SIFMA provides comments to Securities and Exchange Commission (SEC) on the Consolidated Tape Association (CTA) plan, which would implement a rule change to amend the Second Restatement of the Plan in response to requests from the industry to simplify the existing market data fee schedules and reduce associated administrative burdens, 78 Fed. Reg. 44984 (July 25, 2013).

SIFMA greatly appreciates the industry dialogue that led to these proposed changes and fully supports the Plan’s efforts to simplify pricing and reduce the administrative burdens on members.  However, SIFMA continues to believe that the Plan’s overall fees and the process by which fee changes are made – even for the laudatory reasons here – are inconsistent with the decision of the United States Court of Appeals for the District of Columbia Circuit in NetCoalition v. SEC.