The World Federation of Exchanges is concerned about the lack of strategic thought in the Commission's proposed Volume-Based Exchange Transaction Pricing for NMS Stocks rule. Moving away from the ubiquitous concept of volume-based pricing is a mistake. The proposed rule puts retail traders at a disadvantage and undermines the objectives of fair, orderly, and efficient markets. Furthermore, the proposed rule adversely impacts capital formation by increasing trading costs. Finally, transparency in alternative trading systems ought to be further considered. Overall, we suggest the Commission re-consider the proposed rule in light of its potential negative consequences and would welcome a more collaborative and strategic approach to regulatory decision-making.