Joint Self-Regulatory Plan Relating to Quotation & Transaction for NASDAQ-Listed Securities

SIFMA and NetCoalition provide comments to the Securities and Exchange Commission (SEC) on a proposal by the operating committee of the Joint Self-Regulatory Organization Plan Governing the Collection, Consolidation, and Dissemination of Quotation and Transaction Information for NASDAQ-Listed Securities Traded on Exchanges on an Unlisted Trading Privilege Basis (the Plan), which would replace the annual administrative fees that the Participants impose with respect to real-time data with monthly access fees.  The groups believe that the operating committee’s actions relate to what the SEC refers to as “core” data, and are inconsistent with the findings of the U.S. Court of Appeals for the District of Columbia Circuit in NetCoalition v. Securities and Exchange Commission. Given the inconsistency, the groups request the SEC summarily repeal the amendment filed and require that the amendment be refiled and reviewed appropriately.