Intercontinental Exchange, Inc. (NYSE:ICE), a leading global provider of technology and data, today reported August 2025 trading volume and related revenue statistics, which can be viewed on the company’s investor relations website at https://ir.theice.com/ir-resources/supplemental-information in the Monthly Statistics Tracking spreadsheet. August highlights include: Total open interest (OI) up 13% y/y, including record OI of 106.1M lots on August 25 Energy OI up 6% y/y, including record futures of 40.2M lots on August 28 Oil OI up 14% y/y Brent OI up 16% y/y WTI* OI up 5% y/y Other Crude & Refined products ADV up 4% y/y; OI up 17% y/y, including record futures of 6.0M lots on August 28 Natural Gas ADV up 8% y/y, OI up 2% y/y, including record futures of 24.4M on August 25 TTF Gas ADV up 3% y/y, including record futures of 2.4M lots on August 22 Asia Gas ADV up 38% y/y; OI up 49% y/y, including record OI of 200k lots on August 14 Sugar OI up 4% y/y Cotton ADV 24% y/y, OI up 17% y/y Financials ADV up 6% y/y; OI up 34% y/y Interest Rates ADV up 9% y/y; OI up 41% y/y, including record futures of 11.5M on August 25 Euribor OI up 26% y/y SONIA ADV up 23% y/y; OI up 63% y/y, including record OI of 11.0M lots on August 13 NYSE Cash Equities ADV up 39% y/y NYSE Equity Options ADV up 5% y/y * Combined OI and volumes of WTI and ICE HOU

Today, the Office of Information and Regulatory Affairs released the Spring 2025 Unified Agenda of Regulatory and Deregulatory Actions. This regulatory agenda reflects that it is a new day at the Securities and Exchange Commission. The items on the agenda represent the Commission's renewed focus on supporting innovation, capital formation, market efficiency, and investor protection. The agenda covers potential rule proposals related to the offer and sale of crypto assets to help clarify the regulatory framework for crypto assets and provide greater certainty to the market. A key priority of my Chairmanship is clear rules of the road for the issuance, custody, and trading of crypto assets while continuing to discourage bad actors from violating the law. It also covers a number of envisioned deregulatory rule proposals to reduce compliance burdens and facilitate capital formation, including by simplifying pathways for raising capital and investor access to private businesses. It discusses amending existing rules to improve and modernize them as well as address disclosure burdens. In addition, it considers recommending that the Commission invite public comment regarding rethinking the Consolidated Audit Trail (CAT), especially in the wake of a recent decision by the U.S. Court of Appeals for the Eleventh Circuit. Market participants and Congress have rightly pushed back on CAT’s seemingly endless cost increases and the risks of storing so much sensitive data together. Importantly, the agenda reflects our withdrawal of a host of items from the last Administration that do not align with the goal that regulation should be smart, effective, and appropriately tailored within the confines of our statutory authority.

New Central Limit Order Book for U.S. Treasury Trading to Launch Oct. 6 CME Group, the world's leading derivatives marketplace, today announced that Citigroup, J.P. Morgan and Morgan Stanley will be available to trade cash U.S. Treasuries on BrokerTec Chicago when it launches on October 6. "With leading financial firms on board for day one on BrokerTec Chicago, trading U.S. Treasury futures and cash will be more efficient than ever before," said Mike Dennis, CME Group Global Head of Fixed Income. "CME Group is in a unique position to bring these markets together, unlocking value for our clients worldwide who want to more precisely hedge their risk amid record debt issuance and ongoing economic uncertainty." At launch, clients will be able to trade all seven of BrokerTec's on-the-run benchmark U.S. Treasuries. To align with the futures market, these products will be available in smaller notional sizes and at tighter price increments. Clients will be able to use their existing connectivity to CME Globex, including the BrokerTec API. CME Group operates BrokerTec, whose platform for benchmark cash U.S. Treasuries and U.S. and EU repo transactions is the world's leading marketplace for fixed income trading. In Q1 this year, BrokerTec set an all-time single-day average daily notional volume record of $1.05 trillion across its dealer-to-dealer central limit order book, dealer-to-client request-for-quote and streaming platforms. CME Group U.S. Treasury futures and options also reached an all-time average daily volume record of 8.8 million contracts in 2025.  BrokerTec Chicago is offered as part of BrokerTec Americas LLC. For more information, visit https://www.cmegroup.com/chicago-CLOB.

