Letters

Proposed Change to Introduce a NYSE OpenBook Nonprofessional Subscriber Fee

Summary

SIFMA provides comments to the Securities and Exchange Commission (SEC) on a proposed change to introduce a NYSE OpenBook nonprofessional subscriber fee and to revise the unit of count that determines the device fees payable by data recipients, SR-NYSE-2008-131; Release No. 34-59198. SIFMA fundamentally objects to the application of the NYSE ArcaBook Approval Order’s “fair and reasonable” test to OpenBook Ultra fees – both professional and nonprofessional.

 

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