Self-Regulatory Organizations; New York Stock Exchange LLC; Order Granting Approval of Proposed Rule Change, as Modified by Amendment Nos. 2 and 3, To Amend Its Rules To Prohibit Member Organizations From Seeking Reimbursement, in Certain Circumstances, From Issuers for Forwarding Proxy and Other Materials to Beneficial Owners, 46733-46737 [2021-17760]
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Federal Register / Vol. 86, No. 158 / Thursday, August 19, 2021 / Notices
a barrier to entry to smaller participants
and notes that the proposed pricing
structure for is associated with relative
usage of the various market participants.
Firms that are primarily order routers
seeking best-execution do not utilize
Limited Service MEI Ports on MIAX
Emerald and therefore will not pay the
fees associated with the tiered-pricing
structure. Rather, the fees described in
the proposed tiered-pricing structure
will only be allocated to market making
firms that engage in advanced trading
strategies and typically request multiple
Limited Service MEI Ports. Accordingly,
the firms engaged in market making
business generate higher costs by
utilizing more of the Exchange’s
resources. The market making firms that
purchase higher amounts of Limited
Service MEI Ports tend to have specific
business oriented market making and
taking strategies, as opposed to firms
simply engaging in best-execution order
routing business. Additionally, the use
of such additional Limited Service MEI
Ports is entirely voluntary.
The Exchange also does not believe
that the proposed rule change will result
in any burden on inter-market
competition that is not necessary or
appropriate in furtherance of the
purposes of the Act. As discussed
above, options market participants are
not forced to access all options
exchanges. The Exchange operates in a
highly competitive environment, and as
discussed above, its ability to price
access and ports is constrained by
competition among exchanges and third
parties. There are other options markets
of which market participants may access
in order to trade options. There is also
a possible range of alternative strategies,
including routing to the exchange
through another participant or market
center or accessing the Exchange
indirectly. For example, there are 15
other U.S. options exchanges, which the
Exchange must consider in its pricing
discipline in order to compete for
market participants. In this competitive
environment, market participants are
free to choose which competing
exchange to use to satisfy their business
needs. As a result, the Exchange
believes this proposed rule change
permits fair competition among national
securities exchanges. Accordingly, the
Exchange does not believe its proposed
fee changes impose any burden on
competition that is not necessary or
appropriate in furtherance of the
purposes of the Act.
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C. Self-Regulatory Organization’s
Statement on Comments on the
Proposed Rule Change Received From
Members, Participants, or Others
Written comments were neither
solicited nor received.
III. Date of Effectiveness of the
Proposed Rule Change and Timing for
Commission Action
The foregoing rule change has become
effective pursuant to Section
19(b)(3)(A)(ii) of the Act,27 and Rule
19b–4(f)(2) 28 thereunder. At any time
within 60 days of the filing of the
proposed rule change, the Commission
summarily may temporarily suspend
such rule change if it appears to the
Commission that such action is
necessary or appropriate in the public
interest, for the protection of investors,
or otherwise in furtherance of the
purposes of the Act. If the Commission
takes such action, the Commission shall
institute proceedings to determine
whether the proposed rule should be
approved or disapproved.
IV. Solicitation of Comments
Interested persons are invited to
submit written data, views, and
arguments concerning the foregoing,
including whether the proposed rule
change is consistent with the Act.
Comments may be submitted by any of
the following methods:
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–
EMERALD–2021–25 on the subject line.
Paper Comments
• Send paper comments in triplicate
to Secretary, Securities and Exchange
Commission, 100 F Street NE,
Washington, DC 20549–1090.
All submissions should refer to File
Number SR–EMERALD–2021–25. This
file number should be included on the
subject line if email is used. To help the
Commission process and review your
comments more efficiently, please use
only one method. The Commission will
post all comments on the Commission’s
internet website (https://www.sec.gov/
rules/sro.shtml). Copies of the
submission, all subsequent
amendments, all written statements
with respect to the proposed rule
change that are filed with the
Commission, and all written
communications relating to the
proposed rule change between the
Commission and any person, other than
those that may be withheld from the
public in accordance with the
provisions of 5 U.S.C. 552, will be
available for website viewing and
printing in the Commission’s Public
Reference Room, 100 F Street NE,
Washington, DC 20549, on official
business days between the hours of
10:00 a.m. and 3:00 p.m. Copies of the
filing also will be available for
inspection and copying at the principal
office of the Exchange. 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–EMERALD–2021–25 and
should be submitted on or before
September 9, 2021.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.29
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021–17759 Filed 8–18–21; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–92667; File No. SR–NYSE–
2020–98]
Self-Regulatory Organizations; New
York Stock Exchange LLC; Order
Granting Approval of Proposed Rule
Change, as Modified by Amendment
Nos. 2 and 3, To Amend Its Rules To
Prohibit Member Organizations From
Seeking Reimbursement, in Certain
Circumstances, From Issuers for
Forwarding Proxy and Other Materials
to Beneficial Owners
August 13, 2021.
I. Introduction
On November 30, 2020, New York
Stock Exchange LLC (‘‘NYSE’’ or
‘‘Exchange’’) filed with the Securities
and Exchange Commission (‘‘SEC’’ or
‘‘Commission’’), pursuant to Section
19(b)(1) of the Securities Exchange Act
of 1934 (‘‘Act’’) 1 and Rule 19b–4
thereunder,2 a proposed rule change to
amend its rules to prohibit member
organizations from seeking
reimbursement, in certain
circumstances, from issuers for
29 17
27 15
U.S.C. 78s(b)(3)(A)(ii).
28 17 CFR 240.19b–4(f)(2).
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46733
CFR 200.30–3(a)(12).
U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
1 15
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forwarding proxy and other materials to
beneficial owners. The proposed rule
change was published for comment in
the Federal Register on December 18,
2020.3 On January 29, 2021, pursuant to
Section 19(b)(2) of the Act,4 the
Commission designated a longer period
within which to either approve the
proposed rule change, disapprove the
proposed rule change, or institute
proceedings to determine whether to
disapprove the proposed rule change.5
On March 17, 2021, the Commission
instituted proceedings under Section
19(b)(2)(B) of the Act 6 to determine
whether to approve or disapprove the
proposed rule change.7 On April 6,
2021, the Exchange filed Amendment
No. 1 to the proposed rule change; the
Exchange withdrew that amendment on
April 16, 2021. On April 16, 2021, the
Exchange filed Amendment No. 2 to the
proposed rule change, which
superseded the proposed rule change as
originally filed. The proposed rule
change, as modified by Amendment No.
2, was published for comment in the
Federal Register on April 29, 2021.8 On
June 11, 2021, the Commission
designated a longer period for
Commission action on proceedings to
determine whether to approve or
disapprove the proposed rule change.9
On June 22, 2021, the Exchange filed
partial Amendment No. 3 to the
proposed rule change.10 This order
3 See Securities Exchange Act Release No. 90653
(December 14, 2020), 85 FR 82539 (December 18,
2020) (‘‘Original Notice’’). Comments received on
the proposal are available on the Commission’s
website at: https://www.sec.gov/comments/sr-nyse2020-98/srnyse202098.htm.
4 15 U.S.C. 78s(b)(2).
5 See Securities Exchange Act Release No. 91011
(January 29, 2021), 86 FR 8246 (February 4, 2021).
6 15 U.S.C. 78s(b)(2)(B).
7 See Securities Exchange Act Release No. 91343
(March 17, 2021), 86 FR 15536 (March 23, 2021)
(‘‘Order Instituting Proceedings’’).
