Good morning, and welcome. My views are my own as a Commissioner and not necessarily those of the SEC or my fellow commissioners. I want to begin by expressing my sincere gratitude to all the panelists, to the University of Austin for your generous hospitality, and to the Commission staff, especially from the Division of Trading and Markets and the Office of Public Affairs, who pulled together this roundtable in record time. I also want to welcome the students in attendance – your presence adds a valuable perspective to our conversation and may even inspire some of you to dip your toes into the enticing waters of equity market structure. One important regulatory determinant of market structure in the United States is the order protection rule, also known as the trade-through rule, or Rule 611. If we were ranking whether to revisit Rule 611 on a scale of 1 to 10, with 10 being definitely revisit the rule, my gut gives me the middle schoolers’ go-to answer these days: 6 . . . 7. But a 6 or 7 on redoing 611 is an answer without context. The necessary context consists of several factors. First, the U.S. equity markets are unmatched in depth and liquidity, which raises the stakes of any reform. Second, as many of the September 18 roundtable’s panelists noted, the distinctiveness of our markets means that lessons from other jurisdictions may not always be instructive — particularly in areas like best execution and volume thresholds. Third, Rule 611 is intertwined in a complex nest of rules within which equity markets live. Revisiting Rule 611 requires rethinking those other rules too. That message came through loud and clear at the September roundtable. While that roundtable featured robust debate over whether Rule 611 should be repealed, retained, or revised, it also reflected broad agreement that any changes to Rule 611 must be considered alongside related NMS rules, NMS plans, and FINRA regulations. Today we will talk about potential changes to access fee caps, the prohibition on locked and crossed markets, the fair access rule, the SIP revenue allocation model, FINRA’s best execution rule, and more.[1] Fourth, how we implement any changes, including how we sequence changes, will matter. Given the expertise our panelists bring, I anticipate that this roundtable will provide the context necessary to boost my interest in reconsidering Rule 611 all the way up from a 6 or 7 to a 10. I have been a skeptic of Rule 611 since its inception twenty years ago. Dictating how market participants execute trades has never seemed like an exercise for which the SEC is well-suited. People operating in free and transparent markets are good at figuring out how and where to execute trades or finding a professional to help them do so. Rule 611 rests for authority on Section 11A, a 1975 addition to the Securities Exchange Act, which directed the SEC to facilitate the establishment of a national markets system. The mandate is a relic of a time of active government interference in and distrust of markets. Rather than adopting Rule 611 thirty years after Congress gave us this authority, the SEC instead could have deferred to the technology that was eating away at market monopolies and facilitating cross-market arbitrage. Even those of you who disagree with me on this point might agree that Rule 611 has completed its work and may be causing more mischief than good. As emphasized in the previous roundtable, this moment presents a rare opportunity to strengthen our markets. While opinions differ on how well our current market structure serves investors, one trend is undeniable: off-exchange trading volumes are rising, yet new exchanges, many of which replicate existing ones, continue to proliferate. This dynamic points to misaligned incentives and suggests the need for reform. I am anticipating an organic conversation that requires little prompting, but I have a few questions that panelists may want to address: Given that some people view Rule 611 as a best execution backstop, if we eliminate it, how can we craft best execution amendments or guidance to offer clarity without being overly prescriptive? Are there any best execution clarifications that are needed now, independent of any changes to Rule 611? What is the optimal SIP revenue allocation between quoting and trading activity that will curb unnecessary exchange proliferation without foreclosing innovative new entrants in the exchange space? Is readjusting this allocation an interim step on the way to repealing Rule 611? What SEC and FINRA rules would need to be amended if Rule 611 were to be repealed? In the event we propose changes to Rule 611, how should changes to these other NMS rules, plans and FINRA rules be sequenced? Which changes must occur concurrently, which can follow, and which should precede any changes to Rule 611? As the SEC works with market participants experimenting with tokenization, can we draw any lessons that might be relevant to revisiting Rule 611? I look forward to a productive discussion. Thank you. [1] Still other issues may be appropriate for the Commission to tackle later, such as SRO fee filings, and of course, the options market, which is due its own roundtable.

Xceptor, a global leader in data automation for capital markets, today announced significant AI-powered enhancements to its solution delivery operations, designed to speed up deployment and minimise associated risk. The new capabilities include an enhanced upgrade toolkit for on-premises environments and ai-exceptions-bot, an AI agent for SaaS updates within the Xceptor Data Automation Platform. By streamlining solution delivery, Xceptor enables financial institutions to access innovation and reduce technical debt faster, while strengthening operational resilience, agility, and compliance across the trade lifecycle.     Built with AI, the upgrade toolkit performs a precise analysis of Xceptor configuration files and automates over 30 manual checks to identify potential breaking changes before upgrades occur. This proactive approach reduces risk and manual effort, improves accuracy, and decreases time to market, delivering a smoother upgrade experience for clients.     ai-exceptions-bot transforms exceptions handling and increases confidence in SaaS deployments. Acting autonomously, the agent detects software regressions and recommends fixes for an Xceptor engineer to review and implement. This accelerates release cycles while reducing manual checks, bringing faster updates to clients without compromising quality. As part of Xceptor’s advanced quality assurance toolkit for SaaS, ai-exceptions-bot leverages platform telemetry to deliver updates efficiently and minimise delivery risk.    “AI has long been part of Xceptor’s DNA, and we see enormous value in using it to deliver faster innovation to our clients,” said Dan Reid, CTO and Founder at Xceptor. “This is particularly impactful in capital markets, where institutions often struggle to move at speed due to complex infrastructure and stringent regulatory requirements. Being able to respond rapidly to our clients’ needs enables them to transform their operations and meet new demands faster. This is a good example of how we apply AI only where it truly excels - solving real-world challenges today without compromising transparency or control.” 

