., NYSE
National, Inc., and Long Term Stock
Exchange, Inc. (collectively, the
‘‘Participants’’ or ‘‘SROs’’) requested
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that the Securities and Exchange
Commission (‘‘Commission’’ or ‘‘SEC’’)
grant temporary exemptive relief to the
Participants from the National Market
System Plan Governing the
Consolidated Audit Trail (‘‘CAT NMS
Plan’’),1 pursuant to its authority under
Section 36 of the Securities Exchange
Act of 1934 (‘‘Exchange Act’’) 2 and Rule
608(e) of Regulation NMS under the
Exchange Act, from certain reporting
requirements in Section 6.4(d) of the
CAT NMS Plan relating to certain
activities on the floors of national
securities exchanges and certain
activities by Industry Members off
exchange floors.3
Section 36 of the Exchange Act grants
the Commission the authority, with
certain limitations, to ‘‘conditionally or
unconditionally exempt any person,
security, or transaction . . . from any
provision or provisions of [the Exchange
Act] or of any rule or regulation
thereunder, to the extent that such
exemption is necessary or appropriate
in the public interest, and is consistent
with the protection of investors.’’ 4
Under Rule 608(e) of Regulation NMS,
the Commission may ‘‘exempt from
[Rule 608], either unconditionally or on
specified terms and conditions, any selfregulatory organization, member
thereof, or specified security, if the
Commission determines that such
exemption is consistent with the public
interest, the protection of investors, the
maintenance of fair and orderly markets
and the removal of impediments to, and
perfection of the mechanism of, a
national market system.’’ 5
For the reasons set forth below, this
Order grants the Participants’ request for
a temporary exemption from Section
6.4(d) of the CAT NMS Plan as set forth
in the July 1, 2020 Exemption Request,
expiring on July 31, 2023.
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II. Request for Relief
In the July 1, 2020 Exemption
Request, the Participants request that
the Commission exempt each
Participant from the requirement in
Section 6.4(d) of the CAT NMS Plan that
1 The CAT NMS Plan was approved by the
Commission, as modified, on November 15, 2016.
See Securities Exchange Act Release No. 79318
(November 15, 2016), 81 FR 84696 (November 23,
2016) (‘‘CAT NMS Plan Approval Order’’).
2 15 U.S.C. 78mm(a)(1).
3 See letter from the Participants to Vanessa
Countryman, Secretary, Commission, dated July 1,
2020 (the ‘‘July 1, 2020 Exemption Request’’).
Unless otherwise noted, capitalized terms are used
as defined in the CAT NMS Plan. MEMX LLC was
added as a Participant to the CAT NMS Plan on
June 5, 2020. See Securities Exchange Act Release
No. 89306 (July 13, 2020), 85 FR 43626 (July 17,
2020).
4 15 U.S.C. 78mm(a)(1).
5 17 CFR 242.608(e).
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17:59 Nov 17, 2020
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each Participant, through its
Compliance Rule, require its Industry
Members to record and electronically
report to the Central Repository: (1)
Floor broker verbal announcements of
firm bids and offers on an exchange
trading floor that are otherwise reported
as systematized orders; and (2) market
maker verbal announcements of firm
quotes on an exchange trading floor, to
the extent either are considered orders
reportable under Rule 613 of Regulation
NMS, the CAT NMS Plan and the
Compliance Rules, until July 31, 2023.
As a condition to this exemptive relief,
the Participants state that they would
continue to require that firm verbal
interest on an exchange floor (which
includes both floor broker verbal
announcements of firm bids and offers
and market maker verbal
announcements of firm quotes) be
expressed pursuant to exchange rules
approved by the Commission,6 and that
any such firm verbal interest expressed
by a floor broker must be related to a
CAT-reportable systematized order, and
any resulting trade must be reported to
CAT.
In addition, the Participants request
that the Commission exempt each
Participant from the requirement in
Section 6.4(d) of the CAT NMS Plan that
each Participant, through its
Compliance Rule, require its Industry
Members to record and electronically
report to the Central Repository the
following communications that occur
‘‘upstairs,’’ 7 to the extent such are
considered reportable under Rule 613 of
Regulation NMS, the CAT NMS Plan
and the Compliance Rules, until July 31,
2023: (1) Telephone discussions
between an Industry Member and a
client that may involve firm bid and
offer communications; and (2)
unstructured electronic and verbal
communications that are not currently
captured by Industry Member order
management or execution systems (e.g.,
Bloomberg chats, text messages).
73545
A. Exchange Floor Activity
The Participants state that on all
exchanges with floor trading,8 each
order must be systematized upon receipt
by the floor broker on the floor of the
exchange.9 The Participants further state
that an order is considered
systematized: (1) When it is sent
electronically to the floor broker’s
system at the exchange; or (2) when the
order is manually systematized by the
floor broker upon receipt outside of the
floor broker’s system and prior to
representation in the floor trading
crowd.10 To the extent a floor broker is
not holding a systematized order, the
floor broker is not eligible to represent
any firm bid or offer, or to request firm
quotes from in-crowd market
participants on the floor of an
exchange.11 The Participants state that
all firm bids or offers represented by a
floor broker must be associated with
orders that have already been
systematized, and that any activity by
the floor broker prior to systemization
cannot be related to an order, bid or
offer pursuant to the CAT NMS Plan.12
As a result of the systematization
requirements, all orders represented
verbally by a floor broker on an
exchange floor are required to be
captured in exchange systems and,
under CAT requirements, the floor
broker’s receipt of the order, and any
modification, electronic route,
cancellation, or execution of the order is
subject to CAT reporting.13 The
Participants believe that two verbal
events on exchange floors may be CATreportable: Floor broker announcements
of firm orders and market maker
announcements of firm quotes.
The Participants state that that
reporting of either of these two verbal
events were not contemplated when the
Commission and the Participants were
considering the cost and impact of the
CAT NMS Plan.14 The Participants
further state that requiring these
elements to be reported to CAT would
have a significant and costly impact to
exchange floors, to floor broker and
market maker business models, and to
market structure; and the data being
captured would provide minimal added
regulatory benefit, likely not justified by
6 Exchanges with floors currently have rules that
govern the operation of the trading floor, from
original receipt and systematization of an order by
a floor broker to execution, including rules
describing how verbal interest on an exchange floor
is to be communicated. See, e.g., July 1, 2020
Exemption Request, Exhibit A (describing the
process for relevant exchanges).
