Self-Regulatory Organizations; The Nasdaq Stock Market LLC; Order Disapproving a Proposed Rule Change, as Modified by Amendment No. 1, To Amend Listing Rules Applicable to Special Purpose Acquisition Companies Whose Business Plan Is To Complete One or More Business Combinations, 28407-28410 [2021-11099]
Download as PDF
Federal Register / Vol. 86, No. 100 / Wednesday, May 26, 2021 / Notices
28407
acts and practices, to promote just and
equitable principles of trade, and, in
general, to protect investors and the
public interest. FINRA believes that, by
amending Rule 1011(p)(4) to correct an
inadvertent drafting error, and fully and
accurately describe the ‘‘final regulatory
actions’’ that the definition of ‘‘specified
risk event’’ includes, the proposed rule
change will provide greater clarity to
members and the public and serve the
intended investor-protection purposes
of the rules approved in SR–FINRA–
2020–011.
(A) By order approve or disapprove
such proposed rule change, or
(B) institute proceedings to determine
whether the proposed rule change
should be disapproved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.12
J. Matthew DeLesDernier,
Assistant Secretary.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
[FR Doc. 2021–11077 Filed 5–25–21; 8:45 am]
B. Self-Regulatory Organization’s
Statement on Burden on Competition
FINRA does not believe that the
proposed rule change is associated with
any material economic impacts or will
result in any burden on competition that
is not necessary or appropriate in
furtherance of the purposes of the Act.
The proposed rule change is not
designed to address any competitive
issues but rather to correct an
inadvertent drafting error in Rule
1011(p)(4) that resulted in a narrower
scope for the ‘‘final regulatory actions’’
that are included in the ‘‘specified risk
event’’ definition than FINRA intended.
The aspect of the economic impact
assessment undertaken in File No. SR–
FINRA–2020–011 that pertained to the
amendments to the Rule 1000 Series
was based on the broader scope for the
‘‘final regulatory actions’’ that are
included in the ‘‘specified risk event’’
definition that FINRA is proposing here.
Consistent with FINRA’s initial intent,
the broader scope for the ‘‘final
regulatory actions’’ that are included in
the ‘‘specified risk event’’ definition
includes, for example, final SEC and
CFTC regulatory actions where the
sanction against the person was a
suspension other than a suspension
from associating with a member.
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–
FINRA–2021–011 on the subject line.
Self-Regulatory Organizations; The
Nasdaq Stock Market LLC; Order
Disapproving a Proposed Rule
Change, as Modified by Amendment
No. 1, To Amend Listing Rules
Applicable to Special Purpose
Acquisition Companies Whose
Business Plan Is To Complete One or
More Business Combinations
C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
Written comments were neither
solicited nor received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
Within 45 days of the date of
publication of this notice in the Federal
Register or within such longer period (i)
as the Commission may designate up to
90 days of such date if it finds such
longer period to be appropriate and
publishes its reasons for so finding or
(ii) as to which the self-regulatory
organization consents, the Commission
will:
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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–FINRA–2021–011. This file
number should be included on the
subject line if e-mail 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
a.m. and 3 p.m. Copies of such filing
also will be available for inspection and
copying at the principal office of
FINRA. All comments received will be
posted without change. Persons
submitting comments are cautioned that
we do not redact or edit personal
identifying information from comment
submissions. You should submit only
information that you wish to make
available publicly.
All submissions should refer to File
Number SR–FINRA–2021–011 and
should be submitted on or before June
16, 2021.
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BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–91961; File No. SR–
NASDAQ–2020–062]
May 20, 2021.
I. Introduction
On September 3, 2020, The Nasdaq
Stock Market LLC (‘‘Nasdaq’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission
(‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Exchange Act’’) 1 and Rule
19b–4 thereunder,2 a proposed rule
change to amend its listing rules to
permit companies whose business plan
is to complete one or more business
combinations (‘‘SPACs’’ or ‘‘Acquisition
Companies’’) 15 calendar days following
the closing of a business combination to
demonstrate that the SPAC has satisfied
the applicable round lot shareholder
requirement. The proposed rule change
was published for comment in the
Federal Register on September 22,
2020.3
On November 4, 2020, pursuant to
Section 19(b)(2) of the Exchange Act,4
the Commission designated a longer
period within which to approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether to
disapprove the proposed rule change.5
12 17
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
3 See Securities Exchange Act Release No. 89897
(September 16, 2020), 85 FR 59574 (‘‘Notice’’).
Comments received on the proposal are available on
the Commission’s website at: https://www.sec.gov/
comments/sr-nasdaq-2020-062/srnasdaq2020062.
htm. See also, infra, note 8.
4 15 U.S.C. 78s(b)(2).
5 See Securities Exchange Act Release No. 90340,
85 FR 71704 (November 10, 2020). The Commission
designated December 21, 2020, as the date by which
it should approve, disapprove, or institute
1 15
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On December 16, 2020, the Commission
instituted proceedings under Section
19(b)(2)(B) of the Exchange Act 6 to
determine whether to approve or
disapprove the proposed rule change
(‘‘OIP)’’.7 On February 25, 2021, the
Exchange filed Amendment No. 1 to the
proposed rule change, which
superseded the proposed rule change as
originally filed. Amendment No. 1 was
published for comment in the Federal
Register on March 16, 2021.8 On March
18, 2021, the Commission designated a
longer period for Commission action on
the proposed rule change.9
This order disapproves the proposed
rule change, as modified by Amendment
No. 1, because, as discussed below,
Nasdaq has not met its burden under the
Exchange Act and the Commission’s
Rules of Practice to demonstrate that its
proposal is consistent with the
requirements of Section 6(b)(5) of the
Exchange Act, and, in particular, the
requirement that the rules of a national
securities exchange be designed to
prevent fraudulent and manipulative
acts and practices and to protect
investors and the public interest.10
II. Description of the Proposal, as
Modified by Amendment No. 1
A SPAC is a company with no
operations whose business plan is to
complete an initial public offering and
then subsequently engage in a merger or
acquisition with one or more
unidentified operating companies
within a specific period of time.11
Nasdaq listing rules, among other
things, require a SPAC to keep at least
90% of the proceeds from its initial
public offering in an escrow account,12
and to complete one or more business
combinations having an aggregate fair
market value of at least 80% of the value
of the escrow account within a specified
period of time.13 Following each
business combination, the combined
company must meet the requirements
proceedings to determine whether to disapprove the
proposed rule change.
