Subject: File No. SR-NASDAQ-2010-089
From: Anonymous Anonymous
Affiliation: Compliance Officer for Broker-Dealer

August 17, 2010

This proposal forces small and mid-sized broker-dealers that currently (or may soon have to) assign unique MPIDs for each walled-off line of business to incur substantial costs, and endangers the separation of their lines of business if they share an MPID across multiple walled-off divisions in attempt to cut costs/save money. Depending of the number of business lines, this can amount to tens of thousands of dollars each year ($1,000 per MPID, per month x 12).

Please see the following excerpt from a speech given by FINRA Chaiman CEO, Richard Ketchum, in which he advocates a requirement that broker-dealers have unique MPIDs for each walled-off division (i.e., multiple MPIDs, and in the case of NASDAQ, supplemental MPIDs). If such a proposal is ultimately made by FINRA and approved by the SEC, broker-dealers with multiple lines of business shall be forced to incur the hefty annual costs associated with having multiple MPIDs (at NASDAQ) for each separate, walled-off business line.

"Clearly, there needs to be more granularity in the audit trail so that the trading activity by market participants can be readily identified. To do this, we believe there should be unique MPIDs for walled-off areas within broker-dealers, for ATS's and for each entity with direct access and these unique MPIDs need to be used uniformly by these participants regardless of where they trade—a major task for both regulators and the industry undoubtedly. But, if we are to regain investor's trust in the integrity of our equities markets—an absolutely essential one."