7 ‘‘Upstairs’’ is a term used to describe the offexchange market. For example, trading that occurs
within a broker-dealer firm or between two brokerdealers in the over-the-counter market would be
described as occurring ‘‘upstairs.’’
8 Currently, these exchanges are NYSE, NYSE
American, NYSE Arca, CBOE, PHLX and BOX.
9 See July 1, 2020 Exemption Request, supra note
3, at 3.
10 See id. at 3.
11 See July 1, 2020 Exemption Request, supra note
3, at 3. See also NYSE Rule 7.35B, NYSE Arca Rule
6.67–O, NYSE American Rule 955NY and Cboe
Rule 5.91(a)(4).
12 See July 1, 2020 Exemption Request, supra note
3, at 3. See also NYSE Rule 7.35B, NYSE Arca Rule
6.67–O, NYSE American Rule 955NY and Cboe
Rule 5.91(a)(4).
13 See July 1, 2020 Exemption Request, supra note
3, at 3.
14 See id. at 6–7.
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the costs that would be required to
create systems to capture the activity.15
The Participants explain that floor
brokers and floor market makers will
ultimately be required to expend
significant effort and funds to provide
the data necessary to report verbal
orders and quotes to CAT.16 The
Participants state that if verbal floor
activity were required to be reported to
CAT, Industry Members operating on
exchange floors would need to create a
process or system to electronically
record in real time the firm data being
verbally communicated on exchange
floors and to merge that data into the
information tracked electronically.17
The Participants state that neither the
exchanges with floors nor Industry
Members currently collect or have the
means to collect the data for verbal
activity on the floor for purposes for
CAT reporting and the measures
necessary to put such systems in place
would significantly disrupt floor
trading.18 The Participants further state
that requiring such reporting would
likely cause market makers to miss
participation in fast-changing markets,
and no similar burden would be borne
by electronic market makers, whose data
collection for CAT reporting will not
impact their real-time ability to provide
liquidity to the market.19
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B. Unstructured Verbal and Electronic
Activity
The Participants believe that much
unstructured verbal and electronic
activity by Industry Members does not
involve firm orders and is thus not
subject to CAT reporting.20 However,
the Participants believe that two types
of verbal and unstructured electronic
upstairs activity may involve firm
orders that would be subject to CAT
reporting: (1) Verbal telephone
discussions between an Industry
Member and a client and (2)
unstructured electronic
communications that are not currently
captured by Industry Member order
management or execution systems.
The Participants state that telephonic
discussions and unstructured electronic
upstairs activities were not
contemplated as being CAT reportable
at the time the Commission adopted
Rule 613 of Regulation NMS and the
CAT NMS Plan.21 The Participants state
that the industry has provided the
15 See
id. at 6.
id. at 6.
17 See id. at 9.
18 See July 1, 2020 Exemption Request, supra note
3, at 6.
19 See id. at 8.
20 See id. at 9.
21 See id. at 9–10.
16 See
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17:59 Nov 17, 2020
Jkt 253001
Participants with cost projections for
capturing and reporting upstairs
negotiations, which are estimated to be
approximately $485 million to $590
million.22 The Participants further state
that these cost projections recognize that
Industry Members do not currently
collect data for these scenarios, and do
not have the means today to collect such
data. The Participants also explain that
there is uncertainty whether necessary
information can be captured with
today’s technology or personnel in a
reliable, accurate and consistent
manner.23 The Participants do not
believe this information will add much
value to the data available in CAT and
any minimal added regulatory benefit
would be outweighed by costs imposed
on, and adverse impact on, Industry
Members.24
The Participants state that the changes
required to capture and report verbal
and unstructured electronic upstairs
activity would cause significant and
adverse changes to existing industry
practices and business models, which
would conflict with one of the
underlying principles of the CAT.25 The
Participants also state that reporting of
this activity may also slow trading
processes at certain broker-dealers, and/
or may increase the time to initiate a
trade, causing clients potentially to
receive less advantageous pricing for
investors.26 The Participants also
believe that if required to be reported,
Industry Members may modify their
workflows to rely more heavily on
indications of interest or similar
methods outside the definition of an
order, thereby avoiding CAT reporting
requirements for that activity, which
could have a negative impact on the
price discovery process as well as
existing workflows.27
The Participants also state that
identifying and reporting of verbal or
unstructured electronic
communications is difficult and given
the subjective nature of determining
whether or not a bid or offer is firm,
CAT reporting of such communications
will be variable and inconsistent.28 The
Participants state that Industry Members
and different individuals could reach
different conclusions about whether or
22 See
id. at 10.
July 1, 2020 Exemption Request, supra note
3, at 10. The Commission understands that this
estimation is based on industry cost projections and
assumes significant manual intervention is
necessary to capture this information.
24 See id.
25 See id.
26 See id.
27 See id.
28 See July 1, 2020 Exemption Request, supra note
3, at 10.
23 See
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not specific verbal or unstructured
electronic communications meet the
elements of a CAT Reportable Event and
Industry Members on opposite sides of
a bid/offer may capture the same
activity differently, resulting in a
misleading view of the transaction.29
III. Discussion of Participants’
Exemption Request
The Commission has carefully
considered the information provided by
the Participants in support of the
Participants’ exemption request. The
Commission believes that granting
temporary exemptive relief is, pursuant
to Section 36 of the Exchange Act,
appropriate in the public interest and
consistent with the protection of
investors, and that pursuant to Rule
608(e), this exemption is consistent with
the public interest, the protection of
investors, the maintenance of fair and
orderly markets and the removal of
impediments to, and the perfection of a
national market system.
Rule 613(j)(9) of Regulation NMS and
Section 1.1 of the CAT NMS Plan
defines the term ‘‘reportable event’’ as
including, but not limited to, the
original receipt or origination,
modification, cancellation, routing, and
execution (in whole or in part) of an
order, and receipt of a routed order.30
The term ‘‘order’’ is defined in Rule
613(j)(8) of Regulation NMS and Section
1.1 of the CAT NMS Plan as including:
(i) Any order received by a member of
a national securities exchange or
national securities association from any
person; (ii) any order originated by a
member of a national securities
exchange or national securities
association; or (iii) any bid or offer.31
‘‘Bid’’ and ‘‘offer’’ are defined in
Regulation NMS as the bid price or offer
price communicated by a member of an
exchange or association to any brokerdealer or to any customer, at which it
is willing to buy or sell one or more
round lots of an NMS security, as
principal or agent, but excluding
indications of interest.32
Rule 613 and the CAT NMS Plan both
require the capture and reporting of
quotes and orders that meet the
definition of a CAT reportable event,
which includes verbal quotes and
orders. The Commission believes that
many unstructured verbal or manual
communications on exchange floors and
‘‘upstairs’’ are reportable events under
Rule 613 and the CAT NMS Plan
because firm verbal quotes and orders,
29 See
id. at 10.
