Subject: File No. 265-29
From: John Rochon
Affiliation: Jiffer Trading

October 20, 2015

Rule 610

One is no longer able to get fair access to market quotes anymore. Having access to non-display data is a requirement in today's market. Nyse has decided to remove Managed Non-Display price breaks from their new fee structure, forcing the small traders who are reliant on a market data aggregator to pay as much as the biggest firms, raising the costs to compete. Managed non-display pricing is a win-win. Its for the guys who need real-time access but don't need data in microseconds since someone else is managing that infrastructure for them. In exchange for the price break on non-direct access, NYSE only has to send data to one provider and not 1,000s of small traders. This recent pricing structure discriminates against those traders who can't hire the lobbyists to manage their interests.

The only reason why Nyse would remove this is because they have monopolistic pricing power and know that people don't have a choice if they want to trade the markets. So my market data bill with NYSE has gone up from $550/month to $8k/month in less than 20 months. Nasdaq only charges $375/month for EVERYTHING. I think NYSE has proven that they can't ensure fair pricing and are just following their lust for revenue.

John Rochon
Jiffer Trading