STA Comments on Market Data Fees

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12 September 2008

September 11, 2008

Ms. Florence E. Harmon
Acting Secretary
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: File No. SR-NYSEArca-2006.21, SEC Release No 34-57917

Dear Ms. Harmon:

The Security Traders Association (“STA”) has historically had a sustained and productive dialogue with the Commission on behalf of our members, and we are respectfully submitting this letter to offer our perspective on the recent Proposed Order Approving Proposal by NYSE Arca, Inc. To Establish Fees for Certain Market Data (the “Proposed Order”).

The STA recognizes the critical role the Commission plays in protecting the integrity and confidence that investors rightfully place in the U.S. markets. We believe (and have consistently maintained) that an appropriate balance between regulation and competition is critical to the development of market structure. We further agree with the Congressional findings underpinning the national market system provisions in the Securities Exchange Act of 1934, as amended by the Securities Acts Amendments of 1975 (Section 11A(a)(1), 15 U.S.C. § 78k-1 (a)(1)), where “The Congress finds that…(C) It is in the public interest and appropriate for the protection of investors and the maintenance of fair and orderly markets to assure…(ii) fair competition among brokers and dealers, among exchange markets, and between exchange markets and markets other than exchange markets…(iii) the availability to brokers, dealers, and investors of information with respect to quotations for and transactions in securities…..”

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