EDX Markets, a leading digital asset technology firm that combines an institutional-only trading venue with a central clearinghouse, today announced a strategic partnership with the Canton Network, the public, permissionless blockchain purpose-built for institutional finance. Both EDX and the Canton Network are backed and leveraged by leading blue-chip institutions in traditional finance. EDX Markets will list Canton Coin on its spot exchange for its clients to trade and settle, as well as support settlement in stablecoins on the Canton Network, enabling institutions to trade with greater speed and capital efficiency while providing the regulatory safeguards and operational oversight they expect. EDX will also operate as a validator on Canton, further strengthening the network’s security and governance as it continues to scale adoption across global financial markets. “Partnering with the Canton Network is a natural extension of our commitment to deliver high-performance, institution-ready infrastructure to the digital asset marketplace,” said David Olsson, Chief Commercial Officer for EDX Markets. “By supporting stablecoin settlement on Canton and participating directly in network validation, we’re advancing our mission to provide secure, compliant and efficient solutions that meet the needs of institutional investors.” The partnership underscores the shared mission of EDX Markets and Canton to accelerate the institutional adoption of digital assets. Together, the firms provide market participants with industry-leading infrastructure to securely engage with tokenized assets, modernize legacy workflows and unlock new trading opportunities. “We’re delighted to welcome EDX Markets as both a validator and a strategic partner,” said Melvis Langyintuo, Head of Canton Foundation. “EDX shares our commitment to meeting institutional requirements for privacy, security, compliance and scalability. Their involvement will help accelerate the development of new capabilities for institutions building on Canton.” EDX and Canton will continue to collaborate on new initiatives to advance the institutional adoption of digital assets, with additional integrations and joint programs anticipated in the coming months.

The Office of the Comptroller of the Currency (OCC) today reported the key issues facing the federal banking system in the Semiannual Risk Perspective for Fall 2025. The OCC reported that the strength of the federal banking system remains sound. Balance sheets remain satisfactory with high capital and liquidity ratios that are well-positioned to absorb potential stress. Financial innovation presents banking opportunities. A lack of investment in new technologies, products, and services may present material risks to long-term bank performance and viability of institutions. The OCC fosters a regulatory environment that enables banks to advance their businesses and client interests while managing financial risks and operating in a safe and sound manner. The OCC highlighted credit, market, operational, and compliance risks, as key risk themes in the report. Highlights from the report include: Commercial and retail loan portfolio delinquencies, loss rates, and noncurrent and classified levels remain manageable. Liquidity remains sound. The OCC has observed an increase in threats posed by foreign state-sponsored actors and sophisticated cybercriminal groups, targeting the financial sector. Banks continue to face challenges from elevated levels and sophistication of fraud, including scams. Related Link OCC Semiannual Risk Perspective for Fall 2025 (PDF)

SIFMA and the Financial Services Sector Coordinating Council (FSSCC) today published an updated version of The Financial Services Sector Reconnection Framework, which is designed be used by a firm which has been compromised by a cyber incident. The SIFMA Framework has been updated jointly by both organizations, addressing the scope of reconnection issues across the industry in order to produce a product suitable for broader adoption by the financial services sector. The document provides a five-step mitigation framework – assess, remediate, assure, reconnect and recover – and is intended to support and inform a technical view of reconnection as well as broader resilience planning. “There are many issues that a firm compromised by a cyber incident must first address in order to reconnect to the financial ecosystem after a cyber event has been contained and mitigated,” said Tom Wagner, managing director, Financial Services Operations at SIFMA. “Most importantly is how the firm should communicate, coordinate and provide assurance to what could be dozens of trading partners in the most efficient and effective way to convey that the problem has been resolved and will not recur. This is crucial so the firm and its trading partners can resume normal business as usual operations.” SIFMA’s Reconnection Framework was originally published in 2020 with the endorsement of U.S. Department of the Treasury, the Analysis and Resilience Center for Systemic Risk (ARC), the Financial Services Information Sharing and Analysis Center (FS-ISAC), FSSCC, sector trade organizations such as the Bank Policy Institute (BPI) and over thirty financial services firms. The original document set out expectations the financial sector has on global systemically important financial institutions in the event of a cyber incident that disrupts critical business operations. Since then, the complexity of the financial services supply chain and the role of relatively small, but nonetheless critical, third-party providers have only increased. At the same time, the world is experiencing a more hostile cybersecurity environment than at any other time in modern history. Through this period, the sector has continued to experience incidents resulting in the disconnection of third parties and the subsequent process of attempting to gain enough assurances about the status of their security to allow for reconnection. As a result, SIFMA responded to broader concerns about third-party resilience by working with its members to update the Framework in 2023. “The Financial Services Sector Reconnection Framework marks an important step on our sector’s preparedness journey,” said FSSCC Chair and PNC Head of Technology Debbie Guild. “This tool will empower firms of all sizes to confidently shape their own reconnection strategies and provides clarity around the sector’s expectations for third party providers. It will help our industry remain resilient and adaptable in the face of an evolving threat landscape.” SIFMA’s Framework has gained wide recognition across the financial sector, including internationally, where the United Kingdom Cross Market Operational Resilience Group (CMORG) and other systemically important financial institutions used it as the basis for their own Reconnection frameworks. The SIFMA/FSSCC and CMORG frameworks are now highly aligned, which demonstrates the demand for a holistic framework usable across the entire financial sector. The Framework is available here.

