SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposed change to introduce a NYSE OpenBook nonprofessional subscriber fee and to revise the unit of count that determines the device fees payable by data recipients, SR-NYSE-2008-131; Release No. 34-59198. SIFMA fundamentally objects to the application of the NYSE ArcaBook Approval Order’s “fair and reasonable” test to OpenBook Ultra fees – both professional and nonprofessional.
SIFMA AMG, Investment Company Institute (ICI), American Chamber of Commerce in Australia (AmCham Australia), Information Technology Industry Council (ITI), Managed…