8 See Securities Exchange Act Release No. 91663
(April 23, 2021), 86 FR 22725 (April 29, 2021)
(‘‘Amendment No. 2’’).
9 See Securities Exchange Act Release No. 92155
(June 11, 2021), 86 FR 32302 (June 17, 2021).
10 In Amendment No. 3, the Exchange stated that
proposed Rule 451A, in specifically stating that no
‘‘fee’’ shall be imposed, is meant to apply to the
charges that are specified in Rule 451, and would
not limit a member organization’s eligibility to
receive reimbursement for other expenses that are
not covered by the specified charges, namely (i)
actual postage costs (including return postage at the
lowest available rate); (ii) the actual cost of
envelopes (provided they are not furnished by the
person soliciting proxies); and (iii) any actual
communication expenses (excluding overhead)
incurred in receiving voting returns either
telephonically or electronically. The Exchange
further stated that this approach is consistent with
the application of existing fee exclusions under
Rule 451. Because Amendment No. 3 does not
materially alter the substance of the proposed rule
change, Amendment No. 3 is not subject to notice
and comment. The full text of Amendment No. 3
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17:28 Aug 18, 2021
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approves the proposed rule change, as
modified by Amendment Nos. 2 and 3.
II. Description of the Proposal, as
Modified by Amendment Nos. 2 and 3
NYSE Rules (‘‘Rule’’) 451 and 465
require NYSE member organizations
that hold securities for beneficial
owners in street name to solicit proxies
from, and deliver proxy and other
materials to, beneficial owners on behalf
of issuers.11 For this service, issuers
reimburse NYSE member organizations
for out-of-pocket, reasonable clerical,
postage, and other expenses incurred for
a particular distribution.12 This
reimbursement structure stems from
Rules 14b–1 and 14b–2 under the Act,13
which impose obligations on issuers
and nominees to ensure that beneficial
owners receive proxy materials. These
rules require issuers to send their proxy
materials to broker-dealers or banks that
hold securities in street name, for
forwarding to beneficial owners, and to
pay nominees for reasonable expenses,
both direct and indirect, incurred in
providing proxy information to
beneficial owners.14 The Commission’s
rules do not specify the fees that
nominees can charge issuers for proxy
distribution; rather, they state that
issuers must reimburse the nominees for
‘‘reasonable expenses’’ incurred.15
The Exchange has proposed to adopt
Rule 451A, pursuant to which,
notwithstanding the applicable
provisions of Rules 451 or 465 or what
may be permitted by the rules of any
other national securities exchange or
national securities association of which
a member organization is also a
is available on the Commission’s website at: https://
www.sec.gov/comments/sr-nyse-2020-98/
srnyse202098-8944033-245707.pdf.
11 See Rules 451 and 465; Amendment No. 2,
supra note 8, 86 FR at 22726. The ownership of
shares in street name means that a shareholder, or
‘‘beneficial owner,’’ has purchased shares through
a broker-dealer or bank, also known as a
‘‘nominee.’’ In contrast to direct ownership, where
shares are directly registered in the name of the
shareholder, shares held in street name are
registered in the name of the nominee, or in the
nominee name of a depository, such as the
Depository Trust Company. See Securities
Exchange Act Release No. 70720 (October 18, 2013),
78 FR 63530, 63531 n.14 (October 24, 2013) (order
approving SR–NYSE–2013–07) (‘‘2013 Approval
Order’’).
12 See Rules 451 and 465; 2013 Approval Order,
supra note 11, 78 FR at 63531.
13 17 CFR 240.14b–1; 17 CFR 240.14b–2.
14 See 17 CFR 240.14b–1 and 14b–2; see also 2013
Approval Order, supra note 11, 78 FR at 63531.
15 See 17 CFR 240.14b–1 and 14b–2; see also 2013
Approval Order, supra note 11, 78 FR at 63531.
Currently, the Supplementary Material to Rule 451,
which is cross-referenced by the Supplementary
Material to Rule 465, establishes maximum rates at
which a NYSE member organization may be
reimbursed for expenses incurred in connection
with distributing proxy and other materials to
beneficial owners.
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member, no fee shall be imposed for a
nominee account that contains only
shares or units of the securities involved
that were transferred to the account
holder by the member organization at no
cost.16
According to the Exchange, the
proposed rule is meant to address a
recent practice in which retail brokers
provide customers, without charge, a
small number of shares with a very
small dollar value as a commercial
incentive (for example, upon opening a
new account or referring a new
customer to the broker).17 The Exchange
stated that Rule 451 does not
distinguish between these beneficial
owners and beneficial owners that have
paid for their shares, so brokers are
required to solicit proxies from these
accounts and are entitled to
reimbursement of their expenses under
NYSE and other self-regulatory
organization rules.18 The Exchange
further stated that, in certain cases, the
issuer can experience a significant
increase in its distribution
reimbursement expenses solely due to
its shares being included in these broker
promotional schemes.19
The Exchange believes that it would
be more appropriate for the broker to
bear the proxy distribution costs in
these circumstances.20 According to the
Exchange, while the distribution of
shares in these broker promotions may
result in a significant increase in the
number of beneficial owners of an
issuer’s stock, the generally very small
size of each of these positions means
that they usually represent a very small
percentage of the voting power.21 As
such, according to the Exchange, the
costs the issuer incurs in reimbursing
the broker for distributing proxies to
these accounts is disproportionate to the
16 See proposed Rule 451A. None of the fees in
the schedule in the Supplementary Material .90 to
Rule 451 would be imposable on issuers in these
circumstances, but issuers would still be
responsible for reimbursing member organizations
for any actual postage costs, envelope costs, and
communication expenses (excluding overhead)
incurred in receiving voting returns, which is
consistent with what occurs currently in other
contexts where no fees are imposed, i.e., a managed
account that contains five or fewer shares or units
of the security involved or an account that contains
only a fractional share. See Amendment No. 3,
supra note 10. Accordingly, references herein to the
distribution costs or expenses for which member
organizations are prohibited from seeking
reimbursement from issuers under the proposal are
meant to refer to the charges specified in
Supplementary Material .90 to Rule 451.
17 See Amendment No. 2, supra note 8, 86 FR at
22726.
18 See id.; see also, e.g., FINRA Rule 2251.
19 See Amendment No. 2, supra note 8, 86 FR at
22726.
20 See id.
21 See id.
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maximum potential vote such shares
represent.22 The Exchange stated that,
by contrast, the broker using such a
scheme chooses to engage in it because
it believes that it will result in a
commercial benefit to the broker.23 In
addition, the Exchange stated that
recipients of shares without charge from
the broker as part of such schemes
typically will not be given any choice as
to which shares they receive and are
therefore not making any investment
decision.24
The Exchange stated that proposed
Rule 451A would not limit a broker’s
right to reimbursement for distributions
to any beneficial owner if any part of
that beneficial owner’s position in an
issuer’s securities was received by any
means other than a transfer without
charge from the broker.25 The Exchange
also stated that proposed Rule 451A
would not limit a broker’s right to
receive reimbursement under Rules 451
and 465 unless that broker itself
transferred the issuer’s shares without
charge into the account of the beneficial
owner.26 The Exchange further stated
that Rules 451 and 465 would continue
to apply to all distributions, so the
broker would continue to be fully
obligated to solicit votes from, and make
other distributions on behalf of issuers
to, all beneficial owners
notwithstanding the limitations on
reimbursement of expenses imposed by
proposed Rule 451A.27
III. Discussion and Commission
Findings
After careful review, the Commission
finds that the proposed rule change, as
modified by Amendment Nos. 2 and 3,
is consistent with the requirements of
the Act and the rules and regulations
thereunder.28 In particular, the
Commission finds that the proposed
rule change, as modified by Amendment
Nos. 2 and 3, is consistent with Section
6(b)(4) of the Act,29 which requires that
an exchange have rules that provide for
the equitable allocation of reasonable
dues, fees, and other charges among its
members, issuers, and other persons
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22 See
id.
