The Securities and Exchange Commission ("Commission" or "SEC") is adopting a new rule of Regulation National Market System ("Regulation NMS") under the Securities and Exchange Act of 1934 ("Exchange Act") to conduct a Transaction Fee Pilot ("Pilot") for National Market System ("NMS") stocks to study the effects that exchange transaction fee-and-rebate pricing models may have on order routing behavior, execution quality, and market quality. We expect the data generated by the pilot, combined with data from existing sources, will facilitate an empirical evaluation of whether the existing exchange transaction-based fee and rebate structure is operating effectively to further statutory goals.