Thank you to the Division of Trading and Markets for organizing this Roundtable on equity market structure and, more specifically, Rule 611 of Regulation NMS. I have been at the SEC for nearly twenty years, and one of my observations is that people often will be more open with their thoughts when meeting outside of Washington, D.C. However, these events take more effort, and I appreciate the contributions of the University of Austin for making this Roundtable possible in Texas. Regulation NMS may have been well‑intentioned, but its implementation has coincided with shrinking displayed size, a significant increase in the number of execution venues, and complex routing behavior that is often difficult to explain to investors. Thus, I commend Chairman Atkins for initiating this review of Rule 611 and inviting market participants to help the SEC evaluate whether the Regulation NMS framework is truly serving investors and our markets. By revisiting the trade‑through regime, we have an opportunity to move to a less costly, more resilient, and more transparent market structure—which would make our markets even stronger. This is not an easy task. My predecessor, Commissioner Elad Roisman, likened our equity market structure rules to the threads of a sweater: pull on one, and you inevitably stress the others—sometimes in unexpected ways.[1] I hope that these Roundtable sessions, and the public comments submitted, help identify many of the other “threads” in Regulation NMS that interconnect with Rule 611, so that we can assess the consequences that might result from potential regulatory changes. One discussion that I look forward to hearing today is on the topic of best execution. A broker-dealer’s obligation to seek best execution of customer orders is one of the “cornerstones of market integrity.” [2] As I noted when the Commission proposed new rules in this area two years ago, best execution is a concept that has been developed by court holdings and specific rules from self-regulatory organizations.[3] But to what extent does our current best execution regime presuppose or rely on entities’ fulfillment of Rule 611? Are there other considerations that should be required if this rule is altered? The Commission should have compelling evidence of need before adding layers on top of the best execution regime already imposed by FINRA.[4] Do panelists think that such a need would arise if Rule 611 were to change and, if so, why? Relatedly, are there further ways that the Commission could increase transparency so that investors, counterparties, and regulators could observe execution quality across venues and enhance private ordering in this area? In 2024, the Commission adopted rule changes to modernize the reports required by Rule 605 to reflect how trading occurs in microseconds across multiple venues.[5] In what other areas would transparency be needed for market participants to have the tools to assess execution quality on their own? Once again, I appreciate the thoughtful approach taken by the Commission staff to consider the entire regulatory framework holistically. This undertaking presents an opportunity for a serious retrospective review of Regulation NMS and Rule 611. With the public’s input, I hope that the Commission can tackle these hard problems with evidence‑based proposals so that our market structure regulations can most effectively serve investors, intermediaries, and issuers. [1] Commissioner Elad L. Roisman, “Remarks at the SIFMA Equity Market Structure Conference: The Dynamics of our Markets and the Changing Structure on which they are Built” (Sept. 19, 2019), available at https://www.sec.gov/newsroom/speeches-statements/roisman-remarks-sifma-equity-market-structure-conference-091919. [2] See Division of Market Regulation, Market 2000: An Examination of Current Equity Market Developments, available at https://www.sec.gov/divisions/marketreg/market2000.pdf. See also Regulation NMS Adopting Release at 37537, note 338. See also Securities Exchange Act Release No. 37619A (Sept. 6, 1996), 61 FR 48290 (Sept. 12, 1996). [3] See FINRA Rule 5310 and MSRB Rule G-18. See also Commissioner Mark T. Uyeda, “Statement on Proposed Rule Regarding Best Execution” (Dec. 14, 2022), available at https://www.sec.gov/newsroom/speeches-statements/uyeda-best-excution-20221214#_ftnref2. [4] See Commissioner Mark T. Uyeda, “Statement on Proposed Rule Regarding Best Execution” (Dec. 14, 2022), available at https://www.sec.gov/newsroom/speeches-statements/uyeda-best-excution-20221214#_ftnref2. [5] See Commissioner Mark T. Uyeda, “Statement on Rule Amendments Regarding Disclosure of Order Execution Information” (Mar. 6, 2024), available at https://www.sec.gov/newsroom/speeches-statements/uyeda-statement-order-execution-quality-030624.

The Alberta Securities Commission (ASC) has issued a Notice of Hearing alleging that Calgary residents Dean Labbe and Julie Labbe engaged in illegal insider trading. According to the Notice of Hearing, between May 2018 and June 2024, Dean Labbe worked on mergers and acquisitions, and other business transactions, at an investment bank. Through his employment, he acquired material non-public information (MNPI) about publicly-traded companies. It is alleged that he and his mother Julie Labbe used this MNPI for highly-profitable trading. It is further alleged that, on one occasion, while in possession of MNPI about a specific company, Dean Labbe recommended or encouraged two individuals to purchase shares of that company. These are allegations and have not been proven in a hearing. An appearance to set a date for a hearing will be held on December 18, 2025 at 9:00 a.m. in the ASC Hearing Room, located on the 5th floor, 250 – 5 Street S.W., Calgary, Alberta. A copy of the Notice of Hearing can be found on the ASC website. The ASC gratefully acknowledges the assistance of the Autorité des marchés financiers (AMF) in this matter. The ASC is the regulatory agency responsible for administering the province’s securities laws. It is entrusted with fostering a fair and efficient capital market in Alberta and with protecting investors. As a member of the Canadian Securities Administrators, the ASC works to improve, coordinate and harmonize the regulation of Canada’s capital markets.

Please be advised the MIAX Options Exchange, MIAX Pearl Options Exchange, MIAX Emerald Options Exchange, MIAX Sapphire Options Exchange and MIAX Pearl Equities Exchange will be closed on Thursday, December 25, 2025 for Christmas Day and Thursday, January 1, 2026 for New Year’s Day.On Wednesday, December 24, 2025, the MIAX Exchanges will have an abbreviated trading session. Trading in all option classes and equity issues will close 3 hours early.