23 See id.
24 See id., 86 FR at 22727.
25 See id., 86 FR at 22726.
26 See id. Specifically, the Exchange stated that if
a beneficial owner transferred shares received in
this manner into an account at another broker, Rule
451A would not preclude that other broker from
claiming reimbursement under Rules 451 and 465.
27 See id.
28 In approving this proposed rule change, as
modified by Amendment Nos. 2 and 3, the
Commission has considered the proposed rule’s
impact on efficiency, competition, and capital
formation. See 15 U.S.C. 78c(f).
29 15 U.S.C. 78f(b)(4).
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using its facilities; and with Section
6(b)(5) of the Act,30 which requires,
among other things, that the rules of a
national securities exchange be
designed to prevent fraudulent and
manipulative acts and practices, to
promote just and equitable principles of
trade, to remove impediments to and
perfect the mechanism of a free and
open market and a national market
system, and, in general, to protect
investors and the public interest, and
not be designed to permit unfair
discrimination between customers,
issuers, brokers, or dealers. The
Commission also believes that the
proposal as modified is consistent with
Rule 14b–1 under the Act.31
The Commission raised concerns
about the proposal in the Order
Instituting Proceedings,32 but the
Commission believes that the Exchange
has amended the proposal adequately to
address those concerns. Originally,
proposed Rule 451A would have
prohibited an NYSE member
organization from imposing distribution
fees on an issuer in cases where the
member provided the shares or units of
the securities held in the beneficial
owner’s account at no cost or at a price
‘‘substantially less than the market
price.’’ 33 In the Order Instituting
Proceedings, the Commission stated that
the Exchange did not explain how it
would determine whether a price is
‘‘substantially less than the market
price’’ or otherwise provide guidance on
the meaning of that term.34 In
Amendment No. 2, the Exchange
addressed the Commission’s concern by
eliminating that term from the proposed
rule, resulting in a rule with a more
clearly defined application to nominee
accounts that contain only shares or
units of the securities involved that
were transferred to the account holder
by the member at no cost.
The Commission also stated in the
Order Instituting Proceedings that the
initial proposal did not explain why it
is consistent with the Act for the
proposed reimbursement prohibition
not to apply if a customer transferred its
account to a new broker or held any
shares of the issuer in its account other
than those received through a belowmarket price transfer from the member
seeking reimbursement.35 Additionally,
the Commission stated that the initial
proposal did not address the feasibility
30 15
U.S.C. 78f(b)(5).
CFR 240.14b–1.
32 See Order Instituting Proceedings, supra note 7.
33 See Original Notice, supra note 3.
34 See Order Instituting Proceedings, supra note 7,
86 FR at 15537.
35 See id., 86 FR at 15537–38.
31 17
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46735
of tracking shares held by a particular
beneficial owner where the eligibility
for reimbursement may change over
time.36 The Exchange addressed these
concerns in Amendment No. 2 by
clarifying that it would be impossible
for the new broker in these
circumstances to track whether the
shares of a specific issuer transferred
into its custody had all been received by
the beneficial owner without charge
from another broker.37 In addition,
according to the Exchange, the new
broker would not have received the
same commercial benefit as the original
broker that transferred the shares
without charge to its customers.38 For
these reasons, the Exchange stated that
it is impracticable to extend the
proposed reimbursement prohibition to
the new broker and reasonable to limit
its application to the original broker that
transferred the shares without charge.39
Further, in the Order Instituting
Proceedings, the Commission stated that
the Exchange had not explained how
the proposal would be consistent with
Rule 14b–1 under the Act 40 in light of
the fact that a broker-dealer would be
required to distribute proxies or other
materials but be precluded from seeking
reimbursement of its expenses in the
applicable circumstances.41 In
Amendment No. 2, the Exchange stated
that any broker that is prohibited from
charging fees under the proposal would
continue to be reimbursed for its
aggregate expenses with respect to
proxy distribution, as the prohibition on
distribution fees would be limited to
those accounts in which the only shares
of the applicable issuer are shares
received without charge from that
broker.42 The Exchange stated that, as
such, the effect of the proposal would be
to reduce the overall reimbursement
received by that broker for a
distribution, but not to eliminate that
reimbursement.43
Commenters broadly supported the
proposal.44 One commenter stated that
36 See
37 See
id., 86 FR at 15538.
Amendment No. 2, supra note 8, 86 FR at
22726.
38 See id., 86 FR at 22726–27.
39 See id., 86 FR at 22727.
40 17 CFR 240.14b–1.
41 See Order Instituting Proceedings, supra note 7,
86 FR at 15538.
42 See Amendment No. 2, supra note 8, 86 FR at
22727.
43 See id.
44 See letters from: Paul Conn, President, Global
Capital Markets, Computershare, dated January 11,
2021 (‘‘First Computershare Letter’’), at 2–3; Niels
Holch, Executive Director, Shareholder
Communications Coalition, dated January 20, 2021
(‘‘Coalition Letter’’), at 5 n.14; Paul Conn, President,
Global Capital Markets, Computershare, dated April
14, 2021 (‘‘Second Computershare Letter’’), at 4;
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the recent broker practice of gifting
small amounts of securities to retail
brokerage clients as a promotional
measure has caused significant
increases in proxy costs for some
issuers, and expressed the view that the
proposal would alleviate much of the
cost impact to issuers from this broker
practice, particularly for accounts
defaulted to e-delivery.45 Two
commenters are issuers that stated that
they experienced dramatic increases in
proxy distribution costs for the 2020
proxy season, which they both
attributed to the inclusion of their
shares in a retail broker’s promotional
free share program.46 Both commenters
asserted that the issuer should not bear
the proxy distribution costs that arise
due to their shares being included in
such a broker promotional program.47
Kim Warnica, Senior Vice President, General
Counsel and Secretary, Marathon Oil Corporation,
dated April 27, 2021 (‘‘Marathon Letter’’); Patrick J.
McEnany, Chairman and CEO, Catalyst
Pharmaceuticals, Inc., dated June 9, 2021 (‘‘Catalyst
Letter’’). An additional commenter appears to
suggest that member organizations should be
reimbursed in certain circumstances that are not
covered by the proposal or the rules the proposal
is amending. See letter from David, dated June 14,
2021.
45 See First Computershare Letter at 2–3. This
commenter also stated that while it understood that
the accounts that receive such ‘‘gifted’’ securities
generally are set for electronic communications, as
a technical matter, if a street-name holder of gifted
securities receives hardcopy proxy communications
rather than electronic delivery, the issuer will still
bear increased costs from printing the materials to
be disseminated by the broker. See id. Even if an
issuer bears increased printing costs due to its
shares being included in a broker promotional
program, as discussed below, the Commission
believes that the proposal is consistent with the Act
because, among other things, the proposed rule’s
prohibition against imposing fees on issuers would
result in a more equitable and not unfairly
discriminatory reallocation to brokers of significant
costs typically associated with the distribution of
proxies and other materials in the circumstances
addressed by the proposal.
