Trading on MEMX continues to grow and diversify, with new highs in both dollars traded and market share
Highlights & Recent Developments
- MEMX total market share reached a record 4.55% on November 23rd
- MEMX hit new daily volume records on November 30th of 603 million shares and $24.8 billion notional value
- Exchange participation continues to grow and diversify, climbing to 66 member firms in November
- MEMX urges the SEC to reject the consolidated data fee proposal, read why here
MEMX exchange market share for November, which excludes off-exchange volume reported to the Trade Reporting Facility (TRF), was 7.3%, including a daily high of 8.0% on November 17th. Total market share in November hit a new high of 4.2% in all securities, with a new daily record of 4.55% on November 23rd.
Volume & Diversity of Liquidity
MEMX reached a new monthly record of $16.4 billion average daily notional traded, including a high of $24.8 billion on November 30th. Average daily share volume hit a new record of 461 million in November, including a high of 602 million shares on November 30th.
MEMX member participation continues to grow and diversify. In addition to a steady increase in new member firms, additional liquidity diversification is occurring as some firms opt to take multiple physical connections to meet their growing bandwidth and trading strategy needs and add more logical ports to segregate order flow for different customers and business lines.
MEMX Speaks Out Against Consolidated Data Fee Proposal
MEMX submitted a comment letter raising a number of issues with the consolidated data fee proposal filed by the SIP operating committees, including the following:
- The fee proposal highlights how the current governance structure is broken and conflicted. 16 firms (four independent exchanges, FINRA, and 11 firms on the advisory committee) opposed the fee proposal. However, under the current governance structure, which allocates votes to each SRO medallion, the three largest exchange groups are currently able to set pricing without support from any of the independent exchanges, FINRA, or industry advisors.
- The proposed consolidated depth-of-book fees are more expensive than comparable proprietary data feeds and would only serve to protect the proprietary feeds and deter the competing consolidators from entering the market. Our comment letter highlighted issues with both the level of fees and the methodology used to set them, noting that the flawed calculations presented in the filings appear to be little more than “lipstick on a pig” given significant unaddressed issues that MEMX raised during the fee-setting process.
- The proposal did not look at current top-of-book consolidated data fees. MEMX believes the top-of-book consolidated data products need to be more aggressively priced to compete with the proprietary data products of the largest three exchange groups, which highlights another conflict. We also recommended introducing a tiered enterprise cap on user fees, which would also help to address administrative reporting challenges and audit risks faced by firms.
What’s next? Firms should evaluate the fee proposal and provide comments to the SEC. We will continue to work with the industry to establish fair and reasonable prices for critical consolidated market data with a goal of promoting widespread access for investors.