Good morning. Welcome to our second Roundtable on the Trade-Through Prohibitions of Regulation NMS, including those watching online. I’m Jamie Selway, the Director of the Division of Trading and Markets. Thank you, Chairman Atkins for your remarks and for your leadership on a policy issue that is central to equity market structure. Thank you, Commissioners Peirce, Crenshaw and Uyeda, for your remarks as well. Thank you to my dedicated Division colleagues, including Ted Venuti, Arisa Kettig, David Liu and Kevin Brennan for gathering us here today and Jon Kroeper, Kelly Riley, Peggy Sullivan, and David Dimitrious, who join me as moderators. Thank you to the University of Austin, a new institution successfully bringing two of our favorite forces – innovation and competition – to bear to disrupt the market for undergraduate education, for allowing us to use its facilities for today’s event. And most importantly, thank you to our panelists. Today’s participants represent a wide variety of expert perspectives in equity markets shaped by nearly twenty years of operational experience with Regulation NMS. We are confident that your contributions will meaningfully inform the Commission’s next steps. Before proceeding further, please note that my remarks today are provided in my official capacity as the Commission’s Director of the Division of Trading and Markets, and do not necessarily reflect the views of the Commission, the Commissioners, or members of the staff. This disclaimer also applies to the comments of my Division colleagues who will join me to moderate today’s panels. On November 4, the citizens of the great state of Texas approved a ballot measure to make certain securities transaction taxes unconstitutional. Now, to anyone whose professional life, or private enthusiasms, involves “trading” or “markets,” this was a welcome development. Our Nation’s laboratories of democracy are a potent force for progress. The free air of Texas inspires and invigorates—and reminds us that markets work. Today’s event continues a journey that the Division began earlier this year. In July, we invited public comment on the trade-through prohibitions applicable to the equities and options markets. In September, we hosted a Roundtable to discuss the issues associated with such prohibitions. We heard informed points of view and received thoughtful feedback. Many participants voiced concern with the status quo and supported a reexamination of the trade-through prohibitions applicable to NMS stocks contained in Rule 611 of Regulation NMS, commonly known as the Trade-Through Rule. As many noted, the Trade-Through Rule is intertwined with other rules and regulations that must be carefully considered should the Commission decide to rescind or modify the Trade-Through Rule. At the time the Trade-Through Rule was adopted, many, including Chairman Atkins, warned that its complexity would lead to negative unintended consequences. Twenty years later, we acknowledge this complexity, and we pay keen attention to such warnings. Accordingly, today’s Roundtable aims to illuminate the Trade-Through Rule’s entanglements with other requirements, so that if the Rule is removed or altered, our market structure is improved, not damaged. We expect another lively, thought-provoking discussion today. We have designed the panels to more deeply consider the ramifications of rescinding or modifying the Trade-Through Rule. When the Trade-Through Rule was proposed as part of Regulation NMS, commenters emphasized the futility of protecting the best displayed prices against trade-throughs if those prices were not fairly and efficiently accessible. Rule 610 promotes fair and non-discriminatory access to quotations displayed in the national market system. As adopted, Rule 610 sets forth standards governing access to quotations in NMS stocks, with the stated goal of promoting access in three ways: enabling private linkages, limiting access fees, and restricting locking or crossing quotations. During the September Roundtable and in comments received, contributors urged consideration of the contrapositive—are all of the requirements included in Rule 610 necessary if the Trade Through Rule is rescinded or modified? Our first panel will tackle this question. Much of Regulation NMS’s substance is contained in its defined terms. Our second panel will drill down on the necessary changes, if any, that may need to be made to the definitions contained in Rule 600 if the Trade-Through Rule was to be modified or rescinded. Of particular importance is any effect on the national best bid and national best offer – the NBBO. A robust, transparent, reliable NBBO is essential in promoting fair, efficient, and liquid markets—and the U.S. capital markets are rightly known as the most liquid in the world. For this reason, decades of Commission oversight of consolidated market data have centered on ensuring that the NBBO remains ground zero for price discovery and a consistent baseline for best execution. The second panel will also consider the incentives associated with the current formula for market data revenue allocation and how these incentives affect the marketplace. Finally, our third panel will consider potential enhancements to the best execution requirements, including whether additional guidance is necessary if changes to the Trade-Through Rule and associated rules are made. During the September Roundtable and through comments submitted, many highlighted the relationship between the Trade-Through Rule and best execution, suggesting that Trade-Through Rule changes could raise questions about how a broker-dealer should handle and execute customer orders. The duty of best execution predates the federal securities laws. Its origin lies in the “common law agency obligations of undivided loyalty and reasonable care that an agent owes to his principal.”[1] These duties are not merely historical—they remain essential today because executing customer orders is a core function of broker-dealers. Upholding best execution is not an empty tradition. Best execution is an evergreen obligation at the core of a broker-dealer’s relationship with its customer. Over the years, a number of considerations have been identified by the courts, the Commission, and FINRA as relevant to best execution. These include not only price, but also speed of execution, clearing costs, size of the order, and the cost and difficulty of executing in a particular market, among others. As then-Commissioner Atkins and Commissioner Cynthia Glassman pointed out at the time of Regulation NMS’s adoption, the Trade-Through Rule seemed to elevate “price [as] the sole criterion for determining how and where orders will be executed” and believed that the Trade-Through Rule restricted “investor choice and ability to obtain best execution.”[2] Of course, FINRA’s role in this area is critical. A best execution rule was first introduced in 1968 by its predecessor, the NASD, laying the groundwork for what would become FINRA’s current rule, approved in 2011. Built on decades of experience with the predecessor rule and guidance, this framework has helped shape how market participants fulfill their obligations. As we consider the evolving market structure and the potential for changes to the Trade-Through Rule, we welcome a thorough examination of FINRA’s best execution rule, its accompanying guidance, and any enhancements that could strengthen its ability to serve investors effectively. Again, many thanks to all for participating in today’s Roundtable. We have our boots on—and we’re ready to ride.   [1] See, e.g., Newton v. Merrill, Lynch, Pierce, Fenner & Smith, Inc., 135 F.3d 266, 270 (3d Cir.), cert. denied, 525 U.S. 811 (1998). [2] Dissent of Commissioners Cynthia A. Glassman and Paul S. Atkins to the Adoption of Regulation NMS (June 9, 2005).

