In 2023, US stock exchanges filed 6 colocation fee rule changes with the SEC. In 2024, they filed 117. The 18-fold surge was not driven by a wave of new entrants or a regulatory mandate — it was triggered by a single cause: Nasdaq's expansion of its primary Carteret, NJ data center, known internally as NY11-4, which created new pricing categories, new cabinet tiers, and new power options that each required a separate 19b-4 filing across every Nasdaq-affiliated venue simultaneously.
NYSE dominated colocation fee filings from 2017 through 2022, filing 18–37 changes per year as it built out its Mahwah, NJ data center (NY4/NY5) and refined its cabinet and cross-connect pricing. Nasdaq, Cboe, and MIAX filed few or no colocation rule changes during that period. Then, in 2024, the dynamic reversed entirely.
NYSE filed zero colocation fee changes in 2024 after averaging 18 per year from 2017 to 2022. The exchange's Mahwah infrastructure was mature, and NYSE Group did not open a new major data center facility during this period. Nasdaq's 2024 surge of 89 filings accounts for 76% of all 2024 colocation filings industry-wide. Cboe contributed 24 filings — up from zero in most prior years — reflecting new connectivity product launches across its four US equity venues (BZX, BYX, EDGX, EDGA).
The 2026 data (through May 25) shows Nasdaq continuing at an elevated pace, with 30 colocation filings in less than five months — and a seventh venue, Nasdaq Texas (NasdaqTX), appearing for the first time in March 2026 as the exchange's newest market begins establishing its fee schedule.
Nasdaq's elevated filing count is partly structural. When Nasdaq changes a colocation fee, it must file a separate 19b-4 with the SEC for each registered exchange it operates. In 2024, that meant six venues: The Nasdaq Stock Market (NASDAQ), Nasdaq BX (BX), Nasdaq PHLX (PHLX), Nasdaq ISE (ISE), Nasdaq GEMX (GEMX), and Nasdaq MRX (MRX). A single pricing decision generates six simultaneous filings.
On March 6, 2024, Nasdaq filed identical colocation fee changes across all six of its venues at once. The same occurred on March 21, March 26, May 17, July 18, July 31, September 16, September 24, October 11, October 31, November 27, and December 6 — twelve separate batches of six. Four additional batches targeted subsets of venues for venue-specific changes.
Each filing is immediately effective under Section 19(b)(3)(A), meaning the fees take effect on the filing date. The SEC has 60 days to suspend an immediately effective filing — it has not done so for any of Nasdaq's 2024 colocation changes.
The batch dates reveal a monthly-or-more cadence throughout 2024. The March batches were driven by the 5.5% general fee increase across all General 8 (connectivity and co-location) services. The July–December batches were largely driven by new fee structures for the NY11-4 data center expansion.
Nasdaq's primary co-location facility is NY11, located in Carteret, New Jersey. As demand for power and cabinet space grew, Nasdaq began an expansion of the facility — designated NY11-4 — to add new capacity. The expansion created pricing scenarios that had never existed before, each requiring its own 19b-4 filing:
The table below shows raw colocation filing counts per exchange group per year. NYSE's dominant position in 2017–2022 reflects its decade-long buildout of the Mahwah and Secaucus data centers. The sharp reversal in 2024 reflects Nasdaq's NY11-4 investment cycle.
| Exchange | 2017 | 2018 | 2019 | 2020 | 2021 | 2022 | 2023 | 2024 | 2025 | 2026* | Total |
|---|---|---|---|---|---|---|---|---|---|---|---|
| NYSE Group | 18 | 16 | 30 | 37 | 20 | 11 | 5 | 0 | 5 | 0 | 142 |
| Nasdaq | 2 | 6 | 0 | 0 | 0 | 0 | 1 | 89 | 7 | 30 | 135 |
| Cboe | 0 | 0 | 1 | 0 | 0 | 0 | 0 | 24 | 16 | 4 | 45 |
| MIAX | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 4 | 8 | 0 | 12 |
| BOX | 0 | 0 | 2 | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 2 |
| Total | 20 | 22 | 33 | 37 | 20 | 11 | 6 | 117 | 36 | 34 | 336 |
* 2026 data through May 25, 2026 (partial year). Source: SEC Federal Register 19b-4 filings database.
