The US Court of Appeals struck down the SEC’s CT-Plan on July 5, 2022. Without the CT-Plan to “outsource” certain SEC authority to the operating committee (2/3 SROs and 1/3 Non-SROs), how will Market Data Reform likely evolve? The Self-Regulatory Organizations (SROs), including FINRA, have stated their willingness to provide part of the expanded data under the Market Data Infrastructure Rules (MDIR). Their Odd-Lot proposal for the Securities Information Processor (SIP) may be a curve ball to the SEC. How should the SEC and market participants react or respond?
As a quick recap, the SEC’s MDIR expected that Competing Consolidators (CCs) under a Decentralized Consolidation Model (DCM) would “permit the market data infrastructure to more readily adapt to changes in technology to better fit the needs of market participants…” Many welcomed the MDIR to expand contents of core data (including depth-of-book, auction information, and more). The SROs obviously disagreed to give away the expanded content for FREE, so everyone would likely be getting a piece of the cost.
