Good afternoon.  Today the Commission takes the next step in our effort to improve the equity market structure regulatory regime.  I am happy to vote to adopt the staff’s recommendation to modernize the governance framework of the equity market data plans.

The Chairman has already thanked everyone individually, but I would like to express my thanks to Director Brett Redfearn and the dedicated staff of our Division of Trading and Markets, including Michael Coe, for their work on this recommendation. I also want to thank everyone in the Division of Economic and Risk Analysis and the Office of the General Counsel who contributed to this order. Separately, I want to take a moment to thank the staff, led by Richard Holley, who worked on the two amendments to the existing equity data plans that we approved earlier this morning.  As this is Public Service Recognition Week, it is quite clear that you all are worthy of recognition for the thoughtful work you’ve done on these initiatives.  Thank you for your continued commitment to advancing this agency’s mission on behalf of investors and our markets.

Regarding the recommendation before us, I believe it is a constructive measure to address certain long-standing concerns regarding the National Market System (“NMS”) plans that facilitate the dissemination of consolidated equity quote and trade data.  I find it difficult to discuss concerns with these plans without also talking about the proprietary data feeds provided by exchanges.  As I noted at the time of the proposed order, “I do see a role for the SEC to address the potential for the proprietary feeds to be the supply that meets that demand [for market data] to the detriment of the purpose of the [Securities Information Processors (“SIPs”)] and under a governance structure where conflicts of interest exist.”[1]  While there will be further work to establish the New Consolidated Data Plan that we are ordering today, I believe that today’s action will ultimately improve the operation of the SIPs by promoting efficiencies, mitigating conflicts, and ensuring a broader base of input into the decision-making process.

I appreciate the feedback we received on the proposed order during the comment period.  While some questioned our proposal and whether it was necessary, others asserted that we had not gone far enough.  After careful consideration, I believe we strike the right balance today in recognizing the regulatory responsibilities required of the self-regulatory organizations in operating an NMS plan while acknowledging market participants’ concerns with the current structure. 

When assessing the individual provisions of this order, we must ensure that we focus on the total effect of the reforms we are adopting today and appreciate how the various elements will work together to improve the provision of consolidated market data. Such an assessment should include the modified amendments to the existing equity data plans related to policies governing conflicts of interest and confidentiality that we approved earlier today and will be incorporated into the New Consolidated Data Plan to be submitted to the Commission.  Anything less than a comprehensive evaluation does not provide for a fair appreciation of our actions.  

Lastly, as I mentioned at the outset of my remarks, this action represents the next step in our commitment to tackle difficult equity market structure issues.  As we continue to explore further improvements, I find it important to remember that our markets, and in particular our equity markets, are complex and interconnected.  When seeking to optimize our regulatory regime, we must be aware of the potential for unintended consequences.  Fact-based assessments that contemplate the full array of market and regulatory forces at play should always guide our actions.  I look forward to the Commission continuing to engage on equity market issues and want to be sure that our efforts reflect other areas that are affected by the dynamics we are addressing today, including, as I’ve mentioned before, our approach to broker-dealer execution.[2]

As I conclude, I would like to reiterate my support for the staff’s recommendation and express my appreciation for all of the feedback from commenters who took the time to engage with us on this issue.

Thank you.