17 CFR 242.613(j)(9).
31 See 17 CFR 242.613(j)(8).
32 See 17 CFR 242.600(b)(8).
30 See
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whether they occur on an exchange
floor or ‘‘upstairs,’’ are reportable to
CAT if they are a firm bid or offer. As
the Participants note, firm indications of
a willingness to buy or sell a security
are orders, bids, or offers and have
reportable events associated with them
pursuant to the CAT NMS Plan.33
However, indications of interest and
other verbal negotiations that do not
constitute firm quotes or orders are not
reportable to CAT, and many
unstructured verbal or manual
communications on exchange floors and
‘‘upstairs’’ are not reportable to CAT
because they are not firm.
The Commission disagrees with the
Participants’ statement that the verbal
announcement of already systematized
and reported orders and of firm quotes
on exchange floors, firm bid and offer
communications in verbal telephone
discussions between an Industry
Member and a client, and firm orders in
unstructured electronic
communications that are not currently
captured by Industry Member order
management or execution systems were
not contemplated as being CATreportable at the time the Commission
adopted Rule 613 and the approval of
the CAT NMS Plan. Verbal quotes and
orders are a subset of ‘‘Manual Order
Events,’’ which, as defined by the CAT
NMS Plan, are non-electronic
communications of order-related
information for which CAT Reporters
must record and report the time of the
event.34 Prior to approval of the CAT
NMS Plan, the Participants requested
and were granted exemptive relief from
the requirement in Rule 613(d)(3) of
Regulation NMS that, for Manual Order
Events, each CAT Reporter record and
report details for reportable events in
timestamps to the millisecond.35 In
support of the request, the SROs listed
examples illustrating reportable events
involving the non-electronic
communication of order-related
information for which CAT Reporters
33 See July 1, 2020 Exemption Request, supra note
3, at 3.
34 See CAT NMS Plan at Section 1.1 (defining
‘‘Manual Order Events’’ as ‘‘a non-electronic
communication of order-related information for
which CAT Reporters must record and report the
time of the event’’).
35 See Securities Exchange Act Release No. 77265
(March 1, 2016), 81 FR 11856 (March 7, 2016). The
Commission granted exemptive relief conditioned
upon (1) Manual Order Events being recorded and
reported with granularity to the second; (2) Manual
Order Events being identified as such in the CAT;
and (3) the Electronic Capture of Manual Order
Events being recorded and reported to the
millisecond. Manual Order Events are defined in
the CAT NMS Plan as a non-electronic
communication of order-related information for
which CAT Reporters must record and report the
time of the event.
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17:59 Nov 17, 2020
Jkt 253001
must record and report the time of the
event under Rule 613, and, among other
things, noted that ‘‘a floor broker at an
exchange that represents an order on the
floor of the exchange may have to
capture the time stamp of order events
manually.’’ 36
The Participants state that capturing
this verbal activity would be costly, and
provide minimal added regulatory
benefit likely not justified by the costs.
In particular, as noted above, Industry
Members have provided Participants
with cost projections for capturing and
reporting upstairs negotiations, which
are estimated to be approximately
$485M to $590M. The Commission
acknowledges the current difficulties of
implementing reporting of such events,
as described by the Participants in the
July 1, 2020 Exemption Request.
Currently, the exchanges with floors and
Industry Members do not have the
means to collect the information
necessary for reporting verbal activity
on exchange floors or upstairs. At the
same time, the Commission believes
that the collection of verbal quotes and
orders would provide regulatory
benefits that do not currently exist today
and disagrees with the Participants
statement that capturing such data
would provide minimal added
regulatory benefit.37 Such reporting
would help regulators better identify
potential violations of securities laws,
regulations, and exchange rules,
including violations of best execution
obligations, firm bid/offer obligations
and exchange priority rules. For
example, the reporting of firm verbal
quotes from floor market makers would
allow regulators to determine whether a
market maker has ‘‘backed away’’ from
a firm quote. Currently, regulators do
not have detailed information relating to
most verbal quotes and orders and such
information would allow regulators to
more capably perform regulatory and
surveillance functions, and the
Commission does not believe it is
appropriate to exclude such quotes and
orders from CAT reporting, which often
are more complex and/or involve larger36 See letter from BATS Exchange, Inc., BATS YExchange, Inc., BOX Options Exchange LLC, C2
Options Exchange, Inc., Chicago Board Options
Exchange, Inc., Chicago Stock Exchange, Inc.,
EDGA Exchange, Inc., EDGX Exchange, Inc.,
Financial Industry Regulatory Authority, Inc.,
International Securities Exchange, LLC, ISE Gemini,
LLC, Miami International Securities Exchange LLC,
The Nasdaq Stock Market LLC, Nasdaq OMX BX,
Inc., Nasdaq OMX PHLX LLC, National Stock
Exchange, Inc., NYSE Arca, Inc., New York Stock
Exchange LLC, and NYSE MKT LLC to Brent J.
Fields, Secretary, Commission, dated January 30,
2015, at 33, available at: https://www.sec.gov/rules/
exorders/2016/finra-incoming-letter-013015.pdf.
37 See July 1, 2020 Exemption Request, supra note
3, at 6 and 10.
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73547
sized orders, particularly on options
trading floors and trading floors for
proprietary products.
Given the concerns expressed by the
Participants, the Commission believes
the Participants’ request to delay the
reporting requirements for verbal quotes
and orders is reasonable. While
including verbal quotes and orders in
the CAT will provide regulatory
benefits, the Commission acknowledges
that the reporting of such orders and
quotes involves complexity and/or
costs, especially because capture of this
information may require significant
manual human intervention. The
Commission believes that granting
temporary exemptive relief to delay the
reporting of verbal quotes and orders
could allow Participants and Industry
Members time to develop or implement
technological changes necessary to
capture this information at a lower cost.
The Commission further believes that
over time, the costs of capturing this
CAT reportable information could
decline due to technological or business
developments, such as through the
usage of artificial intelligence or
automated processes to capture and
report such information, instead of
reliance on the manual capture of order
information.
