April 20, 2017
I apologize for missing the deadline for comments, this new proposal was just recently brought to my attention.
I am writing anonymously because I am afraid of retaliation from the employees and management of NYSE as will be outlined below. It is likely there are others withholding comment for this reason. These fees are large enough to destroy small firms and traders. And this latest proposal pretty much sweeps 99% of the user base into the non-display category.
It is time this entire CTA/CTB pricing model be acknowledged for what it is - a money grab by NYSE. The SIP is a public utility that is essential to the proper functioning of the market. Beyond that many market participants are legally required to subscribe for compliance and risk management purposes - purposes considered non-display by NYSE.
Furthermore, the whole justification for this pricing model is to align fees with useage. Going by this yardstick it is an abject failure. A small retail trader or boutique broker/dealer pays the same exact amount as the largest HFT or market maker. Also, access fees are charged whether using a 3rd party data vendor, a retail broker, or getting data direct from NYSE - this makes absolutely no sense.
Finally, the rules are applied and exempted arbitrarily by employees and management. In my experience, different account managers have different criteria. Some decisions I have been made aware of seem punitive. I have seen similar users get charged different rates. I have already seen these fees put smaller operators out of business.
CTA/CTB are essential public utilities administered by a monopoly. The SEC needs to exert much more control over the pricing process. My suggestions:
1) force NYSE to revert to the pre 2014 pricing model until they can come up with something better.
2) Force NYSE to be transparent about costs and revenue. NYSE needs to outline in detail their costs, their expected revenue per subscriber type along with the expected number of subscribers. They should detail what type of user is intended to be in included in which type of subscription. For example, market makers would be subscription type A, retail traders would be subscription type B, broker/dealers using data for compliance would be type C.
3) Access fees should only be charged to users getting data from NYSE directly.
4) Only NYSE requires users to pay NYXData directly. There's no reason fees can't be paid through resellers, as is done by every other market venue in the US. This is just a waste of everyone's money and time getting billed separately every month by NYSE.
5) Fees should be priced with the idea of ENCOURAGING more market participants - not driving them out of business.
Thank you for your time.