September 2, 2020

Vanessa Countryman
Secretary
Securities and Exchange Commission
100 F Street NE.,
Washington, DC 20549

Re: NYSE Rule Proposals to Amend the Schedule of Wireless Connectivity Fees and Charges to Add Wireless Connectivity Services; File Nos. SR-NYSE-2020-11, SRNYSE-2020-05, SR-NYSEAMER-2020-10, SR-NYSEAMER-2020-05, SR-NYSEArca-2020-15, SR-NYSEArca-2020-08, SR-NYSECHX-2020-05, SR-NYSECHX-2020-02 NYSENAT-2020-08, NYSENAT-2020-03

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 submits this letter to comment on the above-referenced filing submitted to the U.S. Securities and Exchange Commission (“Commission”) to add wireless connectivity services and charge applicable fees by New York Stock Exchange LLC,2 NYSE American LLC,3 NYSE Arca, Inc.,4 NYSE Chicago, Inc.5 and NYSE National, Inc.6 (collectively, “NYSE”). First, we support the Commission’s finding that Ice Data Services (“NYSE Affiliate”) offering wireless market data connections are facilities of the exchange. Second, while the NYSE’s amendment is designed to provide a level playing field for competition to connect to the exchanges’ exclusive market data feeds via wireless connectivity services, the Commission should continue to ensure NYSE does not engage in other practices that would give the NYSE Affiliate an advantage over competitors.

Third, the Commission should clearly note that the competition for wireless connectivity services remains distinct from whether the fees charged for the exclusive market data meet the requirements of the Securities Exchange Act of 1934 (“Exchange Act”).7