6 15 U.S.C. 78s(b)(2)(B).
7 See Securities Exchange Act Release No. 90682,
85 FR 83113 (December 21, 2020).
8 See Securities Exchange Act Release No. 91294
(March 10, 2021), 86 FR 14508 (March 16, 2021)
(‘‘Notice II’’). Comments received in response to
Amendment No. 1 to the proposal are available on
the Commission’s website at: https://www.sec.gov/
comments/sr-nasdaq-2020-062/srnasdaq2020062.
htm.
9 See Securities Exchange Act Release No. 91348,
86 FR 15747 (March 24, 2021).
10 15 U.S.C. 78f(b)(5).
11 See Securities Exchange Act Release No. 58228
(July 25, 2008), 73 FR 44794 (July 31, 2008) (order
approving the predecessor rule to IM–5101–2).
12 See Nasdaq IM–5101–2(a).
13 See Nasdaq IM–5101–2(b).
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for initial listing on Nasdaq 14 including
those requiring a minimum number of
round lot shareholders (the
‘‘Shareholder Requirement’’).15 If the
combined company does not meet all
the initial listing requirements following
a business combination, Nasdaq listing
rules currently provide that Nasdaq staff
will issue a Staff Delisting
Determination.16
In its proposal, Nasdaq acknowledges
that its existing rules require that,
‘‘following each business combination’’
with a SPAC, the resulting company
must satisfy all initial listing
requirements. Nasdaq states, however,
that the rule does not provide a
timetable for the company to
demonstrate that it satisfies those
requirements. Accordingly, Nasdaq
proposes to modify the rule to specify
if the SPAC demonstrates that it will
satisfy all requirements except the
applicable Shareholder Requirement,
then the SPAC will receive 15 calendar
days following the closing to
demonstrate that it satisfied the
applicable Shareholder Requirement
immediately following the transaction’s
closing. In addition, Nasdaq proposes to
require that a company relying on this
15-day grace period publicly announce,
prior to the business combination, on a
Form 8–K, where required by SEC rules,
or by issuing a press release, that it has
not yet demonstrated compliance with
the Shareholder Requirement and is
subject to delisting if it cannot do so
within the requisite time frame.17
14 See Nasdaq IM–5101–2(d). If a shareholder vote
on the business combination is held, public
shareholders voting against a business combination
must have the right to convert their shares of
common stock into a pro rata share of the aggregate
amount then in the escrow account (net of taxes
payable and amounts distributed to management for
working capital purposes) if the business
combination is approved and consummated. Id. If
a shareholder vote on the business combination is
not held, the company must provide all
shareholders with the opportunity to redeem their
shares for cash equal to their pro rata share of the
aggregate amount then in the deposit account (net
of taxes payable and amounts distributed to
management for working capital purposes). See
Nasdaq IM–5101–2(e).
15 Nasdaq has three listing tiers, each of which
require, among other things, a company to have a
minimum number of shareholders in order to
initially list on the Exchange. See Nasdaq Rule 5315
(f)(1) (on Global Select, an issuer must have at least
550 Total Holders with a minimum average
monthly trading volume over the prior 12 months,
2,200 Total Holders, or 450 Round Lot Holders with
50% of holders holding Unrestricted Securities);
Nasdaq Rule 5405(a)(3) (on Global, an issuer must
have at least 400 Round Lot Holders with 50% of
holders holding Unrestricted Securities); and
Nasdaq Rule 5505(a)(3) (on Capital, an issuer must
have at least 300 Round Lot Holders with at least
50% of holders holding Unrestricted Securities.
16 See Nasdaq IM–5101–2(d).
17 See Notice II of Amendment No. 1, supra note
8.
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Finally, Nasdaq proposes to halt trading
in the securities if the company fails to
make this public announcement.18
Nasdaq states that it ordinarily
determines compliance with the
Shareholder Requirement at the time of
a business combination by reviewing a
company’s public disclosures and
information provided by the company
about the transaction.19 According to
Nasdaq, if it cannot determine
compliance using public information, it
will typically request the company to
provide additional information such as
registered shareholder lists from the
company’s transfer agent, data from
Cede & Co. about shares held in street
name, or data from broker-dealers and
third parties that distribute information
such as proxy materials for the brokerdealers. If the company can provide
information demonstrating compliance
before the business combination closes,
Nasdaq states that no further
information would be required.
However, Nasdaq states that it has
observed that in some cases it can be
difficult for a company to obtain
evidence demonstrating the number of
shareholders that it has or will have
following a business combination.
Nasdaq states that shareholders in a
SPAC may redeem or tender their shares
until just before the time of the business
combination, and the SPAC may not
know how many shareholders will
choose to redeem until very close to the
consummation of the business
combination.20 Nasdaq states that this
could impact its ability to determine
compliance before the business
combination closes, in cases where the
number of round lot shareholders is
close to the applicable requirement.
Nasdaq states that under its proposal
the SPAC must still demonstrate that it
satisfied the round lot shareholder
requirement immediately following the
business combination, and that the
proposal merely would give the SPAC
15 calendar days to provide evidence
that it had met the Shareholder
Requirement. Nasdaq also states that it
believes that the proposed public
disclosure requirement will help
provide transparency to investors about
the status of the company during the
additional time period it has to evidence
18 See
id.
19 Nasdaq
states, for example, that the merger
agreement may result in the Acquisition Company
issuing a round lot of shares to more than 300
holders of the target of the business combination at
closing.