No changes to the constituents of the STI FTSE Russell announces that there will be no changes to the constituents of the Straits Times Index (STI), following the September 2025 quarterly review. A full list of STI constituents can be found on the website. The STI reserve list will see the following changes (in alphabetical order): Entering STI Reserve List Exiting STI Reserve List Olam Group CapitaLand Ascott Trust Yangzijiang Financial Holding ComfortDelGro The STI Reserve List (in alphabetical order) Keppel REIT NetLink NBN Trust Olam Group Suntec REIT Yangzijiang Financial Holding All changes from this review take effect at the start of business on 22 September 2025 and the next review will take place in December 2025. The indexes are reviewed quarterly in accordance with the index ground rules and to facilitate the inclusion of eligible IPO stocks. The FTSE ST methodology ensures the indexes accurately represent the investable universe for benchmarking purposes and can be easily replicated as the basis of index-linked products. FTSE Russell has partnered with SPH Media Trust, publisher of The Straits Times newspaper, and SGX Group (Singapore Exchange) to jointly calculate Singapore’s main stock market benchmark. The STI is widely followed by investors as the benchmark for the Singapore market and is used as the basis for a range of financial products including Exchange Traded Funds (ETFs), warrants, futures and other derivatives. FTSE Russell is the index administrator. Further information on the FTSE ST Index Series, including all additions and deletions as well as ground rules, is available at FTSE Strait Times (ST) Index Series | LSEG

Strategic financing supports Puro.earth initiatives to accelerate carbon removal at scale. Puro.earth, a leading carbon-crediting platform for engineered carbon dioxide removal (CDR), today announced it has raised €11 million in a Series B funding round led by Nasdaq with participation from Fortum Innovation & Venturing. Puro.earth will deploy this funding to strengthen the infrastructure that supports its best-in-class certification journey for suppliers. Key initiatives include enabling more frequent issuance of high-integrity carbon removal credits, facilitating offtake agreements, and advancing open integration of digital measurement, reporting, and verification (dMRV) tools. The new investment builds on a period of strong growth and innovation at Puro.earth, highlighted by enhancements to its market-leading biochar methodology, the launch of an API enabling streamlined carbon removal trading through sales channels, strategic partnerships with leading organizations to facilitate CDR project financing, and the appointment of new leadership to accelerate carbon removal at scale. It reinforces Puro.earth’s strategic mission to scale high-integrity carbon removal markets globally, solidifying its role as a leading standard and registry for scientifically rigorous and independently verified CO₂ Removal Certificates (CORCs). By enhancing Puro.earth’s customer offerings to meet rising demand for durable carbon removals, Nasdaq and Puro.earth are well positioned—through their combined financial market and climate expertise—to drive innovation and to scale the carbon market. “Carbon removal is evolving from innovation to infrastructure,” said Jan-Willem Bode, President of Puro.earth. “With this latest round of funding, we’re strengthening the systems that facilitate scale in CDR deployment and enhancing our customer offerings to better support the growing demand for durable engineered removals. Our approach is grounded in science, market discipline, and transparency. This is what our ecosystem of buyers and suppliers demands—Nasdaq and Puro.earth are well-placed to meet this need by combining financial infrastructure and climate expertise to foster innovation and accelerate the carbon market growth.” “With this investment, we aim to accelerate our shared vision of enabling high-integrity carbon markets,” said Fredrik Ekström, Head of Carbon Markets at Nasdaq and Chairman of the Board at Puro.earth. “Together with Nasdaq's efforts to advance the technological infrastructure of carbon markets, Puro.earth is delivering the transparency and operational capacity essential to making carbon dioxide removal (CDR) a credible and investable solution in both carbon and financial markets.” Puro.earth developed the first standard dedicated to engineered carbon removal in 2019 as part of Fortum’s Innovation & Venturing unit. In 2021, Nasdaq became the majority owner of the company. To date, Puro.earth has issued more than 1 million CO₂ Removal Certificates (CORCs) - more than any other engineered CDR standard and registry to-date.

