January 21, 2020

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

Re: SIFMA Comment Letter on the NYSE National Rule Proposal to Establish Fees for the NYSE National Integrated Feed: File No. SR-NYSENAT-2019-31

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 establish market data fees by NYSE National, Inc. (“NYSE National”).2 Currently, there are no fees for use of the NYSE National Integrated Feed. NYSE National is looking to impose the new fees discussed in more detail below. To show that the proposed rule change is consistent with applicable statutory requirements under the Securities Exchange Act of 1934 (“Exchange Act”),3 NYSE National must provide sufficient rationale for these fees by following the examples of necessary information set forth in the Staff Guidance on SRO Rule Filings Relating to Fees,4 or another acceptable means. NYSE National failed to provide the necessary information for the SEC to independently determine whether the fees meet the requirements of the Exchange Act, and in consequence, SIFMA requests the Commission to institute proceedings to determine whether to approve or disapprove the proposal.

Effective February 3, 2020, NYSE National proposes to commence charging the following monthly fees for its Integrated Feed: access fee of $2,500; redistribution fee of $1,500; professional user fee of $10 and non-professional user fee of $1; non-display fee of $5,000 for each category of use with a cap of $15,000 for category three; a non-display use declaration late fee of $1,000; and a $200 fee for each additional location a firm takes in the feed. SIFMA opposes NYSE National’s filing to establish fees for its Integrated Feed because the Exchange has not provided the requisite justification per the Staff Guidance.