Letters

Market Data Rebates for Reporting Off-Exchange Transactions

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposed rule change to amend NASD Rule 7001B to increase the market data rebates for reporting off-exchange transactions on the NASD/Nasdaq Trade Reporting Facility (TRF), File No. SR-FINRA-2007-041; and the order granting NetCoalition petition for review, File No. SR-NYSEArca-2006-21.  SIFMA believes that rebates are evidence that market data fees are not fair and reasonable.  SIFMA’s other concerns include: (i) the absence of any consideration of the burden on competition; and (ii) the lack of transparency in the TRF costs deducted before the revenue is allocated to the business members and in the market data revenues that result in the rebates.

 

 

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