SIFMA’s Market Data Subcommittee provides comments to the Securities and Exchange Commission (SEC) on FINRA’s proposals relating the restructuring of quotation collection and dissemination for over-the-counter (OTC) equity securities, File No. SR-FINRA-2009-077, Exchange Act Release No. 60999. The proposal: 1) permits FINRA to cease operation of the OTC Bulletin Board; and 2) requires FINRA members to submit all their quotations in OTC equity securities to a new, FINRA-controlled, quotation consolidation facility contemporaneous with such members’ display of quotations in any interdealer quotation system that permits updates on a real-time basis. SIFMA is concerned about the consolidation of control of this market data under a self-regulatory organization (SRO) because of the potential monopoly and competitive advantage gained through an SRO’s use of regulatory authority.