46 See Marathon Letter at 1–2; Catalyst Letter at
2. One of these commenters stated that its 2020
proxy distribution bill was 2,402 percent higher
than the 2019 bill, representing distribution to
3,051 percent more stockholders in 2020 than in
2019. See Marathon Letter at 1. The commenter
noted that as of its 2020 stockholder meeting date,
80 percent of the stockholders that held the
commenter’s shares through accounts at the
particular retail broker held five shares or less. See
id. The commenter believes that, for the vast
majority of the accounts holding fewer than five
shares, the shares were chosen by that retail broker,
not the beneficial owners. See id. at 2. Similarly,
the other issuer commenter stated that the number
of holders of its common shares who hold their
shares through that retail broker increased by more
than 2,057 percent from 2019 to 2020, and its proxy
distribution bill from the distribution platform that
services that retail broker grew 1,779 percent from
2019 to 2020 (from approximately $12,500 to
approximately $234,000). See Catalyst Letter at 1–
2. The commenter believes the increase in both
shareholders and costs is directly attributable to the
retail broker and its promotional activities. See id.
at 2.
47 See Marathon Letter at 2; Catalyst Letter at 2.
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Another commenter stated that the
promotions the proposed rule change is
designed to address provide commercial
benefits to broker-dealers without
providing any parallel benefits to public
companies.48
The Commission believes that the
proposal as modified is consistent with
Sections 6(b)(4) and 6(b)(5) of the Act,
as well as Rule 14b–1. The proposed
rule would appropriately reallocate
from an issuer to a broker the fee-related
expense of distributing proxy and other
materials to beneficial owners in the
limited circumstance where the
beneficial owner’s account contains
only shares or units of the issuer’s
securities that were transferred to the
beneficial owner by the broker at no
cost.49 This circumstance would appear
to arise typically due to a broker
promotional program that, as stated by
the Exchange, the broker chooses to
engage in because it believes it will
result in a commercial benefit to the
broker and, as noted by one
commenter,50 provides commercial
benefits to the broker without providing
any parallel benefits to the issuer.51 The
Commission therefore believes that the
proposal is reasonably designed to
result in a more equitable and not
unfairly discriminatory allocation of the
costs of the distribution of proxy and
other materials, consistent with Sections
6(b)(4) and 6(b)(5) of the Act.
The Commission also believes that the
proposal is consistent with the Section
6(b)(5) goal of protecting investors and
the public interest, and is consistent
with Rule 14b–1, because the cost
reallocation effectuated by the proposal
would not diminish brokers’ obligations
to distribute issuer materials to accounts
in which securities are held in street
name, including accounts covered by
the proposal, i.e., that contain only
shares or units of the securities involved
that were transferred to the account
holder by the member organization at no
cost. Moreover, this cost reallocation
48 See
Coalition Letter at 5 n.14.
supra note 25 and accompanying text.
50 See Coalition Letter at 5 n.14. See also Catalyst
Letter at 2.
51 One commenter stated that, if, after receiving
gifted shares, an investor subsequently chooses to
increase its share ownership and makes an
investment decision to buy additional shares, it
would be appropriate to shift the cost of proxy
distribution back to the issuer. See Marathon Letter
at 2. As stated above, the Exchange’s proposal
would affect accounts that only include shares that
were transferred to the account holder by the broker
at no cost, and accordingly, if a street name investor
were to be induced to purchase or otherwise
acquire any additional shares of the issuer as a
result of being gifted shares by a broker, the issuer
would then bear the proxy distribution costs for
that investor’s account. See supra note 25 and
accompanying text.
49 See
PO 00000
Frm 00064
Fmt 4703
Sfmt 4703
does not preclude the broker from
receiving assurance of reimbursement of
its ‘‘reasonable expenses,’’ both direct
and indirect, consistent with Rule 14b–
1. In previously approving, in 2013, an
Exchange proposal that, among other
things, eliminated fees for distributing
issuer materials to managed accounts
with five or fewer shares of the issuer’s
securities, the Commission
acknowledged that any general rule
setting forth an industry-wide fee
schedule for the reimbursement of
reasonable broker-dealer expenses
necessarily will not precisely reimburse
the actual expenses incurred by
individual firms.52 Here, a broker with
accounts covered by the proposal may
not receive precise reimbursement for
its expenses incurred for a distribution
pertaining to the issuer whose shares it
gave away at no cost, but the broker
would continue to be reasonably
reimbursed for its expenses, both direct
and indirect, in the aggregate.53 The
proposal would not eliminate a broker’s
ability to charge reimbursement fees for
distributing an issuer’s materials to
accounts that hold any shares or units
of the issuer’s securities that the
beneficial owner purchased or acquired
in any way other than from the broker
at no cost. Nor would the proposal affect
the broker’s ability to charge
reimbursement fees for distributing
materials on behalf of issuers whose
shares it did not give away at no cost.
Any shortfall in precise reimbursement
of expenses experienced by the broker
because of the proposal would be
confined to fee-related expenses
attributable to distributing an issuer’s
materials to beneficial owners that
receive those materials solely due to the
broker’s own promotional efforts.
Based on the foregoing, the
Commission finds that the proposed
rule change, as amended, is consistent
with the Act and the rules and
regulations thereunder.
52 See Rule 451, Supplementary Material .90;
2013 Approval Order, supra note 11, 78 FR at 63546
(stating that this rule with respect to managed
accounts was designed to provide reasonable
reimbursement of the overall expenses of brokerdealers in the aggregate, and the extent of
reimbursement of any individual firm would vary
depending on the specifics of its account
population). One commenter analogized the
scenario presented by this proposal to the
Exchange’s prior proposal to eliminate fees for
distributing issuer materials to managed accounts
with five or fewer shares of the issuer’s securities.
See Marathon Letter at 2.
53 As clarified in Amendment No. 3, supra note
10, issuers must reimburse brokers for any non-feerelated expenses—i.e., any actual, out-of-pocket
postage, envelope, and communication expenses
incurred in receiving voting returns—
notwithstanding the proposed rule.
E:\FR\FM\19AUN1.SGM
19AUN1
Federal Register / Vol. 86, No. 158 / Thursday, August 19, 2021 / Notices
IV. Conclusion
It is therefore ordered, pursuant to
Section 19(b)(2) of the Act,54 that the
proposed rule change (SR–NYSE–2020–
98), as amended by Amendment Nos. 2
and 3, be and hereby is approved.
For the Commission, by the Division of
Trading and Markets, pursuant to delegated
authority.55
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021–17760 Filed 8–18–21; 8:45 am]
BILLING CODE 8011–01–P
SECURITIES AND EXCHANGE
COMMISSION
[Release No. 34–92661; File No. SR–MIAX–
2021–37]
Self-Regulatory Organizations; Miami
International Securities Exchange LLC;
Notice of Filing and Immediate
Effectiveness of a Proposed Rule
Change To Amend Its Fee Schedule To
Adopt a Tiered-Pricing Structure for
Additional Limited Service MIAX
Express Interface Ports
August 13, 2021.
Pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934
(‘‘Act’’),1 and Rule 19b–4 thereunder,2
notice is hereby given that on August 2,
2021, Miami International Securities
Exchange LLC (‘‘MIAX’’ or ‘‘Exchange’’)
filed with the Securities and Exchange
Commission (‘‘Commission’’) a
proposed rule change as described in
Items I, II, and III below, which Items
have been prepared by the Exchange.
The Commission is publishing this
notice to solicit comments on the
proposed rule change from interested
persons.
lotter on DSK11XQN23PROD with NOTICES1
I. Self-Regulatory Organization’s
Statement of the Terms of Substance of
the Proposed Rule Change
The Exchange is filing a proposal to
amend the MIAX Options Fee Schedule
(the ‘‘Fee Schedule’’) to amend certain
port fees.
The text of the proposed rule change
is available on the Exchange’s website at
https://www.miaxoptions.com/rulefilings, at MIAX’s principal office, and
at the Commission’s Public Reference
Room.
