SIFMA Executives Urge SEC to Ensure CT Plan Fees Reflect Actual Costs
SIFMA executives urged the SEC to treat the upcoming Consolidated Tape ("CT") Plan fee filing as an opportunity for reforming the U.S. consolidated equity market data system.
In a Pennsylvania + Wall post, SIFMA Capital Markets Group’s lawyers described the CT Plan - a new, single national market system plan to replace the three existing Equity Data Plans. The executives stated that the CT Plan will be responsible for collecting, consolidating, and disseminating all consolidated equity market data beginning in early 2027. The CT Plan is expected to submit its first fee filing to the SEC in November. The lawyers highlighted that this filing will provide the SEC and the public with their first look at the proposed fees for accessing consolidated market data, which is a critical element in ensuring the efficiency and transparency of the U.S. equity markets.
The executives argued that the current systems have not kept pace with market evolution. They said that while the SEC is responsible for ensuring that core data is widely available at reasonable cost, exchanges have prioritized proprietary data products, creating conflicts of interest that hinder improvements to consolidated feeds. They noted that past SEC reform efforts were delayed by exchange challenges, but the new CT Plan presents a renewed opportunity to enhance data quality, fairness, and investor access across U.S. equity markets.
The executives urged the SEC to:
- Ensure Fees Reflect Actual Costs and Improving Cost Transparency. The executives urged the SEC to ensure the CT Plan’s proposed fees are fair, reasonable, and directly tied to the actual costs of collecting and disseminating equity market data, consistent with Exchange Act requirements. They emphasized that transparent cost disclosures are necessary for verifying compliance and preventing implementation delays. The executives warned that current fee levels are disproportionate, citing SEC findings that only about 11% of 2017 market data revenues covered operating expenses—with the rest distributed to exchanges. They called on the CT Plan to establish a clear, transparent cost basis to correct this imbalance.
- Simplify Policies and Data Agreements. The executives recommended that the SEC scrutinize the CT Plan’s proposed policies and data subscriber agreements to ensure they are clear, efficient, and practical. They criticized current Equity Data Plan policies as overly complex and burdensome, particularly regarding reporting and auditing requirements, and urged the adoption of simpler fee structures, broader redistribution rights, and reduced administrative obligations.
- Reevaluate the Market Data Infrastructure Model. The executives questioned whether the Competing Consolidator/Self-Aggregator model adopted in the Market Data Infrastructure Rule will successfully foster competition in market data. They called on the SEC to revisit this model, set a firm deadline for the CT Plan to propose data fees for competing consolidators, and determine whether the decentralized framework is viable or requires modification to achieve the intended reforms.