Good morning, ladies and gentlemen. I am pleased to join my fellow Commissioners and Jamie Selway, director of our Division of Trading and Markets, in welcoming you to today’s roundtable. I should also like to acknowledge and thank the University of Austin for providing the setting for today’s program; our esteemed panelists for contributing their perspectives; and our audience, whether here on campus or by livestream, for taking part in this important discussion. Finally, before I share a few reflections, I must add that the views I express this morning are my own as Chairman and do not necessarily reflect those of the SEC as an institution or of the other Commissioners. As I noted at our September roundtable, the SEC adopted Regulation NMS at a time of profound transformation. Electronic trading systems were continuing to unsettle old assumptions about how markets could function as handling and routing practices became more transparent, competition drove commissions lower, and penny pricing reshaped the mechanics of trading. Rather than meet these disruptions with a measured approach, in 2005 the Commission decided to impose prescriptive rules and dictate very specific processes to address what it perceived as ills—even as these new trends and technologies were still evolving. Worse, the staff came out with repeated rounds of FAQs to ameliorate the challenges that their problematic rules engendered. While I fully supported then, as I do now, the worthy goal of enhancing market efficiency, then-Commissioner Cynthia Glassman and I objected to Reg NMS’s adoption because we believed that the rigidity of its regime, especially Rule 611, would hinder, rather than enhance, the long-term growth of our markets. Two decades have given us the benefit of perspective, and the verdict is clear: Reg NMS, built on flawed foundations, has invited gamesmanship and contributed to the fragmentation of our markets, the dispersal of liquidity, and diminished transparency. The very outcomes that we feared have come to pass. Our warnings are now lessons. And Reg NMS—Rule 611’s trade-through prohibitions in particular—command a fresh look so that we can continue to strengthen our securities markets. Indeed, we must summon the courage to acknowledge when well-intended policies have produced unintended consequences. To this end, our first roundtable engaged an array of industry participants, academics, and regulators in Washington, for a very fruitful initial discussion. Their perspectives, along with the thoughtful comment letters that we have since received, underscore a broad consensus: revisiting Rule 611 is a worthwhile and overdue endeavor. While views may vary on the scope of potential changes, a significant number of panelists and commenters believe that the rule should be modified or rescinded entirely. In September, we also heard several potential paths forward, including volume thresholds for protected quotes, block exceptions, rescinding the locked and crossed market prohibition, adjustments to access fee caps, and revisions to the market data revenue allocation formula. Each of these proposals merits serious consideration. Yet as I cautioned two decades ago, we must take a careful, deliberative approach to any changes, lest we make the mistakes that brought us here. So today, we take a necessary next step in that process. Of course, we will continue our discussion of the trade-through prohibitions. But we will also delve more deeply into how Rule 611 intersects with other parts of Reg NMS rules and our market structure more broadly. Specifically, our first panel will focus on Rule 610 and its requirements relating to fair access, access fees, and locked/crossed markets. Our second group of panelists will then discuss Rule 600, including the defined terms intertwined with the trade-through rule, the effects on the NBBO, as well as the incentives associated with the market data formula revenue allocation from the consolidated market data plans. Finally, our third panel will examine potential enhanced best execution guidance if the Commission modifies or rescinds the trade-through prohibitions of Rule 611. Today’s roundtable will help to ensure that we do not saddle a future Commission—or the next generation of investors and market participants—with the same set of challenges that we left for ourselves two decades ago. We owe it to them to be thoughtful, to be rigorous, and to be reflective. So, I want to thank our panelists and moderators once more for being here. I should also like to encourage members of the public to continue sharing your perspectives through our comment file. As we undertake this reassessment of Reg NMS, your insights are indispensable. I look forward to today’s discussions and to the takeaways that will emerge from them. Thank you all for being here, and for your continued engagement in the critical work before us.

The Canton Network, the privacy-enabled blockchain purpose-built for regulated financial markets, today announced World Liberty Financial's (“WLFI”) intention to deploy its USD1 stablecoin on Canton. This planned integration represents a significant milestone in WLFI’s strategy to expand USD1’s reach across institutional onchain finance and accelerate adoption among regulated global market participants. USD1 has rapidly emerged as one of the fastest-growing digital dollar stablecoins, surpassing a $2 billion market capitalisation. Built to institutional standards, USD1 is a fully reserved, 1:1 redeemable digital asset, backed entirely by short-term U.S. government treasuries, U.S. dollar deposits, and other cash equivalents.  By planning to launch USD1 on the Canton Network, WLFI aims to expand the stablecoin’s capabilities into a regulated, interoperable ecosystem designed for global finance. Canton’s architecture allows institutions to settle tokenized assets and stablecoins with privacy, control, and compliance, enabling a wide range of high-value financial use cases, including: Collateralization for derivatives and institutional lending Instant, cross-border payments with 24/7 settlement Onchain asset issuance, funding, and redemption Interoperable onchain financing across institutions and markets “Institutions around the world, from sovereign entities to global asset managers, are looking for a trusted and purely digital U.S. dollar,” said Zak Folkman, Co-Founder and Chief Operating Officer of World Liberty Financial. “Our intention to deploy USD1 on Canton will allow regulated institutions to transact securely and privately while leveraging the programmability and efficiency of blockchain technology. Canton’s institutional-grade infrastructure creates an ideal foundation for real-world digital dollar settlement.” “WLFI’s move to bring USD1 to Canton highlights the growing demand for compliant, interoperable digital assets within institutional markets,” said Melvis Langyintuo, Executive Director of the Canton Foundation. “Canton’s privacy-first architecture enables stablecoins like USD1 to power next-generation financial applications, from intraday repo to digital bond settlement, without compromising regulatory requirements.”

CUSIP Global Services (CGS) today announced the release of its CUSIP Issuance Trends Report for November 2025. The report, which tracks the issuance of new security identifiers as an early indicator of debt and capital markets activity over the next quarter, found a monthly increase in request volume for new corporate identifiers and a monthly decrease in volume for new municipal identifiers. North American corporate CUSIP requests totaled 8,572 in November, which is up 4.1% on a monthly basis. On an annualized basis, North American corporate requests were up 8.3% over November 2024 totals. Requests for new U.S. corporate debt identifiers rose 8.6% while requests for new U.S. corporate equity identifiers declined 9.1% for the month of November. The aggregate total of identifier requests for new municipal securities – including municipal bonds, long-term and short-term notes, and commercial paper – fell 12.5% versus October totals. On a year-over-year basis, overall municipal volumes were up 14.9% through the end of November. Texas led state-level municipal request volume with a total of 169 new CUSIP requests in November, followed by California (83) and New York (78). “Corporate request volumes continue to surge, this month led by corporate debt issuers,” said Gerard Faulkner, Director of Operations for CGS. “With strong momentum heading into the final month of the year, we anticipate closing out 2025 with most core asset classes showing year-over-year growth in new CUSIP request volumes.” Requests for international equity CUSIPs fell 17.7% in November and international debt CUSIP requests rose 5.2%. On an annualized basis, international equity CUSIP requests were up 13.8% and international debt CUSIP requests were up 10.3%. To view the full CUSIP Issuance Trends report for November, please click here. Following is a breakdown of new CUSIP Identifier requests by asset class year-to-date through November 2025: Asset Class 2025 YTD 2024 YTD YOY Change U.S. Corporate Debt 32,077 24,679 30.0% Long-Term Municipal Notes 732 595 23.0% Private Placement Securities 4,982 4,269 16.7% Municipal Bonds 10,871 9,463 14.9% International Equity 1,744 1,533 13.8% International Debt 6,580 5,967 10.3% Canada Corporate Debt & Equity 6,007 5,616 7.0% U.S. Corporate Equity 11,149 10,690 4.3% Syndicated Loans 2,844 2,802 1.5% Short-Term Municipal Notes 1,006 1,070 -6.0% CDs < 1-year Maturity 8,582 9,242 -7.1% CDs > 1-year Maturity 6,931 7,954 -12.9%        