54 15
U.S.C. 78s(b)(2).
CFR 200.30–3(a)(12).
1 15 U.S.C. 78s(b)(1).
2 17 CFR 240.19b–4.
55 17
VerDate Sep<11>2014
17:28 Aug 18, 2021
Jkt 253001
II. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
In its filing with the Commission, the
Exchange included statements
concerning the purpose of and basis for
the proposed rule change and discussed
any comments it received on the
proposed rule change. The text of these
statements may be examined at the
places specified in Item IV below. The
Exchange has prepared summaries, set
forth in sections A, B, and C below, of
the most significant aspects of such
statements.
A. Self-Regulatory Organization’s
Statement of the Purpose of, and
Statutory Basis for, the Proposed Rule
Change
1. Purpose
The Exchange proposes to amend the
Fee Schedule to adopt a tiered-pricing
structure for additional Limited Service
MIAX Express Interface (‘‘MEI’’) Ports 3
available to Market Makers.4 The
Exchange believes a tiered-pricing
structure will encourage Market Makers
to be more efficient and economical
when determining how to connect to the
Exchange. This should also enable the
Exchange to better monitor and provide
access to the Exchange’s network to
ensure sufficient capacity and headroom
in the System.5
Additional Limited Service MEI Port
Tiered-Pricing Structure
The Exchange proposes to amend the
fees for additional Limited Service MEI
Ports. Currently, the Exchange allocates
two (2) Full Service MEI Ports 6 and two
(2) Limited Service MEI Ports 7 per
3 MIAX Express Interface is a connection to MIAX
systems that enables Market Makers to submit
simple and complex electronic quotes to MIAX. See
Fee Schedule, note 26.
4 The term ‘‘Market Makers’’ refers to Lead Market
Makers (‘‘LMMs’’), Primary Lead Market Makers
(‘‘PLMMs’’), and Registered Market Makers
(‘‘RMMs’’) collectively. See Exchange Rule 100.
5 The term ‘‘System’’ means the automated
trading system used by the Exchange for the trading
of securities. See Exchange Rule 100.
6 Full Service MEI Ports provide Market Makers
with the ability to send Market Maker quotes,
eQuotes, and quote purge messages to the MIAX
System. Full Service MEI Ports are also capable of
receiving administrative information. Market
Makers are limited to two Full Service MEI Ports
per matching engine. See Fee Schedule, Section
5)d)ii), note 27.
7 Limited Service MEI Ports provide Market
Makers with the ability to send eQuotes and quote
purge messages only, but not Market Maker Quotes,
to the MIAX System. Limited Service MEI Ports are
also capable of receiving administrative
information. Market Makers initially receive two
Limited Service MEI Ports per matching engine. See
Fee Schedule, Section 5)d)ii), note 28.
PO 00000
Frm 00065
Fmt 4703
Sfmt 4703
46737
matching engine 8 to which each Market
Maker connects. Market Makers may
also request additional Limited Service
MEI Ports for each matching engine to
which they connect. The Full Service
MEI Ports, Limited Service MEI Ports
and the additional Limited Service MEI
Ports all include access to the
Exchange’s primary and secondary data
centers and its disaster recovery center.
Market Makers may request additional
Limited Service MEI Ports for which
they are assessed a $100 monthly fee for
each additional Limited Service MEI
Port for each matching engine. This fee
has been unchanged since 2016.9
The Exchange now proposes to move
from a flat monthly fee per additional
Limited Service MEI Port for each
matching engine to a tiered-pricing
structure per additional Limited Service
MEI Ports for each matching engine
under which the monthly fee would
vary depending on the number of
additional Limited Service MEI Ports
the Market Maker elects to purchase.
Specifically, the Exchange will continue
to provide the first and second
additional Limited Service MEI Ports for
each matching engine free of charge, as
described above, per the initial
allocation of Limited Service MEI Ports
that Market Makers receive.
Specifically, (i) the third and fourth
additional Limited Service MEI Ports for
each matching engine will increase from
the current flat monthly fee of $100 to
$150 per port; (ii) the fifth and sixth
additional Limited Service MEI Ports for
engine matching engine will increase
from the current flat monthly fee of
$100 to $200 per port; and (iii) the
seventh additional Limited Service MEI
Port, and each Limited Service MEI Port
for each matching engine purchased
thereafter, will increase from the current
monthly flat fee of $100 to $250 per port
(collectively, the ‘‘Proposed Access
Fees’’).
2. Statutory Basis
The Exchange believes that its
proposal to amend its Fee Schedule is
8 A ‘‘matching engine’’ is a part of the MIAX
electronic system that processes options quotes and
trades on a symbol-by-symbol basis. Some matching
engines will process option classes with multiple
root symbols, and other matching engines will be
dedicated to one single option root symbol (for
example, options on SPY will be processed by one
single matching engine that is dedicated only to
SPY). A particular root symbol may only be
assigned to a single designated matching engine. A
particular root symbol may not be assigned to
multiple matching engines. See Fee Schedule,
Section 5)d)ii), note 29.
9 See Securities Exchange Act Release No. 79666
(December 22, 2016), 81 FR 96133 (December 29,
2016) (SR–MIAX–2016–47).
E:\FR\FM\19AUN1.SGM
19AUN1
Agencies
[Federal Register Volume 86, Number 158 (Thursday, August 19, 2021)]
[Notices]
[Pages 46733-46737]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2021-17760]
-----------------------------------------------------------------------
SECURITIES AND EXCHANGE COMMISSION
[Release No. 34-92667; File No. SR-NYSE-2020-98]
Self-Regulatory Organizations; New York Stock Exchange LLC; Order
Granting Approval of Proposed Rule Change, as Modified by Amendment
Nos. 2 and 3, To Amend Its Rules To Prohibit Member Organizations From
Seeking Reimbursement, in Certain Circumstances, From Issuers for
Forwarding Proxy and Other Materials to Beneficial Owners
August 13, 2021.
I. Introduction
On November 30, 2020, New York Stock Exchange LLC (``NYSE'' or
``Exchange'') filed with the Securities and Exchange Commission
(``SEC'' or ``Commission''), pursuant to Section 19(b)(1) of the
Securities Exchange Act of 1934 (``Act'') \1\ and Rule 19b-4
thereunder,\2\ a proposed rule change to amend its rules to prohibit
member organizations from seeking reimbursement, in certain
circumstances, from issuers for
[[Page 46734]]
forwarding proxy and other materials to beneficial owners. The proposed
rule change was published for comment in the Federal Register on
December 18, 2020.\3\ On January 29, 2021, pursuant to Section 19(b)(2)
of the Act,\4\ the Commission designated a longer period within which
to either approve the proposed rule change, disapprove the proposed
rule change, or institute proceedings to determine whether to
disapprove the proposed rule change.\5\ On March 17, 2021, the
Commission instituted proceedings under Section 19(b)(2)(B) of the Act
\6\ to determine whether to approve or disapprove the proposed rule
change.\7\ On April 6, 2021, the Exchange filed Amendment No. 1 to the
proposed rule change; the Exchange withdrew that amendment on April 16,
2021. On April 16, 2021, the Exchange filed Amendment No. 2 to the
proposed rule change, which superseded the proposed rule change as
originally filed. The proposed rule change, as modified by Amendment
No. 2, was published for comment in the Federal Register on April 29,
2021.\8\ On June 11, 2021, the Commission designated a longer period
for Commission action on proceedings to determine whether to approve or
disapprove the proposed rule change.\9\ On June 22, 2021, the Exchange
filed partial Amendment No. 3 to the proposed rule change.\10\ This
order approves the proposed rule change, as modified by Amendment Nos.
