Subject: File No. SR-NASDAQ-2014-089
From: Suzanne Hamlet Shatto

September 25, 2014


(Release No. 34-73025; File No. SR-NASDAQ-2014-089)
September 9, 2014

Self-Regulatory Organizations; The NASDAQ Stock Market LLC; Notice of Filing and Immediate Effectiveness of Proposed Rule Change to Modify NASDAQ Rule 7018 Fees

NASDAQ is proposing to amend NASDAQ Rule 7018 to modify fees assessed for execution and routing securities listed on NASDAQ (“Tape C”), NYSE (“Tape A”) and on exchanges other than NASDAQ and the NYSE (“Tape B”).The Exchange is proposing to no longer offer a recently adopted credit3 provided to members that qualify under certain requirements of the Market Quality Incentive Programs of Rule 7014. Specifically, NASDAQ will no longer provide a credit of $0.0001 per share executed to a member that either qualifies for a credit under Rule 7014(c)(3) or that is designated as a Qualified Market Maker (“QMM”) under Rule 7014(d). The credit currently provided is based on the shares executed through the qualifying MPID under Rules 7014(c)(3) or 7014(d), and is provided in addition to any other credit or rebate for which the member may qualify. NASDAQ believes that the elimination of this program is warranted since it has failed to increase liquidity in Tape A securities or to provide members with additional incentive to improve market quality.

so they want to stop paying a rebate because it failed to increase liquidity?  but the other rule filing 34-72549 wants to increase another rebate because they hope it will increase volume?  what kind of volume does it want?  this experiment was using investor $ in order to see if increased rebates will lead to more "liquidity" but the experiment didn't work.  i think they should withdraw at least one rule filing.  i think NASDAQ should get their rule filings into harmony and quit filing so many rule proposals about small system items.  the problem with the stock markets are rather systemic and operational procedures are not well-documented, transparent, nor even approved by the SEC.

i believe that rebates do not improve the market and in fact damage the market because they are not transparent, seek to advantage one user over another user, are not improving markets for retail/institutional investors.

suzanne hamlet shatto, investor