Leading global cybersecurity and corporate intelligence consultancy S-RM has announced a new partnership with RingStone, a leading technology due diligence provider, to make it easier for investors to review both technology and cybersecurity risks when buying or backing companies. The two firms have worked side-by-side on numerous transactions this year, providing complementary expertise across technology and cybersecurity. Formalising the partnership will allow investors to access both services through one agreement, saving time and simplifying the process.  The partnership will make the due diligence process more efficient and less burdensome for investors and their targets. Clients will be able to contract under a single set of terms, work with a single point of contact for both workstreams, and benefit from a coordinated approach that minimises duplication. Meetings and workshops will also be run jointly to avoid duplication of effort. The partnership not only reduces costs, but also gives investors a more clear and holistic overall picture of a company's technology systems and security.   Felicity Loudon, Private Equity Practice Lead, Cybersecurity, at S-RM, said: "We’re very pleased to strengthen our ties with RingStone. Investors now understand that technology and cybersecurity can’t be looked at separately. By bringing our expertise together, we can give clients a full and joined-up view, helping them invest with greater confidence."   Brian Briggs, Managing Director, EMEA at RingStone, added: "We’re formalising our partnership with S-RM to strengthen and augment our in-house cyber capabilities as part of our commitment to delivering white-glove service for our clients. By joining forces, we're making it easier for investors to access high-quality technology and cyber due diligence in one package - empowering smarter investments and stronger outcomes.”  

Despite static buy side budgets, bulge bracket banks increase their pricing and market share across the board in H1 2025  JP Morgan retains market share top spot; Jefferies retains second place and UBS rounds out the top 3 Data shows that post-MiFID research valuation processes are robust – rising AUMs do not automatically increase research spend  Substantive Research, the research and market data discovery and pricing analytics provider, today publishes the findings of its latest survey into investment research pricing and consumption, highlighting how research spending has evolved in the first half of 2025. In terms of research payment rankings, JP Morgan maintains its top spot, with Jefferies maintaining its second place, and UBS returning to the top 3 for the first time since 2022, after some strong growth in client research payments across the universe surveyed. Up until recently, market share gains by brokers have been a direct result of investing in hiring and retaining skilled research analysts, against a backdrop of post-MiFID II price deflation and the accompanying sell side analyst ‘brain drain’. However, in this latest cycle it’s clear that with resourcing having stabilised, it’s the firms that drive interactions (analyst meetings, corporate access engagements etc.) that now win increased market share in this post-MiFID II environment.  2025 Study Findings Overall, the study makes it clear that Assets Under Management (AUM) growth is no longer an automatic driver for higher research budgets.  The real drivers for increased investment research spend are new requirements for analyst coverage or rising buy side headcount. However, even with new headcount, the research budget increases can still be small, as most full service agreements with the bulge bracket firms will cover a portion of the increased need for access.  This should all give comfort to European end investors as they react to many of their asset managers’ intentions to adopt Commission Sharing Agreements (CSAs) in Europe and return to client-funded budgets in 2026. End investors should be reassured that there are now rigorous, well-governed processes in place that ensure any payments for research deliver identifiable value.  The survey shows that in H1 2025: Research budgets stayed largely flat in monetary terms (-0.2%) but have decreased in both the US and Europe when measured as basis points of AUM, due to increased average AUM levels.  On this basis the survey reflects a decrease of 3% in the US and 1.4% in the UK/EU respectively). Buy side spend continues to concentrate with the top brokers - the top 10 brokers now command 55.1% of investment research budgets. Top brokers continue to exercise pricing power - In tough market conditions for research, bulge bracket providers still increased their pricing by 1.5% on average, while specialist research-driven brokers decreased 0.5%. This either suggests that the bulge’s reinvestment into their research product is driving increased consumption of analyst meetings, or that asset managers are valuing holistic sell side relationships over the specific value provided by research alone.  A July 2025 Substantive Research client survey charted the buy side’s appetite to take advantage of the softening of MiFID II rules by UK/EU regulators.  87% of respondents at the time said that within two years at least half of investment research budgets in Europe will be client-funded, representing an enormous shift from a previously sceptical asset management community. Mike Carrodus, CEO of Substantive Research, said: “Average AUMs have gone up - pre-MiFID II that would have meant that research spending automatically went up to coincide - that’s not the case now. If you’re a European pension fund faced with the return of research charges from your asset managers next year, you can be confident that payments to brokers will only go up if new costs added new coverage or delivered new insights that contribute to performance.”  He added: “However this also points to the issue which motivated the UK’s Treasury and the FCA to roll back research rules. In Europe there is a lack of new investment in research, at a time when new data sources and technology are rapidly being adopted in other regions. Maybe we needed to go through this rollercoaster, with regulations going too far and then retrenching in order to achieve a happy medium. European asset managers could now have the flexibility to buy new research, balanced with a mandatory focus on ensuring value for their end investors. Will brokers prioritise the clients that have moved to a funding structure that potentially unlocks more money for them? No guarantees – but the current messaging from the sell side points to a two-tier market of research consumers in 2026”. Universe of firms covered by the research: 44 of the largest asset managers surveyed AUM : > $18 Trillion  Geographic split: 30% N. America, 20% EU, 50% UK