2 and 3.
---------------------------------------------------------------------------
\1\ 15 U.S.C. 78s(b)(1).
\2\ 17 CFR 240.19b-4.
\3\ See Securities Exchange Act Release No. 90653 (December 14,
2020), 85 FR 82539 (December 18, 2020) (``Original Notice'').
Comments received on the proposal are available on the Commission's
website at: https://www.sec.gov/comments/sr-nyse-2020-98/srnyse202098.htm.
\4\ 15 U.S.C. 78s(b)(2).
\5\ See Securities Exchange Act Release No. 91011 (January 29,
2021), 86 FR 8246 (February 4, 2021).
\6\ 15 U.S.C. 78s(b)(2)(B).
\7\ See Securities Exchange Act Release No. 91343 (March 17,
2021), 86 FR 15536 (March 23, 2021) (``Order Instituting
Proceedings'').
\8\ See Securities Exchange Act Release No. 91663 (April 23,
2021), 86 FR 22725 (April 29, 2021) (``Amendment No. 2'').
\9\ See Securities Exchange Act Release No. 92155 (June 11,
2021), 86 FR 32302 (June 17, 2021).
\10\ In Amendment No. 3, the Exchange stated that proposed Rule
451A, in specifically stating that no ``fee'' shall be imposed, is
meant to apply to the charges that are specified in Rule 451, and
would not limit a member organization's eligibility to receive
reimbursement for other expenses that are not covered by the
specified charges, namely (i) actual postage costs (including return
postage at the lowest available rate); (ii) the actual cost of
envelopes (provided they are not furnished by the person soliciting
proxies); and (iii) any actual communication expenses (excluding
overhead) incurred in receiving voting returns either telephonically
or electronically. The Exchange further stated that this approach is
consistent with the application of existing fee exclusions under
Rule 451. Because Amendment No. 3 does not materially alter the
substance of the proposed rule change, Amendment No. 3 is not
subject to notice and comment. The full text of Amendment No. 3 is
available on the Commission's website at: https://www.sec.gov/comments/sr-nyse-2020-98/srnyse202098-8944033-245707.pdf.
---------------------------------------------------------------------------
II. Description of the Proposal, as Modified by Amendment Nos. 2 and 3
NYSE Rules (``Rule'') 451 and 465 require NYSE member organizations
that hold securities for beneficial owners in street name to solicit
proxies from, and deliver proxy and other materials to, beneficial
owners on behalf of issuers.\11\ For this service, issuers reimburse
NYSE member organizations for out-of-pocket, reasonable clerical,
postage, and other expenses incurred for a particular distribution.\12\
This reimbursement structure stems from Rules 14b-1 and 14b-2 under the
Act,\13\ which impose obligations on issuers and nominees to ensure
that beneficial owners receive proxy materials. These rules require
issuers to send their proxy materials to broker-dealers or banks that
hold securities in street name, for forwarding to beneficial owners,
and to pay nominees for reasonable expenses, both direct and indirect,
incurred in providing proxy information to beneficial owners.\14\ The
Commission's rules do not specify the fees that nominees can charge
issuers for proxy distribution; rather, they state that issuers must
reimburse the nominees for ``reasonable expenses'' incurred.\15\
---------------------------------------------------------------------------
\11\ See Rules 451 and 465; Amendment No. 2, supra note 8, 86 FR
at 22726. The ownership of shares in street name means that a
shareholder, or ``beneficial owner,'' has purchased shares through a
broker-dealer or bank, also known as a ``nominee.'' In contrast to
direct ownership, where shares are directly registered in the name
of the shareholder, shares held in street name are registered in the
name of the nominee, or in the nominee name of a depository, such as
the Depository Trust Company. See Securities Exchange Act Release
No. 70720 (October 18, 2013), 78 FR 63530, 63531 n.14 (October 24,
2013) (order approving SR-NYSE-2013-07) (``2013 Approval Order'').
\12\ See Rules 451 and 465; 2013 Approval Order, supra note 11,
78 FR at 63531.
\13\ 17 CFR 240.14b-1; 17 CFR 240.14b-2.
\14\ See 17 CFR 240.14b-1 and 14b-2; see also 2013 Approval
Order, supra note 11, 78 FR at 63531.
\15\ See 17 CFR 240.14b-1 and 14b-2; see also 2013 Approval
Order, supra note 11, 78 FR at 63531. Currently, the Supplementary
Material to Rule 451, which is cross-referenced by the Supplementary
Material to Rule 465, establishes maximum rates at which a NYSE
member organization may be reimbursed for expenses incurred in
connection with distributing proxy and other materials to beneficial
owners.
---------------------------------------------------------------------------
The Exchange has proposed to adopt Rule 451A, pursuant to which,
notwithstanding the applicable provisions of Rules 451 or 465 or what
may be permitted by the rules of any other national securities exchange
or national securities association of which a member organization is
also a member, no fee shall be imposed for a nominee account that
contains only shares or units of the securities involved that were
transferred to the account holder by the member organization at no
cost.\16\
---------------------------------------------------------------------------
\16\ See proposed Rule 451A. None of the fees in the schedule in
the Supplementary Material .90 to Rule 451 would be imposable on
issuers in these circumstances, but issuers would still be
responsible for reimbursing member organizations for any actual
postage costs, envelope costs, and communication expenses (excluding
overhead) incurred in receiving voting returns, which is consistent
with what occurs currently in other contexts where no fees are
imposed, i.e., a managed account that contains five or fewer shares
or units of the security involved or an account that contains only a
fractional share. See Amendment No. 3, supra note 10. Accordingly,
references herein to the distribution costs or expenses for which
member organizations are prohibited from seeking reimbursement from
issuers under the proposal are meant to refer to the charges
specified in Supplementary Material .90 to Rule 451.
---------------------------------------------------------------------------
According to the Exchange, the proposed rule is meant to address a
recent practice in which retail brokers provide customers, without
charge, a small number of shares with a very small dollar value as a
commercial incentive (for example, upon opening a new account or
referring a new customer to the broker).\17\ The Exchange stated that
Rule 451 does not distinguish between these beneficial owners and
beneficial owners that have paid for their shares, so brokers are
required to solicit proxies from these accounts and are entitled to
reimbursement of their expenses under NYSE and other self-regulatory
organization rules.\18\ The Exchange further stated that, in certain
cases, the issuer can experience a significant increase in its
distribution reimbursement expenses solely due to its shares being
included in these broker promotional schemes.\19\
---------------------------------------------------------------------------
\17\ See Amendment No. 2, supra note 8, 86 FR at 22726.
\18\ See id.; see also, e.g., FINRA Rule 2251.
\19\ See Amendment No. 2, supra note 8, 86 FR at 22726.
---------------------------------------------------------------------------
The Exchange believes that it would be more appropriate for the
broker to bear the proxy distribution costs in these circumstances.\20\
According to the Exchange, while the distribution of shares in these
broker promotions may result in a significant increase in the number of
beneficial owners of an issuer's stock, the generally very small size
of each of these positions means that they usually represent a very
small percentage of the voting power.\21\ As such, according to the
Exchange, the costs the issuer incurs in reimbursing the broker for
distributing proxies to these accounts is disproportionate to the
[[Page 46735]]
maximum potential vote such shares represent.\22\ The Exchange stated
that, by contrast, the broker using such a scheme chooses to engage in
it because it believes that it will result in a commercial benefit to
the broker.\23\ In addition, the Exchange stated that recipients of
shares without charge from the broker as part of such schemes typically
will not be given any choice as to which shares they receive and are
therefore not making any investment decision.\24\
---------------------------------------------------------------------------
\20\ See id.