Miami International Holdings, Inc. ("MIAX" or the "Company") (NYSE: MIAX), a technology-driven leader in building and operating regulated financial markets across multiple asset classes, today announced the closing of a secondary public offering of 7,762,500 shares of its common stock, which included 1,012,500 shares sold pursuant to the underwriters' exercise in full of its option to purchase additional shares, at a price to the public of $41.00 per share (the "Offering"). The Offering consisted entirely of secondary shares including shares issued upon the exercise of warrants sold by certain selling stockholders of MIAX. The Company did not sell any shares of common stock in the Offering and did not receive any proceeds from the Offering. J.P. Morgan, Morgan Stanley and Piper Sandler acted as lead joint bookrunning managers for the offering. Raymond James, Rosenblatt, William Blair, and Keefe, Bruyette & Woods, A Stifel Company, acted as joint bookrunning managers. A registration statement relating to these securities has been filed with the Securities and Exchange Commission ("SEC") and was declared effective on December 11, 2025. The Offering was made only by means of a prospectus. Copies of the final prospectus relating to the Offering may be obtained for free by visiting EDGAR on the SEC website at www.sec.gov. Alternatively, copies of the prospectus may be obtained from: J.P. Morgan Securities LLC, Attention: c/o Broadridge Financial Solutions, 1155 Long Island Avenue, Edgewood, NY 11717, or by email at prospectus-eq_fi@jpmchase.com and postsalemanualrequests@broadridge.com; Morgan Stanley & Co. LLC, Attention: Prospectus Department, 180 Varick Street, 2nd Floor, New York, NY 10014; or Piper Sandler & Co. at, 350 North 5th Street, Suite 1000, Minneapolis, MN 55401, Attention: Prospectus Department, by telephone at (800) 747-3924, or by email at prospectus@psc.com. This press release shall not constitute an offer to sell or the solicitation of an offer to buy these securities, nor shall there be any sale of these securities in any state or jurisdiction in which such offer, solicitation or sale would be unlawful prior to registration or qualification under the securities laws of any such state or jurisdiction.

Gallmetzer HealthCare S.p.A. celebrated its debut on the Vienna Stock Exchange today. CEO Dietrich Gallmetzer traditionally opened trading in the direct market plus segment by ringing the opening bell. The shares of the Bolzano-based company are now tradable on a daily basis in a supervised intraday auction. Gallmetzer HealthCare S.p.A. is a corporate group active in the field of oral and dental care. According to the company, its brand portfolio spans the entire value chain, ranging from in-house production of proprietary products such as anaesthetics and sustainable oral care solutions to dental distribution of its own products and third-party goods. The transaction was accompanied by Wiener Privatbank as lead manager, while the Rosinger Group acts as Capital Market Coach. ICF Bank is responsible for supervising the auction. “With the listing we are opening a new chapter in the development of our company. As Italy’s second-largest dental holding, Gallmetzer HealthCare strengthens trust among partners and customers through its presence on the capital market, while at the same time laying the foundation for further expanding our unique family of brands across Europe,” says Dietrich Gallmetzer, CEO of Gallmetzer HealthCare. Since 2019, the Vienna MTF with its direct market and direct market plus segments has been aimed at small and medium-sized enterprises (SMEs) as well as fast-growing young companies. The straightforward path to the stock exchange provides companies from a wide range of industries with the basis for further growth via the capital market and potential equity financing. A large number of partners within the direct network – consisting of Capital Market Coaches and Direct Funding Partners – support prospective issuers throughout the listing process. Currently, 31 securities are listed across the two entry-level segments.

We are asking for views on new proposals as the next step in shaping the UK’s crypto rules. These proposals continue our progress towards an open, sustainable and competitive crypto market that people can trust. We want a market where innovation can thrive, but where people understand the risks. Regulation cannot – and should not – remove all risk. Instead, it should make sure anyone investing in crypto does so with their eyes open. Our proposals apply a similar approach to crypto as we do in traditional finance: clear information for consumers, proportionate requirements for firms, and flexibility to support innovation. What we’re consulting on Admissions and disclosures – Rules for listing cryptoassets and what firms must tell investors, so people have the facts before they invest. Market abuse – Measures to stop insider trading and manipulation, so markets are fair. Cryptoasset trading platforms – Standards for exchanges to keep trading safe and reliable. Intermediaries – Requirements for brokers and other middlemen, so they act responsibly. Staking – Making sure the risks are clear when firms offer staking – a service that lets you lock up your crypto for a reward. Lending and borrowing – Rules to protect both crypto lenders and borrowers. Decentralised finance (DeFi) – DeFi lets people trade, lend and borrow using crypto without a middleman. We’re asking if the same rules that apply in traditional finance should also apply here. Prudential requirements – Financial safeguards for firms, so they can better manage risk. These proposals build on feedback from earlier discussions and new research published today. They are aligned with new government legislation laid yesterday and reflect our commitment to getting the balance right. David Geale, executive director for payments and digital finance at the FCA, said: 'Regulation is coming – and we want to get it right. We’ve listened to feedback, and now we’re setting out our proposals for the UK’s crypto regime. 'Our goal is to have a regime that protects consumers, supports innovation and promotes trust. We welcome feedback to help us finalise these rules.' We’ve made significant progress in delivering our crypto roadmap and are helping firms meet our standards and become registered while we wait for further legislation. While we work closely with partners to deliver the UK’s crypto rules, people should remember crypto is largely unregulated – except for financial promotions and financial crime purposes. Consultation responses are open until 12 February 2026. To share your views, please see our CP25/40, CP25/41 and CP25/42 pages. Background Read CP25/40, CP25/41 and CP25/42. Read our Cryptoassets consumer research 2025 and Cryptoasset regulation and consumer decision-making: Evidence from an online experiment research notes. These publications mark the next milestone in crypto regulation in the UK closely engaging with the Government’s proposals including the statutory instrument laid at the Parliament yesterday (15 December). We have considered how these consultation papers will apply the UK issuers of stablecoins and have introduced specific rules and guidance where necessary. UK issuers of stablecoins will not be able to pass interest from their own backing assets to holders; we are considering how further financial incentives could be shared with holders when UK issued stablecoins are used. The FCA has previously set out the timeline for crypto regulation in its crypto roadmap. Earlier this year, the FCA consulted on key topics such as stablecoins, cryptoasset custody and conduct of business and high-level standards. Soon, the FCA will consult further on Consumer Duty and other consumer protection matters for cryptoassets, including our approach to financial promotions. Find out more about existing rules firms must comply with. If firms want to become registered under the Money Laundering Regulations 2017, we offer pre-application support. It’s a free meeting with a case officer who can talk them through any questions they might have.  We also run webinars and in person events with industry and compliance teams to educate crypto firms specifically on our rules. There will be more of these in the coming months aimed at specific areas of our rules. We provide firms with lots of resources to help them understand our rules and how to meet expectations. Find out more. The FCA enables a fair and thriving financial services market for the good of consumers and the economy. Find out more about the FCA.

