February 19, 2021
Securities and Exchange Commission
100 F Street NE., Washington, DC 20549
Re: File No. 4-698; Joint Industry Plan; Notice of Filing of Amendment to the National Market System Plan Governing the Consolidated Audit Trail by the Plan Participants—Comment Letter of the Securities Industry and Financial Markets Association
Dear Ms. Countryman:
On behalf of Securities Industry and Financial Markets Association (“SIFMA”)1 and as referenced in our comment letter dated January 27, 2021, enclosed is a White Paper prepared by Professor Craig M. Lewis entitled “Economic Analysis of Proposed Amendment to National Market System Plan Governing the Consolidated Audit Trail.” As set forth in the White Paper, Professor Lewis disagrees with the Charles River Associates report accompanying the proposed amendment and concludes that the proposed amendment, if adopted, would result in a reduction in investor welfare.