Based on the foregoing, pursuant to
Section 36 of the Exchange Act, it is
appropriate in the public interest and
consistent with the protection of
investors, and pursuant to Rule 608(e),
it is consistent with the public interest,
the protection of investors, the
maintenance of fair and orderly markets
and the removal of impediments to, and
the perfection of a national market
system to grant temporary relief for the
reporting of: (1) Floor broker verbal
announcements of firm orders on an
exchange that are otherwise reported as
systematized orders; (2) market maker
verbal announcements of firm quotes on
an exchange trading floor and; (3)
telephone discussions between an
Industry Member and a client that
involve firm bid and offer
communications; and (4) unstructured
electronic communications that are not
currently captured by Industry Member
order management or execution
systems. Granting temporary exemptive
relief until July 31, 2023, which is the
date requested by Participants in the
July 1, 2020 Exemption Request, and
which is approximately one year after
the date by which the Participants
previously estimated that the CAT
would be fully implemented, July 11,
E:\FR\FM\18NON1.SGM
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73548
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khammond on DSKJM1Z7X2PROD with NOTICES
2022,38 would provide CAT Reporters
the time to fully consider how to report
such events and create the necessary
technological and process changes
required to capture these required
quotes and orders while minimizing
potential business disruptions and
impacts to existing workflows. As a
condition to this relief, the Participants
must provide the Commission a written
status update on the reporting of these
quotes and orders by July 31, 2022,
including the estimated costs of
reporting these quotes and orders and
an implementation plan for the
reporting of these quotes and orders.
IV. Conclusion
The Commission believes it is
appropriate to grant temporary
exemptive relief that exempts each
Participant from the requirement in
Section 6.4(d) of the CAT NMS Plan for
each Participant, through its
Compliance Rule, to require its Industry
Members to record and electronically
report to the Central Repository the
following communications, until July
31, 2023: (1) Floor broker verbal
announcements of firm orders on an
exchange that are otherwise reported as
systematized orders; (2) market maker
verbal announcements of firm quotes on
an exchange trading floor; (3) telephone
discussions between an Industry
Member and a client that may involve
firm bid and offer communications; and
(4) unstructured electronic and verbal
communications that are not currently
captured by Industry Member order
management or execution systems. As a
condition to this relief, the Participants
must provide the Commission a written
status update on the reporting of these
quotes and orders by July 31, 2022,
including the estimated costs of
reporting these quotes and orders and
an implementation plan for the
reporting of these quotes and orders.
Furthermore, as a condition to this
exemptive relief, Participants must
continue to require that firm verbal
interest on an exchange floor be
expressed pursuant to exchange rules
approved by the Commission and
Participants must require that any firm
verbal interest expressed by a floor
broker must be related to a CATreportable systematized order, and any
resulting trade must be reported to CAT.
Accordingly, it is hereby ordered,
pursuant to Section 36(a)(1) of the
Exchange Act,39 and Rule 608(e) of the
Exchange Act 40 that the Participants are
38 See Securities Exchange Act Release No. 88890
(May 15, 2020), 85 FR 31322, 31334 (May 22, 2020).
39 15 U.S.C. 78mm(a)(1).
40 17 CFR 242.608(e).
VerDate Sep<11>2014
17:59 Nov 17, 2020
Jkt 253001
granted an exemption, until July 31,
2023, from the requirement in Section
6.4(d) of the CAT NMS Plan that
requires each Participant, through its
Compliance Rule, to require its Industry
Members to record and electronically
report to the Central Repository: (1)
Floor broker verbal announcements of
firm orders on an exchange that are
otherwise reported as systematized
orders; (2) market maker verbal
announcements of firm quotes on an
exchange trading floor; (3) telephone
discussions between an Industry
Member and a client that may involve
firm bid and offer communications; (4)
unstructured electronic and verbal
communications that are not currently
captured by Industry Member order
management or execution systems (e.g.,
Bloomberg chats, text messages), subject
to the conditions described above.
By the Commission.
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–25393 Filed 11–17–20; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[SEC File No. 270–399, OMB Control No.
3235–0456]
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:
Form 24F–2
Notice is hereby given that pursuant
to the Paperwork Reduction Act of 1995
(44 U.S.C. 3501–3520), the Securities
and Exchange Commission (the
‘‘Commission’’) is soliciting comments
on the collection of information
summarized below. The Commission
plans to submit this existing collection
of information to the Office of
Management and Budget for extension
and approval.
Rule 24f–2 (17 CFR 270.24f–2) under
the Investment Company Act of 1940
(15 U.S.C. 80a) requires any open-end
management companies (‘‘mutual
funds’’), unit investment trusts
(‘‘UITs’’), registered closed-end
investment companies that make
periodic repurchase offers under rule
23c–3 under the Investment Company
Act [17 CFR 270.23c–3] (‘‘interval
funds’’), or face-amount certificate
companies (collectively, ‘‘funds’’)
deemed to have registered an indefinite
PO 00000
Frm 00094
Fmt 4703
Sfmt 9990
amount of securities to file, not later
than 90 days after the end of any fiscal
year in which it has publicly offered
such securities, Form 24F–2 (17 CFR
274.24) with the Commission. Form
24F–2 is the annual notice of securities
sold by funds that accompanies the
payment of registration fees with respect
to the securities sold during the fiscal
year.
The Commission estimates that 6,794
funds file Form 24F–2 on the required
annual basis. The average annual
burden per respondent for Form 24F–2
is estimated to be four hours. The total
annual burden for all respondents to
Form 24F–2 is estimated to be 27,176
hours.
The estimate of average burden hours
is made solely for the purposes of the
Paperwork Reduction Act, and is not
derived from a comprehensive or even
a representative survey or study of the
costs of Commission rules.
Compliance with the collection of
information required by Form 24F–2 is
mandatory. The Form 24F–2 filing that
must be made to the Commission is
available to the public. An agency may
not conduct or sponsor, and a person is
not required to respond to, a collection
of information unless it displays a
currently valid control number.
The Commission requests written
comments on: (a) Whether the collection
of information is necessary for the
proper performance of the functions of
the Commission, including whether the
information has practical utility; (b) the
accuracy of the Commission’s estimate
of the burdens of the collection of
information; (c) ways to enhance the
quality, utility, and clarity of the
information collected; and (d) ways to
minimize the burden of the collection of
information on respondents, including
through the use of automated collection
techniques or other forms of information
technology. Consideration will be given
to comments and suggestions submitted
in writing within 60 days of this
publication.