Duco, a leading SaaS provider of AI-powered operational data automation, has announced a strategic collaboration with Phoenix Group, one of the UK’s largest long-term savings and retirement businesses, to modernise reconciliation infrastructure, empower operational teams, and scale efficiently across its Asset Management division.  The project will create a unified, cloud-based environment for reconciling investment and accounting records across 20 administrators and multiple asset classes. By simplifying these critical workflows, Phoenix aims to strengthen controls, reduce manual intervention, and give its teams greater ownership of daily operations.  Philip Shaw, Asset Management COO of Phoenix Group, said: “Bringing our reconciliation infrastructure to the cloud is a key part of our operational strategy,” said Shaw. “With Duco, we can manage change more quickly, reduce reliance on IT support, and establish a consistent model for how data is reconciled across the business.”  “The relationship with Duco has been open and collaborative from the start,” added Shaw. “We value the team’s understanding of our environment and their commitment to helping us build a system that supports future growth.”  The initial phase will focus on automating reconciliation between Investment Book of Record (IBOR) and Accounting Book of Record (ABOR) data, ensuring consistent, auditable controls and alignment with European Market Infrastructure Regulation (EMIR) standards.  Michael Chin, Chief Executive Officer of Duco, said: “Phoenix Group represents the kind of institution Duco was made for: complex operations, multiple data sources, and a clear drive for efficiency and control. We’re delighted to support them in building a reconciliation platform that’s fit for the next decade.”    

Today, ACER releases its Opinion on France’s National Resource Adequacy Assessment (NRAA). This assessment complements the European Resource Adequacy Assessment (ERAA) 2024, using input assumptions and modelling approaches that better reflect the characteristics of the national electricity system, drawing on historical data and recent developments. What is a resource adequacy assessment? The European Resource Adequacy Assessment (ERAA) evaluates electricity resource adequacy across the EU and provides a consistent framework to assess whether additional national measures are needed to ensure security of supply. ERAA is carried out annually by the European Network of Transmission System Operators for Electricity (ENTSO-E) and reviewed by ACER. Member States can complement the European analysis through national assessments (NRAAs). While based on the ERAA methodology, NRAAs may capture new developments or national specificities not yet reflected in the latest ERAA. When a national assessment identifies new adequacy concerns, the Member State informs ACER. In turn, ACER issues an opinion on the differences between the national and European assessments. What did ACER find? ACER finds the French assessment clear, robust and generally aligned with ERAA 2024 for most target years. However, unlike ERAA, the NRAA identifies an adequacy concern for 2030, estimating nearly twenty hours during the year when electricity demand would not be met (above France’s reliability standard of two hours). ACER notes that most differences with ERAA 2024 are justified by national specificities or methodological improvements. At the same time, it identifies some unjustified differences that could overestimate the projected risks. What are the next steps? ACER encourages the French authorities to consider its recommendations to ensure a more accurate assessment of adequacy risks. Read more.

Global fintech leader Broadridge Financial Solutions, Inc. (NYSE: BR) today announced significant enhancements to its multi-asset portfolio and trade order management platform, introducing fully integrated general ledger capabilities and a redesigned user interface (UI). These upgrades mark an important step forward in Broadridge’s strategy to deliver a unified, front-to-back investment management solution that increases operational efficiency, elevates fiduciary oversight, and supports faster, more informed decision-making for buyside firms. “Across the alternatives and broader asset management landscape, firms are under tremendous pressure to modernize fragmented technology stacks, enhance controls, and differentiate in an increasingly competitive market,” said Frank Cataudo, General Manager of Investment Management Solutions, Broadridge. “Broadridge is investing meaningfully in the evolution of our platform to help clients meet these challenges head-on. The addition of an integrated general ledger and our redesigned UI reflect our commitment to providing a more unified, transparent, and scalable platform for the next generation of investment management solutions.” The new general ledger capabilities extend Broadridge’s portfolio management system by embedding period accounting and financial statement reporting directly into the investment platform. The solution provides a fund-level general ledger that systematically posts accounting entries for all investment activity, offers tools for period adjustments, introduces workflows to close the period, and provides out-of-the-box financial statements. By offering a comprehensive shadow book of record, clients can improve the accuracy and efficiency of their month-end close and compare seamlessly against official fund administrator books and records. As asset managers face mounting demands for transparency, automation, and regulatory compliance, the integrated general ledger supports improved fiduciary controls, operational stability, and data accuracy. The architecture is also built to support next-generation scalability and future global compatibility. Complementing the new general ledger functionality, Broadridge has introduced a redesigned UI that delivers a modern, intuitive, and consolidated workspace for portfolio managers and traders. The updated UI optimizes workflows, and unifies portfolio management, risk management, analytics, and reporting into a single experience – reducing the need to navigate across multiple screens and enabling faster, more informed decision-making. Broadridge’s multi-asset portfolio and trade order management platform is recognized as a leading solution for asset managers, hedge funds, asset owners, and other buyside firms, offering seamless integration across diverse asset classes to enhance decision-making and operational efficiency.