NYSE Group filed zero colocation fee rule changes in 2024 — a sharp contrast to the 11–37 it filed annually from 2017 to 2022. The last significant NYSE colocation action before 2025 was a June 2023 batch across five venues (NYSE, NYSE Arca, NYSE American, NYSE National, NYSE Chicago) amending Partial Cabinet Solution bundles. In 2025, NYSE returned with a small five-venue batch in October, including the newly-formed NYSE Texas.
The divergence between NYSE and Nasdaq in 2024 reflects different infrastructure cycles. NYSE's Mahwah, NJ (NY4/NY5) campus — one of the largest financial data centers in the world — was fully operational throughout this period, requiring only incremental pricing refinements. Nasdaq's Carteret expansion represented active capital deployment into new capacity, which naturally produces more regulatory filings as new products and pricing tiers are established.
NYSE Texas's appearance in October 2025 parallels NasdaqTX's 2026 debut: new exchange venues must file their colocation fee schedules from scratch, briefly elevating filing counts before settling into a maintenance cadence.
Colocation (colo) refers to the practice of housing a trading firm's servers in the same physical data center as the exchange's matching engine. Because electronic trading is latency-sensitive to the microsecond level, physical proximity to the exchange reduces round-trip signal times and provides a structural performance advantage.
Exchange colocation fee schedules typically cover: cabinets (rack space, measured in U-height and power density), power (kW allocation and power distribution units), cross-connects (fiber cables between customer cages and exchange infrastructure), external telco/inter-cabinet connectivity (connections between customer racks in different areas of the same data center), and market data connectivity feeds (direct feed subscriptions delivered over physical infrastructure).
Physical port fees (the subject of Study 3) are a related but distinct product — they cover direct fiber circuits to the exchange matching engine rather than cabinet space in the same building.
The SEC's oversight role over colocation fees stems from a 2010 concept release and subsequent regulatory guidance establishing that colocation services provided by exchanges in connection with their trading operations constitute exchange services subject to the fee filing requirements of Section 19(b). As a result, any change to colocation pricing — adding a new cabinet tier, changing a power allocation rate, adjusting a cross-connect fee, or offering a new reservation program — requires a 19b-4 filing.
This creates an inherent filing multiplier for exchanges that operate multiple registered venues. Nasdaq's six venues in 2024 meant every single colocation product decision generated six rule filings. When Nasdaq launched Ultra High Density Cabinets in NY11-4, that was not one filing — it was six.
Cboe's 24 colocation filings in 2024 represent a sharp uptick from the 0–1 filings per year it had filed from 2017 to 2023. The filings were spread across Cboe's four US equity venues (BZX, BYX, EDGX, EDGA) in coordinated batches — typically all four venues filing on the same date or within days of each other.
Unlike Nasdaq's filings, which were driven by a specific infrastructure event, Cboe's 2024 colocation activity appears to reflect new connectivity product launches — including a new connectivity offering announced in mid-2024 — rather than a single data center buildout. Cboe's colocation filings continued at a reduced but elevated pace in 2025 (16 filings), suggesting this represents a new normal rather than a one-time event.
MIAX filed four colocation changes in December 2024, simultaneously across all four MIAX venues (MIAX, MIAX Pearl, MIAX Emerald, MIAX Sapphire), followed by eight more in 2025. Like Cboe, MIAX appears to be entering a phase of more active colocation fee management after years of minimal activity in this category.
Source: All 19b-4 filings published in the Federal Register from January 1, 2017 through May 25, 2026, for exchanges in the NYSE, Nasdaq, Cboe, MIAX, BOX, IEX, MEMX, and LTSE families. Data extracted via the Federal Register API and stored in a local SQLite database.
Classification: Filings are classified as FEE_COLOCATION when their title contains keywords including "colocation," "co-location," "cabinet," "cage," "colo," or "cross-connect" (case-insensitive). This is a title-based classification; body text is not read during classification. Filing bodies for key 2024 filings were read directly for this study to verify the NY11-4 narrative.
Filing attribution: Each exchange venue is counted separately. When Nasdaq files across 6 venues on the same date, that counts as 6 filings. This matches the regulatory reality — each is a distinct legal filing with the SEC.
Limitations: The title-based classifier may miss filings that describe colocation fee changes without using standard keywords (e.g., a filing titled "Amendment to General 8 Fee Schedule" would be classified as FEE_OTHER). The true count of colocation fee changes may be modestly higher than reported here.