NASDAQ Proposal to Establish Certain Fees

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a NASDAQ proposal that would establish fees for registering and transferring registration of associated persons, File No. SR-NASDAQ-2007-099.  SIFMA requests that the SEC do away with the filing by exercising to its authority under Section 19(b) of the Securities Exchange Act of 1934 on the grounds that the registration fee increase proposed by the Nasdaq Stock Market LLC does not satisfy the equitable allocation standards of Section 6(b)(4) of the Exchange Act. In addition, SIFMA further requests that the SEC review and address more generally the broader policy issue of regulatory fee increases currently imposed by other for-profit exchanges, as well as the SEC’s own procedures for reviewing proposed exchange fee rules.