20 The Exchange notes that SPACs are unlike
other newly listing companies which do not face
redemptions and are not already listed and trading
at the time they must demonstrate compliance.
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compliance with the Shareholder
Requirement.21
Nasdaq believes that the proposal
‘‘balances the burden placed on the
Acquisition Company to obtain accurate
shareholder information for the new
entity and the need to ensure that a
company that does not satisfy the initial
listing requirements following a
business combination enters the
delisting process promptly.’’ 22 Nasdaq
states that if the company does not
evidence compliance within the
proposed time period, Nasdaq staff
would issue a Staff Delisting
Determination, which the company
could then appeal to an independent
hearings panel.23
The Commission received two
comment letters opposing the proposal
from the Council of Institutional
Investors.24 The commenter stated that
additional information from Nasdaq in
response to the OIP would be helpful in
determining whether the proposed rule
change is consistent with the Exchange
Act, and questioned whether a
loosening of SPAC listing standards is
consistent with the protection of
investors and the public interest.25 More
broadly, the commenter referenced a
recent study that it believes finds that
SPACs and their officers and directors
face limited liability to investors for
material misstatements in, or omissions
from, their registration statements, and
that SPAC structures generally create
losses for long-term investors.26 Finally,
the commenter referenced the study’s
suggestion that the regulatory treatment
for SPACs should be generally
equivalent to that for direct listings and
questioned whether Nasdaq’s proposal
would lead to a pro-SPAC bias.27 The
Exchange responded to CII Letter I that
the proposal would not loosen SPAC
listing standards because under its
proposal SPACs would still have to
comply with the Shareholder
Requirement at the time of the business
combination and would just be
provided an additional 15 days after
completing their business combination
21 See
Notice II of Amendment No. 1, supra note
8.
22 The Exchange also states that shareholders of
the SPAC would be harmed if Nasdaq issued a
delisting determination at a time when the
company did, in fact, satisfy all initial listing
requirements but could not yet provide proof.
23 The Exchange has also proposed to eliminate
a duplicative paragraph and add a new subsection
enumeration to its existing rule.
24 See Letter from Jeffrey P. Mahoney, General
Counsel, Council of Institutional Investors (January
7, 2021) (‘‘CII Letter I’’); Letter from Jeffrey P.
Mahoney, General Counsel, Council of Institutional
Investors (March 25, 2021) (‘‘CII Letter II’’).
25 See CII Letter I, supra note 24.
26 Id.
27 See CII Letter II, supra note 24.
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to demonstrate such compliance.28 The
Exchange further stated that its proposal
will provide transparency and does not
pose any additional risk to the
protection of shareholders.29
III. Discussion and Commission
Findings
The Commission must consider
whether Nasdaq’s proposal is consistent
with the Exchange Act and the rules and
regulations thereunder applicable to a
national securities exchange, including
Section 6(b)(5) of the Exchange Act,
which requires, in relevant part, that the
rules of a national securities exchange
be designed ‘‘to prevent fraudulent and
manipulative acts and practices’’ and
‘‘to protect investors and the public
interest.’’ 30 Under the Commission’s
Rules of Practice, the ‘‘burden to
demonstrate that a proposed rule change
is consistent with the Exchange Act and
the rules and regulations issued
thereunder . . . is on the self-regulatory
organization [‘SRO’] that proposed the
rule change.’’ 31
The description of a proposed rule
change, its purpose and operation, its
effect, and a legal analysis of its
consistency with applicable
requirements must all be sufficiently
detailed and specific to support an
affirmative Commission finding,32 and
any failure of an SRO to provide this
information may result in the
Commission not having a sufficient
basis to make an affirmative finding that
a proposed rule change is consistent
with the Exchange Act and the
28 See Letter from Arnold Golub, Vice President
and Deputy General Counsel, (February 25, 2021)
(‘‘Nasdaq Letter’’).
29 Id.
30 15 U.S.C. 78f(b)(5). Pursuant to Section 19(b)(2)
of the Exchange Act, 15 U.S.C. 78s(b)(2), the
Commission must disapprove a proposed rule
change filed by a national securities exchange if it
does not find that the proposed rule change is
consistent with the applicable requirements of the
Exchange Act. Exchange Act Section 6(b)(5) states
that an exchange shall not be registered as a
national securities exchange unless the Commission
determines that ‘‘[t]he rules of the exchange are
designed to prevent fraudulent and manipulative
acts and practices, to promote just and equitable
principles of trade, to foster cooperation and
coordination with persons engaged in regulating,
clearing, settling, processing information with
respect to, and facilitating transactions in securities,
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 are not
designed to permit unfair discrimination between
customers, issuers, brokers, or dealers, or to regulate
by virtue of any authority conferred by this title
matters not related to the purposes of this title or
the administration of the exchange.’’ 15 U.S.C.
78(f)(b)(5).
31 Rule 700(b)(3), Commission Rules of Practice,
17 CFR 201.700(b)(3).
32 See id.
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28409
applicable rules and regulations.33
Moreover, ‘‘unquestioning reliance’’ on
an SRO’s representations in a proposed
rule change is not sufficient to justify
Commission approval of a proposed rule
change.34
The Commission has consistently
recognized the importance of the
minimum number of holders and other
similar requirements stating that such
listing standards help ensure that
exchange listed securities have
sufficient public float, investor base,
and trading interest to provide the depth
and liquidity necessary to promote fair
and orderly markets.35 The Shareholder
Requirement also helps to ensure that
trading in exchange-listed securities is
not susceptible to manipulation.36
As discussed above, Nasdaq is
proposing to: (1) Allow a SPAC 15
calendar days following the closing of a
business combination to demonstrate
that it satisfied the applicable
Shareholder Requirement immediately
following the transaction’s closing, and
(2) require a SPAC relying on the
additional 15 day period to publicly
announce, prior to the listing of the
combined company, that it has not
demonstrated compliance with the
Shareholder Requirement and is subject
to delisting if it cannot do so within the
requisite time period. Nasdaq states that
it can be difficult for a SPAC to obtain
evidence demonstrating the number of
holders the SPAC will have following
its business combination because SPAC
shareholders have the right to redeem or
tender their shares until just before the
time of such business combination.
