Stock Market Bigwigs Tweak Fees for Trading Info Sharing
Published Date: 12/31/2025
Notice
Summary
Big stock market players teamed up to create a new fee schedule for the CT Plan, which helps share important trading info. This change affects vendors and subscribers who use this data, and it sets clear prices starting soon. The SEC is now asking for public feedback before making it official, so everyone gets a fair say!
Analyzed Economic Effects
7 provisions identified: 2 benefits, 1 costs, 4 mixed.
Inflation Adjustment: Up to 15.95% on Certain Fees
The Operating Committee proposes increasing Non‑Display Fees, Access Fees, and the Redistribution (Real‑Time Redistributor) fee by up to 15.95%, based on the Data Processing and Related Services Producer Price Index increase from 101 (January 2015) to 124.185 (May 2025). Examples of proposed fee levels include Non‑Display (ETS) per ETS: Tape A Last Sale $2,315 (from $2,000), Tape B Last Sale $1,155 (from $1,000), Tape C Last Sale $2,025 (from $3,500 previously for Tape C), Direct Access (Tape A Last Sale $1,445), Indirect Access (Tape A Last Sale $865), and Real‑Time Redistributor fees of $1,155 for each Tape.
CT Plan Proposes New Fee Schedule
On December 11, 2025 the CT Plan Members filed a Second Amendment proposing a fee schedule that sets prices charged to Vendors and Subscribers for Transaction Reports and Quotation Information in Eligible Securities. The Securities and Exchange Commission published the filing and is soliciting public comments before any final approval.
Simpler Professional/Non‑Professional Test
The Proposed Fee Schedule replaces the existing status‑based Professional vs Non‑Professional test with use‑based definitions: Professional use is (i) any use by or on behalf of an entity (with certain trust exceptions) or (ii) an individual providing a compensated service to a third party; all other use is Non‑Professional. The proposal also creates a good‑faith safe harbor that exempts real‑time redistributors from audit liability when they rely on user representations about professional usage.
Direct vs Indirect Access Redefined
The Plan would define Direct Access as "any connection within any data center in which a Processor is located" and Indirect Access as any connection that is not Direct Access. The Operating Committee states this change ties the higher fees associated with Direct Access to reduced latency and is intended to prevent gaming.
Derived Data: Display Fee Liability Removed
The Proposed Fee Schedule would eliminate fee liability for the display of single‑security Derived Data so that single‑security and multiple‑security Derived Data are not fee‑liable for display. The Plan also adds creation of Derived Data into the Non‑Display Use category, which means firms that create Derived Data (for example, index creators) will be treated as Non‑Display users and may be subject to Non‑Display fees if they were not previously paying those fees.
Per‑User Rates, Sliding Non‑Professional Scale, Caps
The proposal sets Professional per‑device rates at $26 for Tape A, $23 for Tape B, and $24 for Tape C. Non‑Professional fees shift from $1.00 per user to a sliding scale per Tape of $0.90 (1–2,000), $0.75 (2,001–50,000), $0.60 (50,001–250,000), $0.40 (250,001–1,000,000), and $0.25 (1,000,001+). The Plan also adjusts enterprise caps by reducing Tape A's cap from $686,400 to $648,000 and setting Tape B's cap at $490,000 while aligning Tape C at $648,000.
Simplified Non‑Billable Services and Exemptions
The Proposed Fee Schedule adopts simplified rules for Non‑Billable Services and exemptions: consolidated volume may be displayed with no additional fees (Volume Only), an Academic Waiver policy aligned with the CQ/CTA Plans is adopted, a System Migration exemption is allowed provided migration occurs over a reasonable period, the Disaster Recovery exemption is retained, and the previous Administrative Usage Credit is removed in favor of simply not charging fees for Administrative/Operational Use that is not based on reported usage.
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