Petitioning for Disapproval a Proposal to Extend Fee Pilot Program for NASDAQ Last Sale
SIFMA provides comments to the Securities and Exchange Commission (SEC) petitioning the SEC for disapproval a proposed rule change to extend Fee Pilot Program for NASDAQ Last Sale, File No. SR-NASDAQ-2013-126, SEC Release No. 34-70575.
For the reasons described in this letter, and because NASDAQ’s actions are inconsistent with the decision of the United States Court of Appeals for the District of Columbia Circuit in NetCoalition v. SEC, SIFMA respectfully petitions the SEC to temporarily suspend this rule change under Section 19(b)(3)(C) of the Securities Exchange Act of 1934 (Exchange Act) and institute proceedings to disapprove the rule change under Section 19(b)(2)(B) of the Exchange Act.