*Letters

Principles for Analyzing Market Data Rule Changes

Published on:
July 1, 2008
Issue:
Committee:

SIFMA provides comments to the Securities and Exchange Commission (SEC) on proposed rules relating to principles for analyzing market data rule changes and how to ensure that the investing public is not disadvantaged by changes to the self-regulatory organization (SRO) rulemaking process, File No. SR-NASDAQ-2006-060: SEC Release Nos. 34-55255 and 34-57965; File No. SR-NASDAQ-2008-050: SEC Release Nos. 34-57965 and 34-57973.  The accelerated approval of File No. SR NASDAQ-2006-060 would establish a new Nasdaq last sale data service. SIFMA believes the SEC did not use proper procedure in granting accelerated approval to the pilot program before responding to comments that had previously been submitted about similar filings. SIFMA believes the program may circumvent statutory standards and is concerned about potential SRO abuse in the market data context.

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