Restructuring of Quotation Collection & Dissemination for OTC Equity Securities

SIFMA’s Market Data Subcommittee provides comments to the Securities and Exchange Commission (SEC) on FINRA’s proposals relating the restructuring of quotation collection and dissemination for over-the-counter (OTC) equity securities, File No. SR-FINRA-2009-077, Exchange Act Release No. 60999. The proposal: 1) permits FINRA to cease operation of the OTC Bulletin Board; and 2) requires FINRA members to submit all their quotations in OTC equity securities to a new, FINRA-controlled, quotation consolidation facility contemporaneous with such members’ display of quotations in any interdealer quotation system that permits updates on a real-time basis. SIFMA is concerned about the consolidation of control of this market data under a self-regulatory organization (SRO) because of the potential monopoly and competitive advantage gained through an SRO’s use of regulatory authority.