Please direct your written comments
to David Bottom, Director/Chief
Information Officer, Securities and
Exchange Commission, C/O Cynthia
Roscoe, 100 F Street NE, Washington,
DC 20549; or send an email to: PRA_
Mailbox@sec.gov.
Dated: November 12, 2020.
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020–25354 Filed 11–17–20; 8:45 am]
BILLING CODE 8011–01–P
E:\FR\FM\18NON1.SGM
18NON1
Agencies
[Federal Register Volume 85, Number 223 (Wednesday, November 18, 2020)]
[Notices]
[Pages 73544-73548]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2020-25393]
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SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-90405]
Order Granting a Temporary Conditional Exemption Pursuant to
Section 36 of the Securities Exchange Act of 1934 (``Exchange Act'')
and Rule 608(e) of Regulation NMS Under the Exchange Act, Relating to
the Reporting of Certain Activities on the Floor of National Securities
Exchanges and Certain Activities by Industry Members Off Exchange
Floors, as Required by Section 6.4(d) of the National Market System
Plan Governing the Consolidated Audit Trail
November 12, 2020.
I. Introduction
By letter dated July 1, 2020, BOX Exchange LLC (``BOX''), Cboe BYX
Exchange, Inc., Cboe BZX Exchange, Inc., Cboe EDGA Exchange, Inc., Cboe
EDGX Exchange, Inc., Cboe C2 Exchange, Inc., Cboe Exchange, Inc.
(``CBOE''), Financial Industry Regulatory Authority, Inc. (``FINRA''),
Investors Exchange LLC, Miami International Securities Exchange LLC,
MIAX Emerald, LLC, MIAX PEARL, LLC, NASDAQ BX, LLC, Nasdaq GEMX, LLC,
Nasdaq ISE, LLC, Nasdaq MRX, LLC, NASDAQ PHLX LLC (``PHLX''), The
NASDAQ Stock Market LLC, New York Stock Exchange LLC (``NYSE''), NYSE
American LLC (``NYSE American''), NYSE Arca, Inc. (``NYSE Arca''), NYSE
Chicago, Inc., NYSE National, Inc., and Long Term Stock Exchange, Inc.
(collectively, the ``Participants'' or ``SROs'') requested
[[Page 73545]]
that the Securities and Exchange Commission (``Commission'' or ``SEC'')
grant temporary exemptive relief to the Participants from the National
Market System Plan Governing the Consolidated Audit Trail (``CAT NMS
Plan''),\1\ pursuant to its authority under Section 36 of the
Securities Exchange Act of 1934 (``Exchange Act'') \2\ and Rule 608(e)
of Regulation NMS under the Exchange Act, from certain reporting
requirements in Section 6.4(d) of the CAT NMS Plan relating to certain
activities on the floors of national securities exchanges and certain
activities by Industry Members off exchange floors.\3\
---------------------------------------------------------------------------
\1\ The CAT NMS Plan was approved by the Commission, as
modified, on November 15, 2016. See Securities Exchange Act Release
No. 79318 (November 15, 2016), 81 FR 84696 (November 23, 2016)
(``CAT NMS Plan Approval Order'').
\2\ 15 U.S.C. 78mm(a)(1).
\3\ See letter from the Participants to Vanessa Countryman,
Secretary, Commission, dated July 1, 2020 (the ``July 1, 2020
Exemption Request''). Unless otherwise noted, capitalized terms are
used as defined in the CAT NMS Plan. MEMX LLC was added as a
Participant to the CAT NMS Plan on June 5, 2020. See Securities
Exchange Act Release No. 89306 (July 13, 2020), 85 FR 43626 (July
17, 2020).
---------------------------------------------------------------------------
Section 36 of the Exchange Act grants the Commission the authority,
with certain limitations, to ``conditionally or unconditionally exempt
any person, security, or transaction . . . from any provision or
provisions of [the Exchange Act] or of any rule or regulation
thereunder, to the extent that such exemption is necessary or
appropriate in the public interest, and is consistent with the
protection of investors.'' \4\ Under Rule 608(e) of Regulation NMS, the
Commission may ``exempt from [Rule 608], either unconditionally or on
specified terms and conditions, any self-regulatory organization,
member thereof, or specified security, if the Commission determines
that such exemption is consistent with the public interest, the
protection of investors, the maintenance of fair and orderly markets
and the removal of impediments to, and perfection of the mechanism of,
a national market system.'' \5\
---------------------------------------------------------------------------
\4\ 15 U.S.C. 78mm(a)(1).
\5\ 17 CFR 242.608(e).
---------------------------------------------------------------------------
For the reasons set forth below, this Order grants the
Participants' request for a temporary exemption from Section 6.4(d) of
the CAT NMS Plan as set forth in the July 1, 2020 Exemption Request,
expiring on July 31, 2023.
II. Request for Relief
In the July 1, 2020 Exemption Request, the Participants request
that the Commission exempt each Participant from the requirement in
Section 6.4(d) of the CAT NMS Plan that each Participant, through its
Compliance Rule, require its Industry Members to record and
electronically report to the Central Repository: (1) Floor broker
verbal announcements of firm bids and offers on an exchange trading
floor that are otherwise reported as systematized orders; and (2)
market maker verbal announcements of firm quotes on an exchange trading
floor, to the extent either are considered orders reportable under Rule
613 of Regulation NMS, the CAT NMS Plan and the Compliance Rules, until
July 31, 2023. As a condition to this exemptive relief, the
Participants state that they would continue to require that firm verbal
interest on an exchange floor (which includes both floor broker verbal
announcements of firm bids and offers and market maker verbal
announcements of firm quotes) be expressed pursuant to exchange rules
approved by the Commission,\6\ and that any such firm verbal interest
expressed by a floor broker must be related to a CAT-reportable
systematized order, and any resulting trade must be reported to CAT.
---------------------------------------------------------------------------
\6\ Exchanges with floors currently have rules that govern the
operation of the trading floor, from original receipt and
systematization of an order by a floor broker to execution,
including rules describing how verbal interest on an exchange floor
is to be communicated. See, e.g., July 1, 2020 Exemption Request,
Exhibit A (describing the process for relevant exchanges).
