From: Alec Hanson
Sent: February 6, 2016
To: rule-comments@sec.gov
Subject: File No. SR-NYSE-2016-02

Re: File Number SR-NYSE-2016-02, Notice of Filing and Immediate Effectiveness of Proposed Rule Change Amending the Fees for NYSE OpenBook

Date: February 6, 2016

To: Robert W. Errett, Deputy Secretary, Securities and Exchange Commission

From: Alec Hanson, founder of AHSAT LLC, a proprietary trading firm

We disagree with the proposal to end the Managed Non-Display program. Despite accessing and using the same data feed (NYSE OpenBook) in substantially the same way, our costs more than doubled as a result of this change, on top of numerous increases over the past few years. Specifically, we paid $150 for January 2013 usage and paid $11,000 for January 2016, a 73x increase; the only changes have been billing or licensing changes forced upon us by the New York Stock Exchange ("NYSE"). These increases are indicative of monopolistic pricing and not of a free and competitive market. Contrary to NYSE's assertions, there is no way that we may purchase THIS content other than by paying NYSE (I sincerely invite anyone to notify me of another source). NYSE proprietary data describes supply and demand beyond the BBO strictly from those orders entered on their exchange, which are distinct from the orders entered on other venues and thus from the data purchasable from other venues. One venue's information does not substitute well for another's. Furthermore, because of NYSE's protected quote status, the market cannot simply ignore NYSE. These two features de facto give NYSE a monopoly over its proprietary data, and the result is pricing which is no longer fair nor reasonable, as required by statue as a condition of the privileges of a protected quote and exchange status.

I would refer interested parties to further discussion of these issues in comments on NYSE's pricing of its Integrated feed (File No. SR-NYSE-2015-57 at https://www.sec.gov/comments/sr-nyse-2015-57/nyse201557.shtml). We have also seen a 2.5x price jump from January 1, 2016 for the NYSE Arca Integrated Feed as a result of the end of Managed Non-Display, and oppose that change as filed in File No. SR-NYSEArca-2016-03, Notice of Filing and Immediate Effectiveness of Proposed Rule Change Amending the Fees for NYSE Arca Integrated Feed. I also found recent articles by trading cost expert Larry Tabb relevant, such as "Stock Exchanges Are Eating Your Returns" (Jan 22, 2016, http://www.bloombergview.com/articles/2016-01-22/stock-exchanges-data-fees-harm-investors) and "Fight over Market Data Fees is Going to Get Ugly" (Jan 27, 2016, http://tabbforum.com/opinions/fight-over-market-data-fees-is-going-to-get-ugly).
Thank you for your consideration.