SIFMA provided comments to the Securities and Exchange Commission (SEC) on a proposal by the NASDAQ Stock Market LLC to reduce NASDAQ ‘s fees assessed for accessing liquidity and the credits provided for adding liquidity for a pre-selected set of 14 securities. The fee reduction will apply only to transactions in those securities on NASDAQ.

SIFMA supports the underlying concept of NASDAQ’s proposal, which is consistent with our recommendation to reduce access fees. However, SIFMA believes NASDAQ’s proposal will not contribute meaningful data to any larger market structure questions at hand. In particular, the proposal’s limited scope and application cannot act as a substitute for a market-wide access fee reduction that would change the dynamics of access fees and rebates across the entire market. For the proposal to accurately measure the structural impact of reduced access fees, the proposal should be carried out across all exchanges and with a larger sampling of symbols.

Related Material

SIFMA Equity Market Structure Recommendations – July 10, 2014