Eurex has expanded its successful Partnership Program to Credit Index Derivatives.  Eight leading banks and liquidity providers joined at launch on 1 August 2025, strengthening the liquidity pool for these instruments.  Eurex, one of the world’s leading derivatives exchanges and part of Deutsche Börse Group, has launched a Credit Index Derivatives Partnership Program, delivering a robust liquidity pool for these instruments and marking a significant step towards a more efficient and accessible credit market. The eight prominent financial institutions that have joined the program since its launch on 1 August 2025 are: Banco Santander, BNP Paribas, Flowtraders, Goldman Sachs, Jane Street, J.P. Morgan, Morgan Stanley, and Susquehanna International Group.  Collaborative ecosystem  This program extends Eurex’s successful Partnership Program model – already established in Short-Term Interest Rate (STIR) and interest rate swap markets – to credit derivatives. The performance-based program fosters a collaborative ecosystem, aligning incentives and responsibilities for all participants – from liquidity providers to end-users – in terms of both economics and governance. This shared commitment aims to stimulate growth and liquidity in this key market.  Eurex Credit Index Futures provide a simplified, centrally cleared way to manage credit market exposure, avoiding the complexities and costs associated with OTC instruments like credit default swaps (CDS) and Total Return Swaps (TRS). Clients benefit from cross-product margin efficiencies within Eurex's global, multi-asset suite, including risk offsetting with fixed income products. A liquid and transparent market for Credit Index Futures will broaden access for a wider range of investors, including smaller institutions and electronic proprietary trading firms.  Transforming credit markets  Matthias Graulich, Member of the Executive Board of Eurex: “We are thrilled to launch this program with eight leading partners, sharing a common vision to transform credit markets. By fostering liquidity in Eurex's Credit Index Derivatives, we're accelerating electronification and standardization for a more efficient and accessible market, strengthening Eurex's leadership in listed fixed income and delivering our enhanced value proposition globally.”  The demand for Credit Index Futures has been growing steadily since its inception in October 2021 with the launch of Bloomberg MSCI Euro Corporate Screened Index Futures. Growth has primarily been driven by end clients looking for liquid, transparent, and cost-efficient investment vehicles. Today, the segment includes global credit markets, covering investment grade and high yield tranches across global currencies. The volume and Open Interest this year has more than doubled versus the first eight months of 2024, while the total traded notional in all Credit Index Futures at Eurex stood at over EUR 75 billion, with a total outstanding notional of EUR 2.8 billion as of 31 August 2025.   Joseph Nehorai, Global head of Futures and Options Execution Sales at Goldman Sachs: “We are pleased to see Eurex extend their Partnership Program to include Credit Futures. Our commitment remains as strong as day one, this is well timed to capture the rise in adoption of credit futures by our clients.”  Joe Paccione, Americas Head of Futures and Options Sales and Execution at J.P. Morgan: “Credit Index Futures are a valuable addition to further broadening the scope of macro credit products we trade. Reception from our clients to this product has been robust and we view the extension of the program as a very positive step to continue to build on the global liquidity pool for listed credit derivatives.”  Riccardo Aimone, EMEA Head of Fixed Income Trading at Susquehanna International Group: “We have supported credit index futures at Eurex since their inception and are excited to see the market grow day by day. Joining the Credit Derivatives program underlines our ambition and commitment to the segment.” 

