November 12, 2020

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

Re: File No. 4-757; Filing of a National Market System Plan Regarding Consolidated Equity Market Data

Dear Ms. Countryman:

The Securities Industry and Financial Markets Association (“SIFMA”)1 respectfully submits this letter to the U.S. Securities and Exchange Commission (“Commission” or “SEC”) to comment on the proposal filed by the national securities exchanges and FINRA (collectively, the “SROs” or “Participants”) to establish under Section 11A of the Securities Exchange Act of 1934 (“Exchange Act”) a new single national market system plan governing the public dissemination of real-time consolidated equity market data for national market system (“NMS”) stocks (the “CT Plan”).2 The CT Plan responds to the Commission’s order3 directing the SROs to consolidate the three current market data plans (i.e., the CTA Plan, CQ Plan and Nasdaq UTP Plan) into a single plan to govern the distribution of equity market data. SIFMA supported that Commission order, which is designed to reduce unnecessary duplication among the three current market data plans and to address the exchanges’ conflict of interests as operators of the securities information processors (“SIPs”) under the plans and sellers of proprietary market data products that compete with SIPs.4 We therefore broadly support the CT Plan for consolidating the three current market data plans and providing industry representatives with a vote in the governance of the new NMS plan for the collection and dissemination of equity market data. Adding industry member representation to the governance of the plan (“Non-SRO Voting Representatives”) represents a necessary first step to improving and modernizing the current market data infrastructure.5 SIFMA appreciates the SROs’ submission of the CT Plan and is providing below certain recommendations in response to the Commission’s questions in the Proposal to assist with a timely implementation of the CT Plan.