---------------------------------------------------------------------------
In addition, the Participants request that the Commission exempt
each Participant from the requirement in Section 6.4(d) of the CAT NMS
Plan that each Participant, through its Compliance Rule, require its
Industry Members to record and electronically report to the Central
Repository the following communications that occur ``upstairs,'' \7\ to
the extent such are considered reportable under Rule 613 of Regulation
NMS, the CAT NMS Plan and the Compliance Rules, until July 31, 2023:
(1) Telephone discussions between an Industry Member and a client that
may involve firm bid and offer communications; and (2) unstructured
electronic and verbal communications that are not currently captured by
Industry Member order management or execution systems (e.g., Bloomberg
chats, text messages).
---------------------------------------------------------------------------
\7\ ``Upstairs'' is a term used to describe the off-exchange
market. For example, trading that occurs within a broker-dealer firm
or between two broker-dealers in the over-the-counter market would
be described as occurring ``upstairs.''
---------------------------------------------------------------------------
A. Exchange Floor Activity
The Participants state that on all exchanges with floor trading,\8\
each order must be systematized upon receipt by the floor broker on the
floor of the exchange.\9\ The Participants further state that an order
is considered systematized: (1) When it is sent electronically to the
floor broker's system at the exchange; or (2) when the order is
manually systematized by the floor broker upon receipt outside of the
floor broker's system and prior to representation in the floor trading
crowd.\10\ To the extent a floor broker is not holding a systematized
order, the floor broker is not eligible to represent any firm bid or
offer, or to request firm quotes from in-crowd market participants on
the floor of an exchange.\11\ The Participants state that all firm bids
or offers represented by a floor broker must be associated with orders
that have already been systematized, and that any activity by the floor
broker prior to systemization cannot be related to an order, bid or
offer pursuant to the CAT NMS Plan.\12\ As a result of the
systematization requirements, all orders represented verbally by a
floor broker on an exchange floor are required to be captured in
exchange systems and, under CAT requirements, the floor broker's
receipt of the order, and any modification, electronic route,
cancellation, or execution of the order is subject to CAT
reporting.\13\ The Participants believe that two verbal events on
exchange floors may be CAT-reportable: Floor broker announcements of
firm orders and market maker announcements of firm quotes.
---------------------------------------------------------------------------
\8\ Currently, these exchanges are NYSE, NYSE American, NYSE
Arca, CBOE, PHLX and BOX.
\9\ See July 1, 2020 Exemption Request, supra note 3, at 3.
\10\ See id. at 3.
\11\ See July 1, 2020 Exemption Request, supra note 3, at 3. See
also NYSE Rule 7.35B, NYSE Arca Rule 6.67-O, NYSE American Rule
955NY and Cboe Rule 5.91(a)(4).
\12\ See July 1, 2020 Exemption Request, supra note 3, at 3. See
also NYSE Rule 7.35B, NYSE Arca Rule 6.67-O, NYSE American Rule
955NY and Cboe Rule 5.91(a)(4).
\13\ See July 1, 2020 Exemption Request, supra note 3, at 3.
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The Participants state that that reporting of either of these two
verbal events were not contemplated when the Commission and the
Participants were considering the cost and impact of the CAT NMS
Plan.\14\ The Participants further state that requiring these elements
to be reported to CAT would have a significant and costly impact to
exchange floors, to floor broker and market maker business models, and
to market structure; and the data being captured would provide minimal
added regulatory benefit, likely not justified by
[[Page 73546]]
the costs that would be required to create systems to capture the
activity.\15\
---------------------------------------------------------------------------
\14\ See id. at 6-7.
\15\ See id. at 6.
---------------------------------------------------------------------------
The Participants explain that floor brokers and floor market makers
will ultimately be required to expend significant effort and funds to
provide the data necessary to report verbal orders and quotes to
CAT.\16\ The Participants state that if verbal floor activity were
required to be reported to CAT, Industry Members operating on exchange
floors would need to create a process or system to electronically
record in real time the firm data being verbally communicated on
exchange floors and to merge that data into the information tracked
electronically.\17\ The Participants state that neither the exchanges
with floors nor Industry Members currently collect or have the means to
collect the data for verbal activity on the floor for purposes for CAT
reporting and the measures necessary to put such systems in place would
significantly disrupt floor trading.\18\ The Participants further state
that requiring such reporting would likely cause market makers to miss
participation in fast-changing markets, and no similar burden would be
borne by electronic market makers, whose data collection for CAT
reporting will not impact their real-time ability to provide liquidity
to the market.\19\
---------------------------------------------------------------------------
\16\ See id. at 6.
\17\ See id. at 9.
\18\ See July 1, 2020 Exemption Request, supra note 3, at 6.
\19\ See id. at 8.
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B. Unstructured Verbal and Electronic Activity
The Participants believe that much unstructured verbal and
electronic activity by Industry Members does not involve firm orders
and is thus not subject to CAT reporting.\20\ However, the Participants
believe that two types of verbal and unstructured electronic upstairs
activity may involve firm orders that would be subject to CAT
reporting: (1) Verbal telephone discussions between an Industry Member
and a client and (2) unstructured electronic communications that are
not currently captured by Industry Member order management or execution
systems.
---------------------------------------------------------------------------
\20\ See id. at 9.
---------------------------------------------------------------------------
The Participants state that telephonic discussions and unstructured
electronic upstairs activities were not contemplated as being CAT
reportable at the time the Commission adopted Rule 613 of Regulation
NMS and the CAT NMS Plan.\21\ The Participants state that the industry
has provided the Participants with cost projections for capturing and
reporting upstairs negotiations, which are estimated to be
approximately $485 million to $590 million.\22\ The Participants
further state that these cost projections recognize that Industry
Members do not currently collect data for these scenarios, and do not
have the means today to collect such data. The Participants also
explain that there is uncertainty whether necessary information can be
captured with today's technology or personnel in a reliable, accurate
and consistent manner.\23\ The Participants do not believe this
information will add much value to the data available in CAT and any
minimal added regulatory benefit would be outweighed by costs imposed
on, and adverse impact on, Industry Members.\24\
---------------------------------------------------------------------------
\21\ See id. at 9-10.
\22\ See id. at 10.
\23\ See July 1, 2020 Exemption Request, supra note 3, at 10.
The Commission understands that this estimation is based on industry
cost projections and assumes significant manual intervention is
necessary to capture this information.
\24\ See id.