Further, Nasdaq states that, given the
uncertainty around the number of
redemptions and ongoing trading
through the closing of the business
combination, it may not be possible for
33 See
id.
34 Susquehanna
Int’l Group, LLP v. Securities and
Exchange Commission, 866 F.3d 442, 447 (D.C. Cir.
2017).
35 The Commission considers distribution
standards, including minimum number of holders
and number of shares outstanding requirements, to
be important means of promoting fair and orderly
markets. See, e.g., Securities Exchange Act Release
No. 57785 (May 6, 2008), 73 FR 27597 (May 13,
2008) (SR–NYSE–2008–17) (stating that the
distribution standards, which includes exchange
holder requirements ‘‘. . . should help to ensure
that the [Acquisition Companies’] securities have
sufficient public float, investor base, and liquidity
to promote fair and orderly markets’’); Securities
Exchange Act Release No. 86117 (June 14, 2019), 84
FR 28879 (June 20, 2018) (SR–NYSE–2018–46)
(disapproving a proposal to reduce the minimum
number of public holders continued listing
requirement applicable to Acquisition Companies
from 300 to 100).
36 See, e.g., Securities Exchange Act Release Nos.
91236 (March 2, 2021), 86 FR 13414 (March 8,
2021) (SR–NYSEArca–2020–56) and 90819
(December 29, 2020), 86 FR 332 (January 5, 2021)
(SR–CboeBZX–2020–036).
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the SPAC to definitively establish that it
will satisfy the Shareholder
Requirement before completing the
combination. In addition, Nasdaq states
that, while other companies cannot
become listed until they demonstrate
compliance with the Shareholder
Requirement, SPACs completing
business combinations are already listed
and, without more time, would be the
only type of company to face immediate
delisting as a result of these difficulties.
Finally, Nasdaq states that 21 of the 49
SPAC business combinations processed
by Nasdaq during 2019 and 2020
needed additional time to demonstrate
compliance with the Shareholder
Requirement.
Nasdaq emphasizes that, under its
proposal, the SPAC must still
demonstrate that it satisfied the
applicable Shareholder Requirement
immediately following the business
combination, and is simply being
provided 15 calendar days to provide
evidence that it did. However, Nasdaq
has not explained the extent to which
the 21 SPACs that needed additional
time to demonstrate compliance in 2019
and 2020 actually were in compliance
with the shareholder requirement
immediately following the closing of the
business combination, or instead were
not in compliance and needed
additional time to acquire the requisite
number of shareholders. If the former,
Nasdaq has not explained why, like
newly-listed companies in advance of
their public offerings, the SPAC could
not provide preliminary evidence of its
compliance with the Shareholder
Requirement in advance of the business
combination, or why last minute
shareholder redemptions would impact
that evidence. If the latter, then the
SPACs in fact were not in compliance
with the Shareholder Requirement at
the time of the business combination,
and do not provide support for Nasdaq’s
proposal, which is premised on the
assumption that such SPACs simply
needed additional time to evidence their
compliance.
More broadly, Nasdaq does not
explain how its proposal addresses the
regulatory risks to fair and orderly
markets, investor protection and the
public interest, and the manipulation
concerns if companies initially list, and
can continue to trade, on the Exchange
without meeting the Shareholder
Requirement. Notably, and as discussed
in the OIP, Nasdaq has not addressed
the risk that, by waiting for SPACs to
demonstrate compliance with the
Shareholder Requirement until after the
closing of the business combination,
non-compliant companies could be
listed on the Exchange despite not
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meeting initial listing standards, and
have their securities continue to trade
until the delisting process has been
completed. In such circumstances, a
SPAC could complete a business
combination and very soon thereafter be
subject to delisting proceedings, and
during such time its securities may
continue to trade with a number of
holders that is substantially less than
the required minimum raising concerns
about the maintenance of fair and
orderly markets and investor protection.
While Nasdaq has amended its
proposal to require certain public
disclosure, the Commission does not
believe the disclosure required by the
proposed rule adequately addresses the
potential risks associated with trading
during a time period in which the
minimum number of round lot
shareholders may not be present, nor
has Nasdaq explained why subjecting
shareholders to this potential risk is
consistent with the protection of
investors and the public interest, and
the other requirements of Section 6(b)(5)
of the Exchange Act.37
As stated above, under the
Commission’s Rules of Practice, the
‘‘burden to demonstrate that a proposed
rule change is consistent with the
Exchange Act and the rules and
regulations issued thereunder . . . is on
the self-regulatory organization [‘SRO’]
that proposed the rule change.’’ 38 The
description of a proposed rule change,
its purpose and operation, its effect, and
a legal analysis of its consistency with
applicable requirements must all be
sufficiently detailed and specific to
support an affirmative Commission
finding, and any failure of an SRO to
provide this information may result in
the Commission not having a sufficient
basis to make an affirmative finding that
a proposed rule change is consistent
with the Exchange Act and the
applicable rules and regulations.39 For
the reasons discussed above, the
Commission concludes that, because
Nasdaq has not demonstrated that its
proposal is designed to prevent
fraudulent and manipulative acts and
practices or to protect investors and the
public interest, Nasdaq has not met its
burden to demonstrate that its proposal
is consistent with the requirements of
the Exchange Act and the rules and
regulations thereunder applicable to a
national securities exchange, and in
particular Section 6(b)(5) of the
37 The Commission notes that the commenter
continued to oppose the proposal after Nasdaq
amended it to require this public disclosure. See CII
Letter II, supra note 24.
38 Rule 700(b)(3), Commission Rules of Practice,
17 CFR 201.700(b)(3).
39 See id.
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Exchange Act.40 For this reason, the
Commission must disapprove the
proposal.