\21\ See id.
\22\ See id.
\23\ See id.
\24\ See id., 86 FR at 22727.
---------------------------------------------------------------------------
The Exchange stated that proposed Rule 451A would not limit a
broker's right to reimbursement for distributions to any beneficial
owner if any part of that beneficial owner's position in an issuer's
securities was received by any means other than a transfer without
charge from the broker.\25\ The Exchange also stated that proposed Rule
451A would not limit a broker's right to receive reimbursement under
Rules 451 and 465 unless that broker itself transferred the issuer's
shares without charge into the account of the beneficial owner.\26\ The
Exchange further stated that Rules 451 and 465 would continue to apply
to all distributions, so the broker would continue to be fully
obligated to solicit votes from, and make other distributions on behalf
of issuers to, all beneficial owners notwithstanding the limitations on
reimbursement of expenses imposed by proposed Rule 451A.\27\
---------------------------------------------------------------------------
\25\ See id., 86 FR at 22726.
\26\ See id. Specifically, the Exchange stated that if a
beneficial owner transferred shares received in this manner into an
account at another broker, Rule 451A would not preclude that other
broker from claiming reimbursement under Rules 451 and 465.
\27\ See id.
---------------------------------------------------------------------------
III. Discussion and Commission Findings
After careful review, the Commission finds that the proposed rule
change, as modified by Amendment Nos. 2 and 3, is consistent with the
requirements of the Act and the rules and regulations thereunder.\28\
In particular, the Commission finds that the proposed rule change, as
modified by Amendment Nos. 2 and 3, is consistent with Section 6(b)(4)
of the Act,\29\ which requires that an exchange have rules that provide
for the equitable allocation of reasonable dues, fees, and other
charges among its members, issuers, and other persons using its
facilities; and with Section 6(b)(5) of the Act,\30\ which requires,
among other things, that the rules of a national securities exchange be
designed to prevent fraudulent and manipulative acts and practices, to
promote just and equitable principles of trade, to remove impediments
to and perfect the mechanism of a free and open market and a national
market system, and, in general, to protect investors and the public
interest, and not be designed to permit unfair discrimination between
customers, issuers, brokers, or dealers. The Commission also believes
that the proposal as modified is consistent with Rule 14b-1 under the
Act.\31\
---------------------------------------------------------------------------
\28\ In approving this proposed rule change, as modified by
Amendment Nos. 2 and 3, the Commission has considered the proposed
rule's impact on efficiency, competition, and capital formation. See
15 U.S.C. 78c(f).
\29\ 15 U.S.C. 78f(b)(4).
\30\ 15 U.S.C. 78f(b)(5).
\31\ 17 CFR 240.14b-1.
---------------------------------------------------------------------------
The Commission raised concerns about the proposal in the Order
Instituting Proceedings,\32\ but the Commission believes that the
Exchange has amended the proposal adequately to address those concerns.
Originally, proposed Rule 451A would have prohibited an NYSE member
organization from imposing distribution fees on an issuer in cases
where the member provided the shares or units of the securities held in
the beneficial owner's account at no cost or at a price ``substantially
less than the market price.'' \33\ In the Order Instituting
Proceedings, the Commission stated that the Exchange did not explain
how it would determine whether a price is ``substantially less than the
market price'' or otherwise provide guidance on the meaning of that
term.\34\ In Amendment No. 2, the Exchange addressed the Commission's
concern by eliminating that term from the proposed rule, resulting in a
rule with a more clearly defined application to nominee accounts that
contain only shares or units of the securities involved that were
transferred to the account holder by the member at no cost.
---------------------------------------------------------------------------
\32\ See Order Instituting Proceedings, supra note 7.
\33\ See Original Notice, supra note 3.
\34\ See Order Instituting Proceedings, supra note 7, 86 FR at
15537.
---------------------------------------------------------------------------
The Commission also stated in the Order Instituting Proceedings
that the initial proposal did not explain why it is consistent with the
Act for the proposed reimbursement prohibition not to apply if a
customer transferred its account to a new broker or held any shares of
the issuer in its account other than those received through a below-
market price transfer from the member seeking reimbursement.\35\
Additionally, the Commission stated that the initial proposal did not
address the feasibility of tracking shares held by a particular
beneficial owner where the eligibility for reimbursement may change
over time.\36\ The Exchange addressed these concerns in Amendment No. 2
by clarifying that it would be impossible for the new broker in these
circumstances to track whether the shares of a specific issuer
transferred into its custody had all been received by the beneficial
owner without charge from another broker.\37\ In addition, according to
the Exchange, the new broker would not have received the same
commercial benefit as the original broker that transferred the shares
without charge to its customers.\38\ For these reasons, the Exchange
stated that it is impracticable to extend the proposed reimbursement
prohibition to the new broker and reasonable to limit its application
to the original broker that transferred the shares without charge.\39\
---------------------------------------------------------------------------
\35\ See id., 86 FR at 15537-38.
\36\ See id., 86 FR at 15538.
\37\ See Amendment No. 2, supra note 8, 86 FR at 22726.
\38\ See id., 86 FR at 22726-27.
\39\ See id., 86 FR at 22727.
---------------------------------------------------------------------------
Further, in the Order Instituting Proceedings, the Commission
stated that the Exchange had not explained how the proposal would be
consistent with Rule 14b-1 under the Act \40\ in light of the fact that
a broker-dealer would be required to distribute proxies or other
materials but be precluded from seeking reimbursement of its expenses
in the applicable circumstances.\41\ In Amendment No. 2, the Exchange
stated that any broker that is prohibited from charging fees under the
proposal would continue to be reimbursed for its aggregate expenses
with respect to proxy distribution, as the prohibition on distribution
fees would be limited to those accounts in which the only shares of the
applicable issuer are shares received without charge from that
broker.\42\ The Exchange stated that, as such, the effect of the
proposal would be to reduce the overall reimbursement received by that
broker for a distribution, but not to eliminate that reimbursement.\43\
---------------------------------------------------------------------------
\40\ 17 CFR 240.14b-1.
\41\ See Order Instituting Proceedings, supra note 7, 86 FR at
15538.
\42\ See Amendment No. 2, supra note 8, 86 FR at 22727.
\43\ See id.
---------------------------------------------------------------------------
Commenters broadly supported the proposal.\44\ One commenter stated
that
[[Page 46736]]
the recent broker practice of gifting small amounts of securities to
retail brokerage clients as a promotional measure has caused
significant increases in proxy costs for some issuers, and expressed
the view that the proposal would alleviate much of the cost impact to
issuers from this broker practice, particularly for accounts defaulted
to e-delivery.\45\ Two commenters are issuers that stated that they
experienced dramatic increases in proxy distribution costs for the 2020
proxy season, which they both attributed to the inclusion of their
shares in a retail broker's promotional free share program.\46\ Both
commenters asserted that the issuer should not bear the proxy
distribution costs that arise due to their shares being included in
such a broker promotional program.\47\ Another commenter stated that
the promotions the proposed rule change is designed to address provide
commercial benefits to broker-dealers without providing any parallel
benefits to public companies.\48\
---------------------------------------------------------------------------
\44\ See letters from: Paul Conn, President, Global Capital
Markets, Computershare, dated January 11, 2021 (``First
Computershare Letter''), at 2-3; Niels Holch, Executive Director,
Shareholder Communications Coalition, dated January 20, 2021
(``Coalition Letter''), at 5 n.14; Paul Conn, President, Global
Capital Markets, Computershare, dated April 14, 2021 (``Second
Computershare Letter''), at 4; Kim Warnica, Senior Vice President,
General Counsel and Secretary, Marathon Oil Corporation, dated April
27, 2021 (``Marathon Letter''); Patrick J. McEnany, Chairman and
CEO, Catalyst Pharmaceuticals, Inc., dated June 9, 2021 (``Catalyst
Letter''). An additional commenter appears to suggest that member
organizations should be reimbursed in certain circumstances that are
not covered by the proposal or the rules the proposal is amending.