---------------------------------------------------------------------------
The Participants state that the changes required to capture and
report verbal and unstructured electronic upstairs activity would cause
significant and adverse changes to existing industry practices and
business models, which would conflict with one of the underlying
principles of the CAT.\25\ The Participants also state that reporting
of this activity may also slow trading processes at certain broker-
dealers, and/or may increase the time to initiate a trade, causing
clients potentially to receive less advantageous pricing for
investors.\26\ The Participants also believe that if required to be
reported, Industry Members may modify their workflows to rely more
heavily on indications of interest or similar methods outside the
definition of an order, thereby avoiding CAT reporting requirements for
that activity, which could have a negative impact on the price
discovery process as well as existing workflows.\27\
---------------------------------------------------------------------------
\25\ See id.
\26\ See id.
\27\ See id.
---------------------------------------------------------------------------
The Participants also state that identifying and reporting of
verbal or unstructured electronic communications is difficult and given
the subjective nature of determining whether or not a bid or offer is
firm, CAT reporting of such communications will be variable and
inconsistent.\28\ The Participants state that Industry Members and
different individuals could reach different conclusions about whether
or not specific verbal or unstructured electronic communications meet
the elements of a CAT Reportable Event and Industry Members on opposite
sides of a bid/offer may capture the same activity differently,
resulting in a misleading view of the transaction.\29\
---------------------------------------------------------------------------
\28\ See July 1, 2020 Exemption Request, supra note 3, at 10.
\29\ See id. at 10.
---------------------------------------------------------------------------
III. Discussion of Participants' Exemption Request
The Commission has carefully considered the information provided by
the Participants in support of the Participants' exemption request. The
Commission believes that granting temporary exemptive relief is,
pursuant to Section 36 of the Exchange Act, appropriate in the public
interest and consistent with the protection of investors, and that
pursuant to Rule 608(e), this exemption is consistent with the public
interest, the protection of investors, the maintenance of fair and
orderly markets and the removal of impediments to, and the perfection
of a national market system.
Rule 613(j)(9) of Regulation NMS and Section 1.1 of the CAT NMS
Plan defines the term ``reportable event'' as including, but not
limited to, the original receipt or origination, modification,
cancellation, routing, and execution (in whole or in part) of an order,
and receipt of a routed order.\30\ The term ``order'' is defined in
Rule 613(j)(8) of Regulation NMS and Section 1.1 of the CAT NMS Plan as
including: (i) Any order received by a member of a national securities
exchange or national securities association from any person; (ii) any
order originated by a member of a national securities exchange or
national securities association; or (iii) any bid or offer.\31\ ``Bid''
and ``offer'' are defined in Regulation NMS as the bid price or offer
price communicated by a member of an exchange or association to any
broker-dealer or to any customer, at which it is willing to buy or sell
one or more round lots of an NMS security, as principal or agent, but
excluding indications of interest.\32\
---------------------------------------------------------------------------
\30\ See 17 CFR 242.613(j)(9).
\31\ See 17 CFR 242.613(j)(8).
\32\ See 17 CFR 242.600(b)(8).
---------------------------------------------------------------------------
Rule 613 and the CAT NMS Plan both require the capture and
reporting of quotes and orders that meet the definition of a CAT
reportable event, which includes verbal quotes and orders. The
Commission believes that many unstructured verbal or manual
communications on exchange floors and ``upstairs'' are reportable
events under Rule 613 and the CAT NMS Plan because firm verbal quotes
and orders,
[[Page 73547]]
whether they occur on an exchange floor or ``upstairs,'' are reportable
to CAT if they are a firm bid or offer. As the Participants note, firm
indications of a willingness to buy or sell a security are orders,
bids, or offers and have reportable events associated with them
pursuant to the CAT NMS Plan.\33\ However, indications of interest and
other verbal negotiations that do not constitute firm quotes or orders
are not reportable to CAT, and many unstructured verbal or manual
communications on exchange floors and ``upstairs'' are not reportable
to CAT because they are not firm.
---------------------------------------------------------------------------
\33\ See July 1, 2020 Exemption Request, supra note 3, at 3.
---------------------------------------------------------------------------
The Commission disagrees with the Participants' statement that the
verbal announcement of already systematized and reported orders and of
firm quotes on exchange floors, firm bid and offer communications in
verbal telephone discussions between an Industry Member and a client,
and firm orders in unstructured electronic communications that are not
currently captured by Industry Member order management or execution
systems were not contemplated as being CAT-reportable at the time the
Commission adopted Rule 613 and the approval of the CAT NMS Plan.
Verbal quotes and orders are a subset of ``Manual Order Events,''
which, as defined by the CAT NMS Plan, are non-electronic
communications of order-related information for which CAT Reporters
must record and report the time of the event.\34\ Prior to approval of
the CAT NMS Plan, the Participants requested and were granted exemptive
relief from the requirement in Rule 613(d)(3) of Regulation NMS that,
for Manual Order Events, each CAT Reporter record and report details
for reportable events in timestamps to the millisecond.\35\ In support
of the request, the SROs listed examples illustrating reportable events
involving the non-electronic communication of order-related information
for which CAT Reporters must record and report the time of the event
under Rule 613, and, among other things, noted that ``a floor broker at
an exchange that represents an order on the floor of the exchange may
have to capture the time stamp of order events manually.'' \36\
---------------------------------------------------------------------------
\34\ See CAT NMS Plan at Section 1.1 (defining ``Manual Order
Events'' as ``a non-electronic communication of order-related
information for which CAT Reporters must record and report the time
of the event'').
\35\ See Securities Exchange Act Release No. 77265 (March 1,
2016), 81 FR 11856 (March 7, 2016). The Commission granted exemptive
relief conditioned upon (1) Manual Order Events being recorded and
reported with granularity to the second; (2) Manual Order Events
being identified as such in the CAT; and (3) the Electronic Capture
of Manual Order Events being recorded and reported to the
millisecond. Manual Order Events are defined in the CAT NMS Plan as
a non-electronic communication of order-related information for
which CAT Reporters must record and report the time of the event.
\36\ See letter from BATS Exchange, Inc., BATS Y-Exchange, Inc.,
BOX Options Exchange LLC, C2 Options Exchange, Inc., Chicago Board
Options Exchange, Inc., Chicago Stock Exchange, Inc., EDGA Exchange,
Inc., EDGX Exchange, Inc., Financial Industry Regulatory Authority,
Inc., International Securities Exchange, LLC, ISE Gemini, LLC, Miami
International Securities Exchange LLC, The Nasdaq Stock Market LLC,
Nasdaq OMX BX, Inc., Nasdaq OMX PHLX LLC, National Stock Exchange,
Inc., NYSE Arca, Inc., New York Stock Exchange LLC, and NYSE MKT LLC
to Brent J. Fields, Secretary, Commission, dated January 30, 2015,
at 33, available at: https://www.sec.gov/rules/exorders/2016/finra-incoming-letter-013015.pdf.