IV. Conclusion
For the reasons set forth above, the
Commission does not find, pursuant to
Section 19(b)(2) of the Exchange Act,41
that the proposed rule change is
consistent with the requirements of the
Exchange Act and the rules and
regulations thereunder applicable to a
national securities exchange, and in
particular, with Section 6(b)(5) of the
Exchange Act.42
It is therefore ordered, pursuant to
Section 19(b)(2) of the Exchange Act,
that proposed rule change SR–Nasdaq–
2020–062 is disapproved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.43
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021–11099 Filed 5–25–21; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–91952; File No. SR–
NYSEArca–2021–29]
Self-Regulatory Organizations; NYSE
Arca, Inc.; Notice of Filing of Proposed
Rule Change To List and Trade the
Shares of ConvexityShares 1x SPIKES
Futures ETF Under NYSE Arca Rule
8.200–E (Trust Issued Receipts)
May 20, 2021.
Pursuant to Section 19(b)(1) 1 of the
Securities Exchange Act of 1934
(‘‘Act’’) 2 and Rule 19b–4 thereunder,3
notice is hereby given that on May 13,
2021, NYSE Arca, Inc. (‘‘NYSE Arca’’ or
the ‘‘Exchange’’) filed with the
Securities and Exchange Commission
(‘‘Commission’’) the proposed rule
change as described in Items I and II
below, which Items have been prepared
by the self-regulatory organization. The
Commission is publishing this notice to
solicit comments on the proposed rule
change from interested persons.
40 In disapproving this proposed rule change, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
41 15 U.S.C. 78s(b)(2).
42 15 U.S.C. 78f(b)(5).
43 17 CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 15 U.S.C. 78a.
3 17 CFR 240.19b–4.
E:\FR\FM\26MYN1.SGM
26MYN1
Agencies
[Federal Register Volume 86, Number 100 (Wednesday, May 26, 2021)]
[Notices]
[Pages 28407-28410]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-11099]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-91961; File No. SR-NASDAQ-2020-062]
Self-Regulatory Organizations; The Nasdaq Stock Market LLC; Order
Disapproving a Proposed Rule Change, as Modified by Amendment No. 1, To
Amend Listing Rules Applicable to Special Purpose Acquisition Companies
Whose Business Plan Is To Complete One or More Business Combinations
May 20, 2021.
I. Introduction
On September 3, 2020, The Nasdaq Stock Market LLC (``Nasdaq'' or
``Exchange'') filed with the Securities and Exchange Commission
(``Commission''), pursuant to Section 19(b)(1) of the Securities
Exchange Act of 1934 (``Exchange Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to amend its listing rules to
permit companies whose business plan is to complete one or more
business combinations (``SPACs'' or ``Acquisition Companies'') 15
calendar days following the closing of a business combination to
demonstrate that the SPAC has satisfied the applicable round lot
shareholder requirement. The proposed rule change was published for
comment in the Federal Register on September 22, 2020.\3\
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\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 89897 (September 16,
2020), 85 FR 59574 (``Notice''). Comments received on the proposal
are available on the Commission's website at: https://www.sec.gov/comments/sr-nasdaq-2020-062/srnasdaq2020062.htm. See also, infra,
note 8.
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On November 4, 2020, pursuant to Section 19(b)(2) of the Exchange
Act,\4\ the Commission designated a longer period within which to
approve the proposed rule change, disapprove the proposed rule change,
or institute proceedings to determine whether to disapprove the
proposed rule change.\5\
[[Page 28408]]
On December 16, 2020, the Commission instituted proceedings under
Section 19(b)(2)(B) of the Exchange Act \6\ to determine whether to
approve or disapprove the proposed rule change (``OIP)''.\7\ On
February 25, 2021, the Exchange filed Amendment No. 1 to the proposed
rule change, which superseded the proposed rule change as originally
filed. Amendment No. 1 was published for comment in the Federal
Register on March 16, 2021.\8\ On March 18, 2021, the Commission
designated a longer period for Commission action on the proposed rule
change.\9\
---------------------------------------------------------------------------
\4\ 15 U.S.C. 78s(b)(2).
\5\ See Securities Exchange Act Release No. 90340, 85 FR 71704
(November 10, 2020). The Commission designated December 21, 2020, as
the date by which it should approve, disapprove, or institute
proceedings to determine whether to disapprove the proposed rule
change.
\6\ 15 U.S.C. 78s(b)(2)(B).
\7\ See Securities Exchange Act Release No. 90682, 85 FR 83113
(December 21, 2020).
\8\ See Securities Exchange Act Release No. 91294 (March 10,
2021), 86 FR 14508 (March 16, 2021) (``Notice II''). Comments
received in response to Amendment No. 1 to the proposal are
available on the Commission's website at: https://www.sec.gov/comments/sr-nasdaq-2020-062/srnasdaq2020062.htm.
\9\ See Securities Exchange Act Release No. 91348, 86 FR 15747
(March 24, 2021).
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This order disapproves the proposed rule change, as modified by
Amendment No. 1, because, as discussed below, Nasdaq has not met its
burden under the Exchange Act and the Commission's Rules of Practice to
demonstrate that its proposal is consistent with the requirements of
Section 6(b)(5) of the Exchange Act, and, in particular, the
requirement that the rules of a national securities exchange be
designed to prevent fraudulent and manipulative acts and practices and
to protect investors and the public interest.\10\
---------------------------------------------------------------------------
\10\ 15 U.S.C. 78f(b)(5).
