Comments on the SEC’s National Market System Plan Regarding Equity Market Data

On November 18, 2020, MFA submitted comments to the SEC in response to its proposed single national market system plan governing the dissemination of real-time consolidated equity market data. MFA strongly supports supports the creation of a single NMS plan that can address exchanges’ conflicts of interest arising from their operation of the securities information processors (“SIPs”) while selling proprietary market data are critical to enhancing the efficiency of the distribution of consolidated market data and aligning the operation of the SIPs with their statutory goals.

However, MFA outlines concerns with the proposal specifically:

  1. The SROs’ Lack Meaningful Obligations to the Plan to Ensure the SIPs Carry Out Their Intended Functions
  2. The SROs’ Control over the Election and Tenure of Non-SRO Voting Representatives Should Be Curtailed
  3. The Role of Member Observers Requires Greater Explanation and Functional Specifications
  4. The Plan Should Be Amended Consistent with Regulatory Requirements