On July 19th, the SEC designated September 23, 2011 as the date by which it will approve or disapprove the NASDAQ proposed rule change linking market data fees and transaction execution fees. The NASDAQ proposal raises issues such as whether a tying arrangement may not be consistent with the statutory requirements applicable to a national securities exchange and, in particular, whether the proposal fails to satisfy the standards under the Securities Exchange Act requiring market data fees to be equitable, fair, and not unreasonably discriminatory. SEC Release No. 34-64916.