---------------------------------------------------------------------------
The Participants state that capturing this verbal activity would be
costly, and provide minimal added regulatory benefit likely not
justified by the costs. In particular, as noted above, Industry Members
have provided Participants with cost projections for capturing and
reporting upstairs negotiations, which are estimated to be
approximately $485M to $590M. The Commission acknowledges the current
difficulties of implementing reporting of such events, as described by
the Participants in the July 1, 2020 Exemption Request. Currently, the
exchanges with floors and Industry Members do not have the means to
collect the information necessary for reporting verbal activity on
exchange floors or upstairs. At the same time, the Commission believes
that the collection of verbal quotes and orders would provide
regulatory benefits that do not currently exist today and disagrees
with the Participants statement that capturing such data would provide
minimal added regulatory benefit.\37\ Such reporting would help
regulators better identify potential violations of securities laws,
regulations, and exchange rules, including violations of best execution
obligations, firm bid/offer obligations and exchange priority rules.
For example, the reporting of firm verbal quotes from floor market
makers would allow regulators to determine whether a market maker has
``backed away'' from a firm quote. Currently, regulators do not have
detailed information relating to most verbal quotes and orders and such
information would allow regulators to more capably perform regulatory
and surveillance functions, and the Commission does not believe it is
appropriate to exclude such quotes and orders from CAT reporting, which
often are more complex and/or involve larger-sized orders, particularly
on options trading floors and trading floors for proprietary products.
---------------------------------------------------------------------------
\37\ See July 1, 2020 Exemption Request, supra note 3, at 6 and
10.
---------------------------------------------------------------------------
Given the concerns expressed by the Participants, the Commission
believes the Participants' request to delay the reporting requirements
for verbal quotes and orders is reasonable. While including verbal
quotes and orders in the CAT will provide regulatory benefits, the
Commission acknowledges that the reporting of such orders and quotes
involves complexity and/or costs, especially because capture of this
information may require significant manual human intervention. The
Commission believes that granting temporary exemptive relief to delay
the reporting of verbal quotes and orders could allow Participants and
Industry Members time to develop or implement technological changes
necessary to capture this information at a lower cost. The Commission
further believes that over time, the costs of capturing this CAT
reportable information could decline due to technological or business
developments, such as through the usage of artificial intelligence or
automated processes to capture and report such information, instead of
reliance on the manual capture of order information.
Based on the foregoing, pursuant to Section 36 of the Exchange Act,
it is appropriate in the public interest and consistent with the
protection of investors, and pursuant to Rule 608(e), it is consistent
with the public interest, the protection of investors, the maintenance
of fair and orderly markets and the removal of impediments to, and the
perfection of a national market system to grant temporary relief for
the reporting of: (1) Floor broker verbal announcements of firm orders
on an exchange that are otherwise reported as systematized orders; (2)
market maker verbal announcements of firm quotes on an exchange trading
floor and; (3) telephone discussions between an Industry Member and a
client that involve firm bid and offer communications; and (4)
unstructured electronic communications that are not currently captured
by Industry Member order management or execution systems. Granting
temporary exemptive relief until July 31, 2023, which is the date
requested by Participants in the July 1, 2020 Exemption Request, and
which is approximately one year after the date by which the
Participants previously estimated that the CAT would be fully
implemented, July 11,
[[Page 73548]]
2022,\38\ would provide CAT Reporters the time to fully consider how to
report such events and create the necessary technological and process
changes required to capture these required quotes and orders while
minimizing potential business disruptions and impacts to existing
workflows. As a condition to this relief, the Participants must provide
the Commission a written status update on the reporting of these quotes
and orders by July 31, 2022, including the estimated costs of reporting
these quotes and orders and an implementation plan for the reporting of
these quotes and orders.
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\38\ See Securities Exchange Act Release No. 88890 (May 15,
2020), 85 FR 31322, 31334 (May 22, 2020).
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IV. Conclusion
The Commission believes it is appropriate to grant temporary
exemptive relief that exempts each Participant from the requirement in
Section 6.4(d) of the CAT NMS Plan for each Participant, through its
Compliance Rule, to require its Industry Members to record and
electronically report to the Central Repository the following
communications, until July 31, 2023: (1) Floor broker verbal
announcements of firm orders on an exchange that are otherwise reported
as systematized orders; (2) market maker verbal announcements of firm
quotes on an exchange trading floor; (3) telephone discussions between
an Industry Member and a client that may involve firm bid and offer
communications; and (4) unstructured electronic and verbal
communications that are not currently captured by Industry Member order
management or execution systems. As a condition to this relief, the
Participants must provide the Commission a written status update on the
reporting of these quotes and orders by July 31, 2022, including the
estimated costs of reporting these quotes and orders and an
implementation plan for the reporting of these quotes and orders.
Furthermore, as a condition to this exemptive relief, Participants must
continue to require that firm verbal interest on an exchange floor be
expressed pursuant to exchange rules approved by the Commission and
Participants must require that any firm verbal interest expressed by a
floor broker must be related to a CAT-reportable systematized order,
and any resulting trade must be reported to CAT.
Accordingly, it is hereby ordered, pursuant to Section 36(a)(1) of
the Exchange Act,\39\ and Rule 608(e) of the Exchange Act \40\ that the
Participants are granted an exemption, until July 31, 2023, from the
requirement in Section 6.4(d) of the CAT NMS Plan that requires each
Participant, through its Compliance Rule, to require its Industry
Members to record and electronically report to the Central Repository:
(1) Floor broker verbal announcements of firm orders on an exchange
that are otherwise reported as systematized orders; (2) market maker
verbal announcements of firm quotes on an exchange trading floor; (3)
telephone discussions between an Industry Member and a client that may
involve firm bid and offer communications; (4) unstructured electronic
and verbal communications that are not currently captured by Industry
Member order management or execution systems (e.g., Bloomberg chats,
text messages), subject to the conditions described above.
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\39\ 15 U.S.C. 78mm(a)(1).
\40\ 17 CFR 242.608(e).
By the Commission.
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2020-25393 Filed 11-17-20; 8:45 am]
BILLING CODE 8011-01-P