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II. Description of the Proposal, as Modified by Amendment No. 1
A SPAC is a company with no operations whose business plan is to
complete an initial public offering and then subsequently engage in a
merger or acquisition with one or more unidentified operating companies
within a specific period of time.\11\ Nasdaq listing rules, among other
things, require a SPAC to keep at least 90% of the proceeds from its
initial public offering in an escrow account,\12\ and to complete one
or more business combinations having an aggregate fair market value of
at least 80% of the value of the escrow account within a specified
period of time.\13\ Following each business combination, the combined
company must meet the requirements for initial listing on Nasdaq \14\
including those requiring a minimum number of round lot shareholders
(the ``Shareholder Requirement'').\15\ If the combined company does not
meet all the initial listing requirements following a business
combination, Nasdaq listing rules currently provide that Nasdaq staff
will issue a Staff Delisting Determination.\16\
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\11\ See Securities Exchange Act Release No. 58228 (July 25,
2008), 73 FR 44794 (July 31, 2008) (order approving the predecessor
rule to IM-5101-2).
\12\ See Nasdaq IM-5101-2(a).
\13\ See Nasdaq IM-5101-2(b).
\14\ See Nasdaq IM-5101-2(d). If a shareholder vote on the
business combination is held, public shareholders voting against a
business combination must have the right to convert their shares of
common stock into a pro rata share of the aggregate amount then in
the escrow account (net of taxes payable and amounts distributed to
management for working capital purposes) if the business combination
is approved and consummated. Id. If a shareholder vote on the
business combination is not held, the company must provide all
shareholders with the opportunity to redeem their shares for cash
equal to their pro rata share of the aggregate amount then in the
deposit account (net of taxes payable and amounts distributed to
management for working capital purposes). See Nasdaq IM-5101-2(e).
\15\ Nasdaq has three listing tiers, each of which require,
among other things, a company to have a minimum number of
shareholders in order to initially list on the Exchange. See Nasdaq
Rule 5315 (f)(1) (on Global Select, an issuer must have at least 550
Total Holders with a minimum average monthly trading volume over the
prior 12 months, 2,200 Total Holders, or 450 Round Lot Holders with
50% of holders holding Unrestricted Securities); Nasdaq Rule
5405(a)(3) (on Global, an issuer must have at least 400 Round Lot
Holders with 50% of holders holding Unrestricted Securities); and
Nasdaq Rule 5505(a)(3) (on Capital, an issuer must have at least 300
Round Lot Holders with at least 50% of holders holding Unrestricted
Securities.
\16\ See Nasdaq IM-5101-2(d).
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In its proposal, Nasdaq acknowledges that its existing rules
require that, ``following each business combination'' with a SPAC, the
resulting company must satisfy all initial listing requirements. Nasdaq
states, however, that the rule does not provide a timetable for the
company to demonstrate that it satisfies those requirements.
Accordingly, Nasdaq proposes to modify the rule to specify if the SPAC
demonstrates that it will satisfy all requirements except the
applicable Shareholder Requirement, then the SPAC will receive 15
calendar days following the closing to demonstrate that it satisfied
the applicable Shareholder Requirement immediately following the
transaction's closing. In addition, Nasdaq proposes to require that a
company relying on this 15-day grace period publicly announce, prior to
the business combination, on a Form 8-K, where required by SEC rules,
or by issuing a press release, that it has not yet demonstrated
compliance with the Shareholder Requirement and is subject to delisting
if it cannot do so within the requisite time frame.\17\ Finally, Nasdaq
proposes to halt trading in the securities if the company fails to make
this public announcement.\18\
---------------------------------------------------------------------------
\17\ See Notice II of Amendment No. 1, supra note 8.
\18\ See id.
---------------------------------------------------------------------------
Nasdaq states that it ordinarily determines compliance with the
Shareholder Requirement at the time of a business combination by
reviewing a company's public disclosures and information provided by
the company about the transaction.\19\ According to Nasdaq, if it
cannot determine compliance using public information, it will typically
request the company to provide additional information such as
registered shareholder lists from the company's transfer agent, data
from Cede & Co. about shares held in street name, or data from broker-
dealers and third parties that distribute information such as proxy
materials for the broker-dealers. If the company can provide
information demonstrating compliance before the business combination
closes, Nasdaq states that no further information would be required.
---------------------------------------------------------------------------
\19\ Nasdaq states, for example, that the merger agreement may
result in the Acquisition Company issuing a round lot of shares to
more than 300 holders of the target of the business combination at
closing.
---------------------------------------------------------------------------
However, Nasdaq states that it has observed that in some cases it
can be difficult for a company to obtain evidence demonstrating the
number of shareholders that it has or will have following a business
combination. Nasdaq states that shareholders in a SPAC may redeem or
tender their shares until just before the time of the business
combination, and the SPAC may not know how many shareholders will
choose to redeem until very close to the consummation of the business
combination.\20\ Nasdaq states that this could impact its ability to
determine compliance before the business combination closes, in cases
where the number of round lot shareholders is close to the applicable
requirement.
---------------------------------------------------------------------------
\20\ The Exchange notes that SPACs are unlike other newly
listing companies which do not face redemptions and are not already
listed and trading at the time they must demonstrate compliance.
---------------------------------------------------------------------------
Nasdaq states that under its proposal the SPAC must still
demonstrate that it satisfied the round lot shareholder requirement
immediately following the business combination, and that the proposal
merely would give the SPAC 15 calendar days to provide evidence that it
had met the Shareholder Requirement. Nasdaq also states that it
believes that the proposed public disclosure requirement will help
provide transparency to investors about the status of the company
during the additional time period it has to evidence
[[Page 28409]]
compliance with the Shareholder Requirement.\21\
---------------------------------------------------------------------------
\21\ See Notice II of Amendment No. 1, supra note 8.
---------------------------------------------------------------------------
Nasdaq believes that the proposal ``balances the burden placed on
the Acquisition Company to obtain accurate shareholder information for
the new entity and the need to ensure that a company that does not
satisfy the initial listing requirements following a business
combination enters the delisting process promptly.'' \22\ Nasdaq states
that if the company does not evidence compliance within the proposed
time period, Nasdaq staff would issue a Staff Delisting Determination,
which the company could then appeal to an independent hearings
panel.\23\
---------------------------------------------------------------------------
\22\ The Exchange also states that shareholders of the SPAC
would be harmed if Nasdaq issued a delisting determination at a time
when the company did, in fact, satisfy all initial listing
requirements but could not yet provide proof.
