Brent J. Fields
Secretary
Securities and Exchange Commission
100 F Street NE., Washington, DC 20549

Re: File No. 4-729: Roundtable on Market Data and Market Access

Dear Mr. Fields:

The Securities Industry and Financial Markets Association (“SIFMA”) thanks the U.S. Securities and Exchange Commission (“Commission”) for organizing the Roundtable on Market Data and Market Access (“Roundtable”) to be held on October 25 and 26, 2018. These are very important issues for the markets, and we appreciate the Commission’s attention in this area.

SIFMA has been extremely active in market data issues for more than a decade. We have advocated for market data reforms that will increase market efficiency by providing greater transparency and benefit retail investors by requiring more reasonable fees. In this area, we have advocated mainly on two fronts: first, the need to reform fees for exchanges’ market data products; and second, the need to address the conflicts of interest affecting the quality and operation of the Securities Information Processors (“SIPs”).

Below, we describe the meaningful market-data reforms that SIFMA supports. In addition, we describe flaws in policy papers that NYSE and Nasdaq have issued in advance of the Roundtable.

The Commission recently took a critical step in ordering the exchanges to provide factual and legal support to demonstrate that their market data fees are fair and reasonable as required by the Securities Exchange Act of 1934 (“Exchange Act”). In addition, the Commission should address the issue of speed and content differentials between the market data feeds provided by the SIPs and the proprietary products sold by the exchanges. Both retail investors and market professionals should have access to the most complete and up-to-date market information possible to make informed investing decisions.

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