SIFMA provides comments to the Ontario Securities Commission (OCS) on the Canadian Securities Administration (CSA) Staff Consultation Paper 21-401, Real-Time Market Data Fees (the CSA Paper).  While market data is an extremely complicated area, SIFMA believes analysis flows from two simple bedrocks, both of which the CSA Paper expressly recognizes. First, “real-time market data plays a key role in the price discovery process and provides vital information on the trading activity of the marketplace.” Second, “each marketplace is the only source of order and trade information sent to and transacted on its facility…”.