\23\ The Exchange has also proposed to eliminate a duplicative
paragraph and add a new subsection enumeration to its existing rule.
---------------------------------------------------------------------------
The Commission received two comment letters opposing the proposal
from the Council of Institutional Investors.\24\ The commenter stated
that additional information from Nasdaq in response to the OIP would be
helpful in determining whether the proposed rule change is consistent
with the Exchange Act, and questioned whether a loosening of SPAC
listing standards is consistent with the protection of investors and
the public interest.\25\ More broadly, the commenter referenced a
recent study that it believes finds that SPACs and their officers and
directors face limited liability to investors for material
misstatements in, or omissions from, their registration statements, and
that SPAC structures generally create losses for long-term
investors.\26\ Finally, the commenter referenced the study's suggestion
that the regulatory treatment for SPACs should be generally equivalent
to that for direct listings and questioned whether Nasdaq's proposal
would lead to a pro-SPAC bias.\27\ The Exchange responded to CII Letter
I that the proposal would not loosen SPAC listing standards because
under its proposal SPACs would still have to comply with the
Shareholder Requirement at the time of the business combination and
would just be provided an additional 15 days after completing their
business combination to demonstrate such compliance.\28\ The Exchange
further stated that its proposal will provide transparency and does not
pose any additional risk to the protection of shareholders.\29\
---------------------------------------------------------------------------
\24\ See Letter from Jeffrey P. Mahoney, General Counsel,
Council of Institutional Investors (January 7, 2021) (``CII Letter
I''); Letter from Jeffrey P. Mahoney, General Counsel, Council of
Institutional Investors (March 25, 2021) (``CII Letter II'').
\25\ See CII Letter I, supra note 24.
\26\ Id.
\27\ See CII Letter II, supra note 24.
\28\ See Letter from Arnold Golub, Vice President and Deputy
General Counsel, (February 25, 2021) (``Nasdaq Letter'').
\29\ Id.
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III. Discussion and Commission Findings
The Commission must consider whether Nasdaq's proposal is
consistent with the Exchange Act and the rules and regulations
thereunder applicable to a national securities exchange, including
Section 6(b)(5) of the Exchange Act, which requires, in relevant part,
that the rules of a national securities exchange be designed ``to
prevent fraudulent and manipulative acts and practices'' and ``to
protect investors and the public interest.'' \30\ Under the
Commission's Rules of Practice, the ``burden to demonstrate that a
proposed rule change is consistent with the Exchange Act and the rules
and regulations issued thereunder . . . is on the self-regulatory
organization [`SRO'] that proposed the rule change.'' \31\
---------------------------------------------------------------------------
\30\ 15 U.S.C. 78f(b)(5). Pursuant to Section 19(b)(2) of the
Exchange Act, 15 U.S.C. 78s(b)(2), the Commission must disapprove a
proposed rule change filed by a national securities exchange if it
does not find that the proposed rule change is consistent with the
applicable requirements of the Exchange Act. Exchange Act Section
6(b)(5) states that an exchange shall not be registered as a
national securities exchange unless the Commission determines that
``[t]he rules of the exchange are designed to prevent fraudulent and
manipulative acts and practices, to promote just and equitable
principles of trade, to foster cooperation and coordination with
persons engaged in regulating, clearing, settling, processing
information with respect to, and facilitating transactions in
securities, 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 are not designed
to permit unfair discrimination between customers, issuers, brokers,
or dealers, or to regulate by virtue of any authority conferred by
this title matters not related to the purposes of this title or the
administration of the exchange.'' 15 U.S.C. 78(f)(b)(5).
\31\ Rule 700(b)(3), Commission Rules of Practice, 17 CFR
201.700(b)(3).
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The description of a proposed rule change, its purpose and
operation, its effect, and a legal analysis of its consistency with
applicable requirements must all be sufficiently detailed and specific
to support an affirmative Commission finding,\32\ and any failure of an
SRO to provide this information may result in the Commission not having
a sufficient basis to make an affirmative finding that a proposed rule
change is consistent with the Exchange Act and the applicable rules and
regulations.\33\ Moreover, ``unquestioning reliance'' on an SRO's
representations in a proposed rule change is not sufficient to justify
Commission approval of a proposed rule change.\34\
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\32\ See id.
\33\ See id.
\34\ Susquehanna Int'l Group, LLP v. Securities and Exchange
Commission, 866 F.3d 442, 447 (D.C. Cir. 2017).
---------------------------------------------------------------------------
The Commission has consistently recognized the importance of the
minimum number of holders and other similar requirements stating that
such listing standards help ensure that exchange listed securities have
sufficient public float, investor base, and trading interest to provide
the depth and liquidity necessary to promote fair and orderly
markets.\35\ The Shareholder Requirement also helps to ensure that
trading in exchange-listed securities is not susceptible to
manipulation.\36\
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\35\ The Commission considers distribution standards, including
minimum number of holders and number of shares outstanding
requirements, to be important means of promoting fair and orderly
markets. See, e.g., Securities Exchange Act Release No. 57785 (May
6, 2008), 73 FR 27597 (May 13, 2008) (SR-NYSE-2008-17) (stating that
the distribution standards, which includes exchange holder
requirements ``. . . should help to ensure that the [Acquisition
Companies'] securities have sufficient public float, investor base,
and liquidity to promote fair and orderly markets''); Securities
Exchange Act Release No. 86117 (June 14, 2019), 84 FR 28879 (June
20, 2018) (SR-NYSE-2018-46) (disapproving a proposal to reduce the
minimum number of public holders continued listing requirement
applicable to Acquisition Companies from 300 to 100).
\36\ See, e.g., Securities Exchange Act Release Nos. 91236
(March 2, 2021), 86 FR 13414 (March 8, 2021) (SR-NYSEArca-2020-56)
and 90819 (December 29, 2020), 86 FR 332 (January 5, 2021) (SR-
CboeBZX-2020-036).