See letter from David, dated June 14, 2021.
\45\ See First Computershare Letter at 2-3. This commenter also
stated that while it understood that the accounts that receive such
``gifted'' securities generally are set for electronic
communications, as a technical matter, if a street-name holder of
gifted securities receives hardcopy proxy communications rather than
electronic delivery, the issuer will still bear increased costs from
printing the materials to be disseminated by the broker. See id.
Even if an issuer bears increased printing costs due to its shares
being included in a broker promotional program, as discussed below,
the Commission believes that the proposal is consistent with the Act
because, among other things, the proposed rule's prohibition against
imposing fees on issuers would result in a more equitable and not
unfairly discriminatory reallocation to brokers of significant costs
typically associated with the distribution of proxies and other
materials in the circumstances addressed by the proposal.
\46\ See Marathon Letter at 1-2; Catalyst Letter at 2. One of
these commenters stated that its 2020 proxy distribution bill was
2,402 percent higher than the 2019 bill, representing distribution
to 3,051 percent more stockholders in 2020 than in 2019. See
Marathon Letter at 1. The commenter noted that as of its 2020
stockholder meeting date, 80 percent of the stockholders that held
the commenter's shares through accounts at the particular retail
broker held five shares or less. See id. The commenter believes
that, for the vast majority of the accounts holding fewer than five
shares, the shares were chosen by that retail broker, not the
beneficial owners. See id. at 2. Similarly, the other issuer
commenter stated that the number of holders of its common shares who
hold their shares through that retail broker increased by more than
2,057 percent from 2019 to 2020, and its proxy distribution bill
from the distribution platform that services that retail broker grew
1,779 percent from 2019 to 2020 (from approximately $12,500 to
approximately $234,000). See Catalyst Letter at 1-2. The commenter
believes the increase in both shareholders and costs is directly
attributable to the retail broker and its promotional activities.
See id. at 2.
\47\ See Marathon Letter at 2; Catalyst Letter at 2.
\48\ See Coalition Letter at 5 n.14.
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The Commission believes that the proposal as modified is consistent
with Sections 6(b)(4) and 6(b)(5) of the Act, as well as Rule 14b-1.
The proposed rule would appropriately reallocate from an issuer to a
broker the fee-related expense of distributing proxy and other
materials to beneficial owners in the limited circumstance where the
beneficial owner's account contains only shares or units of the
issuer's securities that were transferred to the beneficial owner by
the broker at no cost.\49\ This circumstance would appear to arise
typically due to a broker promotional program that, as stated by the
Exchange, the broker chooses to engage in because it believes it will
result in a commercial benefit to the broker and, as noted by one
commenter,\50\ provides commercial benefits to the broker without
providing any parallel benefits to the issuer.\51\ The Commission
therefore believes that the proposal is reasonably designed to result
in a more equitable and not unfairly discriminatory allocation of the
costs of the distribution of proxy and other materials, consistent with
Sections 6(b)(4) and 6(b)(5) of the Act.
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\49\ See supra note 25 and accompanying text.
\50\ See Coalition Letter at 5 n.14. See also Catalyst Letter at
2.
\51\ One commenter stated that, if, after receiving gifted
shares, an investor subsequently chooses to increase its share
ownership and makes an investment decision to buy additional shares,
it would be appropriate to shift the cost of proxy distribution back
to the issuer. See Marathon Letter at 2. As stated above, the
Exchange's proposal would affect accounts that only include shares
that were transferred to the account holder by the broker at no
cost, and accordingly, if a street name investor were to be induced
to purchase or otherwise acquire any additional shares of the issuer
as a result of being gifted shares by a broker, the issuer would
then bear the proxy distribution costs for that investor's account.
See supra note 25 and accompanying text.
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The Commission also believes that the proposal is consistent with
the Section 6(b)(5) goal of protecting investors and the public
interest, and is consistent with Rule 14b-1, because the cost
reallocation effectuated by the proposal would not diminish brokers'
obligations to distribute issuer materials to accounts in which
securities are held in street name, including accounts covered by the
proposal, i.e., that contain only shares or units of the securities
involved that were transferred to the account holder by the member
organization at no cost. Moreover, this cost reallocation does not
preclude the broker from receiving assurance of reimbursement of its
``reasonable expenses,'' both direct and indirect, consistent with Rule
14b-1. In previously approving, in 2013, an Exchange proposal that,
among other things, eliminated fees for distributing issuer materials
to managed accounts with five or fewer shares of the issuer's
securities, the Commission acknowledged that any general rule setting
forth an industry-wide fee schedule for the reimbursement of reasonable
broker-dealer expenses necessarily will not precisely reimburse the
actual expenses incurred by individual firms.\52\ Here, a broker with
accounts covered by the proposal may not receive precise reimbursement
for its expenses incurred for a distribution pertaining to the issuer
whose shares it gave away at no cost, but the broker would continue to
be reasonably reimbursed for its expenses, both direct and indirect, in
the aggregate.\53\ The proposal would not eliminate a broker's ability
to charge reimbursement fees for distributing an issuer's materials to
accounts that hold any shares or units of the issuer's securities that
the beneficial owner purchased or acquired in any way other than from
the broker at no cost. Nor would the proposal affect the broker's
ability to charge reimbursement fees for distributing materials on
behalf of issuers whose shares it did not give away at no cost. Any
shortfall in precise reimbursement of expenses experienced by the
broker because of the proposal would be confined to fee-related
expenses attributable to distributing an issuer's materials to
beneficial owners that receive those materials solely due to the
broker's own promotional efforts.
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\52\ See Rule 451, Supplementary Material .90; 2013 Approval
Order, supra note 11, 78 FR at 63546 (stating that this rule with
respect to managed accounts was designed to provide reasonable
reimbursement of the overall expenses of broker-dealers in the
aggregate, and the extent of reimbursement of any individual firm
would vary depending on the specifics of its account population).
One commenter analogized the scenario presented by this proposal to
the Exchange's prior proposal to eliminate fees for distributing
issuer materials to managed accounts with five or fewer shares of
the issuer's securities. See Marathon Letter at 2.
\53\ As clarified in Amendment No. 3, supra note 10, issuers
must reimburse brokers for any non-fee-related expenses--i.e., any
actual, out-of-pocket postage, envelope, and communication expenses
incurred in receiving voting returns--notwithstanding the proposed
rule.
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Based on the foregoing, the Commission finds that the proposed rule
change, as amended, is consistent with the Act and the rules and
regulations thereunder.
[[Page 46737]]
IV. Conclusion
It is therefore ordered, pursuant to Section 19(b)(2) of the
Act,\54\ that the proposed rule change (SR-NYSE-2020-98), as amended by
Amendment Nos. 2 and 3, be and hereby is approved.
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\54\ 15 U.S.C. 78s(b)(2).
\55\ 17 CFR 200.30-3(a)(12).
For the Commission, by the Division of Trading and Markets,
pursuant to delegated authority.\55\
J. Matthew DeLesDernier,
Assistant Secretary.
[FR Doc. 2021-17760 Filed 8-18-21; 8:45 am]
BILLING CODE 8011-01-P