Non-display fees

Joan said:
Eric Scott Hunsader from Nanex has talked about the non-display fees issue.
https://twitter.com/x/status/854768063924908032

Bloomberg has sent a comment to stop these insane fees:
https://www.sec.gov/comments/sr-ctacq-2017-02/ctacq201702-1710668-150186.pdf

SINFA
https://www.sec.gov/comments/sr-ctacq-2017-02/ctacq201702-1710463-150167.pdf

DTN
https://www.sec.gov/comments/sr-ctacq-2017-02/ctacq201702-150163.htm

https://www.sec.gov/comments/sr-ctacq-2017-02/ctacq201702.htm

Robert, have you had a look at these documents?
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Thank you. Will read them tonight. Let's hope the SEC gets more.
 
This is great. Thank you Joan for sharing. I wish that Bloomberg focused less on how secure their system is and more on how unfair the fees are. We will now have to wait and see how the SEC responds. Normally, this is not quick. I would have like to see comments from listed companies on the NYSE complaining how this will limit access to real time data on their list securities. That might have helped. Maybe a few like BAC, WFC an GS saying they will list on the NASDAQ would be an eye opener for the NYSE.

Bob
 
Robert Morse said:
...I wish that Bloomberg focused less on how secure their system is and more on how unfair the fees are. ...
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I had that feeling too after reading the whole document. Although it also clearly states that market data should be distributed in cost-based approach.

Section 6(b)(4) of the Exchange Act of 1934 requires that the "rules of the exchange provide for the equitable allocation of reasonable dues, fees, and other charges among its members and issuers and other person using its facilities." Furthermore, top of book data is a special category of market data where it is even more important to constrain the application of fees. In fact, in NetCoalition v. SEC, 615 F.3d 525 (D.C. Cir. 2010) and NetCoalition v. SEC, 715 F.3d 342 (D.C. Cir. 2013), the Court noted that core data must be cost-based -- appropriately, this is an unyielding standard. The Court specifically noted the "mandatory nature of the regime" and understood the role of the exchanges as sole source providers of the data. As such, the Court endorsed a cost-based approach, rather than a market-based approach. It is totally inconceivable that a 2,000% increase in costs is in line with exchange costs. Regardless, the exchanges have presented no evidence to support the cost-based need for such extortionate fees.
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Oh pls Bob. With all due respect, where is your firm's letter to the SEC? You are one of the few who totally complied and just passed on this BS to all your clients. In case you still don't get it, firm like GS or MS were never asked to pay. It was from the start a selective and totally crooked business idea which never makes it through a legal challenge. You guys just fell for it and Bloomberg on the other side did not. To your credit, your firm is much smaller and would probably take on too much risk to legally challenge this charge. Yet, your silence and complicity is well noted and disappointing to be very honest. It is complicit people in "crime" who imho are even worse than the perpetrators.

Robert Morse said:
This is great. Thank you Joan for sharing. I wish that Bloomberg focused less on how secure their system is and more on how unfair the fees are. We will now have to wait and see how the SEC responds. Normally, this is not quick. I would have like to see comments from listed companies on the NYSE complaining how this will limit access to real time data on their list securities. That might have helped. Maybe a few like BAC, WFC an GS saying they will list on the NASDAQ would be an eye opener for the NYSE.

Bob
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Zzzz1 said:
Oh pls Bob. With all due respect, where is your firm's letter to the SEC? You are one of the few who totally complied and just passed on this BS to all your clients. In case you still don't get it, firm like GS or MS were never asked to pay. It was from the start a selective and totally crooked business idea which never makes it through a legal challenge. You guys just fell for it and Bloomberg on the other side did not. To your credit, your firm is much smaller and would probably take on too much risk to legally challenge this charge. Yet, your silence and complicity is well noted and disappointing to be very honest. It is complicit people in "crime" who imho are even worse than the perpetrators.
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You really have no idea what we did during that time do you? You also have no idea what happened at other firms. You just like to attack.
 
how would we know, Bob, when you do not communicate it nor file letters? How come Bloomberg's letter is there but none of your firm? All you did was basically being inquisitive with your clients how they peruse their data. The data is SOLD by the exchanges and PASSED through by firms like yours. As long as clients abide by the contractual agreements it should be none of your business nor the exchange's business whether the data feeds algorithms, a UI or a chart. Are there letters in public domain from your firm, or are there threads here at ET or other forums where you fought for your clients? Where are those? I do not accuse you or attack you, I simply stated facts. Update us on the facts if you have evidence or backup that shows how you pushed against non-display charges.

Robert Morse said:
You really have no idea what we did during that time do you? You also have no idea what happened at other firms. You just like to attack.
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Zzzz1 said:
good luck with that. After all we need more exchanges not less. Or was it the other way around?
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This exchange is going to put the NYSE out of business.

NO NON-DISPLAY FEES!

These non-display fees infuriate me. This paywalling effectively prevents retail investors from trading algorithmically!
 
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