---------------------------------------------------------------------------
As discussed above, Nasdaq is proposing to: (1) Allow a SPAC 15
calendar days following the closing of a business combination to
demonstrate that it satisfied the applicable Shareholder Requirement
immediately following the transaction's closing, and (2) require a SPAC
relying on the additional 15 day period to publicly announce, prior to
the listing of the combined company, that it has not demonstrated
compliance with the Shareholder Requirement and is subject to delisting
if it cannot do so within the requisite time period. Nasdaq states that
it can be difficult for a SPAC to obtain evidence demonstrating the
number of holders the SPAC will have following its business combination
because SPAC shareholders have the right to redeem or tender their
shares until just before the time of such business combination.
Further, Nasdaq states that, given the uncertainty around the number of
redemptions and ongoing trading through the closing of the business
combination, it may not be possible for
[[Page 28410]]
the SPAC to definitively establish that it will satisfy the Shareholder
Requirement before completing the combination. In addition, Nasdaq
states that, while other companies cannot become listed until they
demonstrate compliance with the Shareholder Requirement, SPACs
completing business combinations are already listed and, without more
time, would be the only type of company to face immediate delisting as
a result of these difficulties. Finally, Nasdaq states that 21 of the
49 SPAC business combinations processed by Nasdaq during 2019 and 2020
needed additional time to demonstrate compliance with the Shareholder
Requirement.
Nasdaq emphasizes that, under its proposal, the SPAC must still
demonstrate that it satisfied the applicable Shareholder Requirement
immediately following the business combination, and is simply being
provided 15 calendar days to provide evidence that it did. However,
Nasdaq has not explained the extent to which the 21 SPACs that needed
additional time to demonstrate compliance in 2019 and 2020 actually
were in compliance with the shareholder requirement immediately
following the closing of the business combination, or instead were not
in compliance and needed additional time to acquire the requisite
number of shareholders. If the former, Nasdaq has not explained why,
like newly-listed companies in advance of their public offerings, the
SPAC could not provide preliminary evidence of its compliance with the
Shareholder Requirement in advance of the business combination, or why
last minute shareholder redemptions would impact that evidence. If the
latter, then the SPACs in fact were not in compliance with the
Shareholder Requirement at the time of the business combination, and do
not provide support for Nasdaq's proposal, which is premised on the
assumption that such SPACs simply needed additional time to evidence
their compliance.
More broadly, Nasdaq does not explain how its proposal addresses
the regulatory risks to fair and orderly markets, investor protection
and the public interest, and the manipulation concerns if companies
initially list, and can continue to trade, on the Exchange without
meeting the Shareholder Requirement. Notably, and as discussed in the
OIP, Nasdaq has not addressed the risk that, by waiting for SPACs to
demonstrate compliance with the Shareholder Requirement until after the
closing of the business combination, non-compliant companies could be
listed on the Exchange despite not meeting initial listing standards,
and have their securities continue to trade until the delisting process
has been completed. In such circumstances, a SPAC could complete a
business combination and very soon thereafter be subject to delisting
proceedings, and during such time its securities may continue to trade
with a number of holders that is substantially less than the required
minimum raising concerns about the maintenance of fair and orderly
markets and investor protection.
While Nasdaq has amended its proposal to require certain public
disclosure, the Commission does not believe the disclosure required by
the proposed rule adequately addresses the potential risks associated
with trading during a time period in which the minimum number of round
lot shareholders may not be present, nor has Nasdaq explained why
subjecting shareholders to this potential risk is consistent with the
protection of investors and the public interest, and the other
requirements of Section 6(b)(5) of the Exchange Act.\37\
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\37\ The Commission notes that the commenter continued to oppose
the proposal after Nasdaq amended it to require this public
disclosure. See CII Letter II, supra note 24.
---------------------------------------------------------------------------
As stated above, under the Commission's Rules of Practice, the
``burden to demonstrate that a proposed rule change is consistent with
the Exchange Act and the rules and regulations issued thereunder . . .
is on the self-regulatory organization [`SRO'] that proposed the rule
change.'' \38\ The description of a proposed rule change, its purpose
and operation, its effect, and a legal analysis of its consistency with
applicable requirements must all be sufficiently detailed and specific
to support an affirmative Commission finding, and any failure of an SRO
to provide this information may result in the Commission not having a
sufficient basis to make an affirmative finding that a proposed rule
change is consistent with the Exchange Act and the applicable rules and
regulations.\39\ For the reasons discussed above, the Commission
concludes that, because Nasdaq has not demonstrated that its proposal
is designed to prevent fraudulent and manipulative acts and practices
or to protect investors and the public interest, Nasdaq has not met its
burden to demonstrate that its proposal is consistent with the
requirements of the Exchange Act and the rules and regulations
thereunder applicable to a national securities exchange, and in
particular Section 6(b)(5) of the Exchange Act.\40\ For this reason,
the Commission must disapprove the proposal.
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\38\ Rule 700(b)(3), Commission Rules of Practice, 17 CFR
201.700(b)(3).
\39\ See id.
\40\ In disapproving this proposed rule change, the Commission
has considered the proposed rule's impact on efficiency,
competition, and capital formation. See 15 U.S.C. 78c(f).
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IV. Conclusion
For the reasons set forth above, the Commission does not find,
pursuant to Section 19(b)(2) of the Exchange Act,\41\ that the proposed
rule change is consistent with the requirements of the Exchange Act and
the rules and regulations thereunder applicable to a national
securities exchange, and in particular, with Section 6(b)(5) of the
Exchange Act.\42\
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\41\ 15 U.S.C. 78s(b)(2).
\42\ 15 U.S.C. 78f(b)(5).
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It is therefore ordered, pursuant to Section 19(b)(2) of the
Exchange Act, that proposed rule change SR-Nasdaq-2020-062 is
disapproved.
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\43\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\43\
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021-11099 Filed 5-25-21; 8:45 am]
BILLING CODE 8011-01-P