SIFMA provides comments to the Securities and Exchange Commission (SEC) petitioning for disapproval of NYSE MKT, LLC proposal to establish non-display usage fees and to amend the professional end-user fees for NYSE MKT Options market data. 

SIFMA strongly believes that the Exchange’s actions are inconsistent with the decisions of the United States Court of Appeals for the District of Columbia Circuit in NetCoalition v. SEC; and in their petition requests the SEC temporarily suspend the rule change and disapprove the rule change under provisions of the Securities Exchange Act of 1934.

SIFMA includes an exhibit with this filing by Dr. David S. Evans, Chairman, Global Economics Group, LLC (March 21, 2011):

Response to Ordover and Bamberger’s Statement Regarding NASDAQ’s Rule Change Concerning the Pricing of Market Data