March 6, 2013
The filing does not include an independent review of proxy costs, as recommended by the NYSE Proxy Working Group in 2006.
The filing does not include a thorough analysis of the costs and benefits of the proposed fee changes, using the same degree of rigor as the SEC applies to its own rules.
The proposed processing and intermediary fees do not allocate fees equitably between large and small issuers.
The fee proposal favors the interests of broker-dealers and discriminates against issuers.
The structure and level of the proposed NYSE proxy fees place a burden on competition.