Supports Citi’s modernisation efforts and client-centric focus Provides AI-ready content, multi-asset class data and workflow solutions across all business lines LSEG and Citi today announced a multi‑year strategic partnership to deploy LSEG’s data, analytics and workflow solutions at enterprise scale. The partnership strengthens Citi’s data foundations, supports its broader modernisation efforts and enhances the quality and speed of client delivery.Under the multi-year agreement, LSEG’s data and analytics will support Citi’s front-to-back workflows across markets, investment banking, wealth, trading, risk, finance and compliance. By consolidating data access and standardising governance, usage rights and entitlements, the partnership will help Citi drive greater scale, efficiency and more consistent data-driven decision-making throughout the bank.LSEG will provide AI-ready content, multi-asset class data spanning economic indicators, pricing and market information, company and reference data, benchmarks and indices, fund and Lipper data, deals data, commodities, news, risk-intelligence and regulatory data. This curated intelligence will support a wide range of activities, enabling clearer insights and more informed client conversations for Citi.The partnership gives Citi access to LSEG’s end-to-end workflow solutions, led by LSEG Workspace, supported by wealth and advisory APIs and enterprise platforms. This is complemented by multi-channel content delivery for real-time and historical pricing, news, investment and advisory content, wealth and trading feeds, FX and buy-side trading capabilities, and professional services. The partnership also strengthens Citi’s compliance, KYC and risk management frameworks. By integrating LSEG’s World-Check risk-intelligence data, Citi will enhance the consistency, auditability and coverage of its onboarding and monitoring processes across markets. David Livingstone, Citi’s Chief Client Officer, said:“High-quality data underpins how we deliver for clients. This partnership with LSEG gives our teams a comprehensive, trusted base of intelligence that spans Citi’s franchise, strengthening how we design products, advise clients, and execute on their behalf. By integrating LSEG’s data and analytics directly into our workflows, we can deliver sharper insights, faster responses, and a more consistent client experience.” Ron Lefferts, Co-Head of Data & Analytics, LSEG, commented:“We are proud to deepen our relationship with Citi through this long-term agreement. Our focus is on delivering trusted, multi-asset class content and workflow solutions that function as strategic infrastructure. By combining AI-ready content, cloud-native analytics and integrated workflow tools such as LSEG Workspace, we are supporting Citi’s modernisation agenda, helping them innovate at scale while strengthening governance, risk management and compliance.”Together, these capabilities will support a wide range of client and internal use cases from portfolio construction, index-linked product design and wealth advisory, to treasury and trading decisions, investment banking origination, risk management and regulatory reporting ensuring teams across Citi can rely on a single, governed view of high-quality data. The partnership underscores LSEG’s role as a strategic data and analytics partner to leading financial institutions globally, helping firms modernise their data infrastructure and unlock new sources of growth for their businesses and their clients.

ASIC has today updated its regulatory guidance on managing conflicts of interest for Australian financial services businesses. The changes align our guidance with developments in law and policy and draw on ASIC’s regulatory experience and insights from its surveillance of private markets. ‘Conflicts of interest aren’t just ethical dilemmas. They pose real threats that erode trust, tarnish reputations, and cause lasting harm to consumers, investors, and the entire financial ecosystem,’ ASIC Commissioner Kate O’Rourke said. ‘Effective conflict management is more than a regulatory checkbox—it’s the cornerstone of trust in financial services. The updated Regulatory Guide 181 AFS Licensing: Managing Conflicts of Interest (RG 181) sets out clear, principles-based guidance for Australian financial services (AFS) licensees. It aims to help licensees fulfil their licensing obligation to have robust arrangements and tailored conflict management strategies in place. Key updates include: how the law applies to conflicts of interest, including the scope of the conflicts management obligation and links to other related obligations the types of conflicts AFS licensees should identify and manage the need for robust, tailored arrangements to manage conflicts practical steps for effective conflict management, and a non-exhaustive ‘catalogue’ of related legal obligations and information. The revised RG 181 replaces guidance issued in August 2004 and is part of ASIC’s ongoing regulatory maintenance and simplification agenda—making it easier for businesses to access regulatory information and understand their obligations. Consultation feedback and ASIC’s response Between 30 July and 5 September 2025, ASIC consulted publicly on proposed updates to RG 181. ASIC received 26 submissions from industry, industry groups and other interested parties, with broad support for simplifying and updating the guidance. Most feedback focused on technical details and specific guidance, such as the illustrative examples ASIC provided to identify different types of conflicts of interest. ASIC updated RG 181 to address this feedback, where appropriate, and we have summarised our responses to key feedback. You can read these responses along with the 22 non-confidential submissions to ASIC’s public consultation on the relevant consultation paper webpage. Background Conflicts of interest are a significant source of misconduct as well as consumer, investor and economic harm within the financial services sector. Under section 912A(1)(aa) of the Corporations Act 2001, AFS licensees must have adequate arrangements in place to effectively manage all conflicts of interest, except those that occur wholly outside a financial services business. The management of conflicts of interest was raised as an area requiring further clarification in a number of submissions to ASIC’s discussion paper on the evolving dynamics in public and private markets, and was a compliance issue identified in ASIC’s private credit surveillance report (REP 820). The issuance of the updated RG 181 was outlined as a deliverable in ASIC’s roadmap for the next 12-18 months, released as part of our response to the discussion paper in November (REP 823). More information Regulatory Guide 181 AFS Licensing: Managing Conflicts of Interest (RG 181) ASIC seeks feedback on proposed updates to conflicts management guidance (25-150MR) Consultation paper 385 Proposed update to RG 181 Licensing: Managing conflicts of interest (CP 385) ASIC media releases are point-in-tim