Open Call – New Consolidated Market Data Plan

STA Open Call – January 23, 2020 – Call Notes[1]

New Consolidated Market Data Plan (“Proposed Order”)

Mike Masone, Citi

Nat Evarts, SSGA

Opening Remarks – Jim Toes, STA

STA Comment Letter on Rule 15c2-11

STA commends the Commission for proposing amendments to modernize Rule 15c2-11 STA offers the following comments about certain aspects of the Proposal, including: (1) the increased burden that may be imposed on market makers; and (2) potential consequences for retail investors when securities are no longer eligible for public quoting. Full letter here

SEC Discussion Document used on recent SEC Meetings

In late Dec. STA conducted meetings at the SEC which included: Commissioners Elad Roisman and Alison Lee. Issues discussed included: Proliferation of strikes in the options market place; implementation of Rule 606; Thinly Traded Securities & others. Complete list & comments here. 

Executive Summary

On Jan 8th the SEC announced it will seek public comments on a proposed order that will modernize the governance of National Market System (NMS) plans by among other things, unifying the three existing plans into one. As we will discuss tonight, we believe this is a significant development. While technology is often credited with being the major influence on the evolution and overall efficiency of our markets, data is the fuel which feeds it. The goals this evening are: raise awareness; educate and most importantly inspire engagement during this window in time when determinations on what defines the new Plan are made.  

Questions & Answers (not covered in the Open Call Material pdf)

Question: Please provide perspective on where market data is today &  Jan 8th announcement The growth, increased speed and development of new and sophisticated trading protocols inherently fed the need to have access to, and consumption of, a wider and more nuanced data set. Through the years, improvements have been made in the consolidation & dissemination of market data (SIPs), but those improvements have not kept pace with the alternatives the industry can and often must access.

The existing governance structure of the SIP Reg NMS Plan was designed in 1975. Markets and the corporate structure of SROs have changed dramatically since that time. Current governance holds little transparency and does not accurately reflect the diverse cross-section of market participants transacting in it. Consolidated market data is now something that needs to be looked at and the SEC is taking the right first step by seeking comments on a new governance structure 

STA Open Call Market Data FINAL Report with Call Material HERE

[1] This brief is meant for informational purposes only and therefore should not be considered legal advice. STA’s goal is to raise awareness on industry developments and encourage dialogue.