SIFMA’s Market Data Subcommittee provides comments to the Securities and Exchange Commission (SEC) regarding SR-NYSE-2010-22, a proposal to make permanent a Unit-of-Count Metric alternative for NYSE OpenBook and makes changes relating to the unit of count for assessing market data fees. SIFMA welcomes the initiative, and considers that more than one individual should not be able to access market data simultaneously using the same entitlement. SIFMA also informs the SEC that the NYSE has informally told that the $1,500 per month cap will be the most that it will charge a firm for internal support function usage of the OpenBook data after the rule is final.