 MEFF, the Spanish derivatives market, launches these new Options with Banco Santander, Banco Sabadell, BBVA, Endesa, Iberdrola, Inditex, Repsol y Telefónica as underlyings BME, through MEFF, the Spanish derivatives market, has listed new European-style cash-settled options contracts, i.e. settled by differences. In this initial phase, the underlying stocks are Banco Santander, Banco Sabadell, BBVA, Endesa, Iberdrola, Inditex, Repsol, and Telefónica. Cash settlement is the procedure whereby the contract is fulfilled on the settlement date only through the transfer in cash of the difference between the price agreed in the contract and the settlement price at maturity. Therefore, in this type of option, there is no possibility of early exercise. The main advantages of these new contracts, available to investors since March 2025, are:  Standardization: simplifies the trading and investment process and benefits contract liquidity. Accessibility: they will be available in the order book and register applications, improving market transparency and efficiency. Flexibility: allows for more varied and sophisticated investment strategies without the possibility of the strategy holder having to deal with early exercises. Cash-settled: as they are cash-settled options, the call seller and put buyer are not required to own the shares on the day of expiration. Clotilde Salmerón, Head of MEFF, explains that “at BME we are constantly working to offer new alternatives for investors. That is why we always listen to our clients' needs and seek to improve our offering. We believe that with this new launch, the Spanish derivatives market offers new incentives for all types of investors, which will allow us to continue growing”. Susquehanna, a member of MEFF, has played a decisive role in the launch of European-style cash-settled equity options. As a leading liquidity provider, Susquehanna, which is committed to providing key liquidity for the growth of this product, offers prices both on screen and for block trades through its institutional trading desk, ensuring solid market coverage. You can find more information about MEFF here.

Trading – Cash Markets (including equities, interest rate and ETP trades) In August 2025, the average daily number of trades was up 46% on the pcp. The average daily value traded on-market of $7.161 billion was up 22% on the pcp.  Volatility (as measured by the average daily movement in the All Ordinaries Index) was 0.5% in August, compared to 0.8% in the pcp.  Future volatility (as measured by the S&P/ASX 200 VIX) in August was an average of 10.8, down 17% on pcp. Click here for full details.

The Securities and Futures Commission (SFC) and the Hong Kong Monetary Authority (HKMA) today published the findings of their annual joint survey on the distribution of non-exchange-traded investment products, showing record sales and level of market participation for these products during 2024 (Note 1). Total transaction amount of non-exchange-traded investment products by licensed corporations (LCs) and registered institutions (RIs) surged 40% year-on-year to a record $6,073 billion in 2024 (Note 2). Market participation also witnessed broad-based growth last year. The number of firms engaged in the sale of investment products grew by 9% to a new high of 414, with an overwhelming 46% more than doubling their sales year-on-year. The number of large firms saw a 12% increase to 101 (Note 3). Also setting new record highs are the manpower deployed to distribute investment products, which rose by 4% to more than 19,000, and the number of clients completing at least one transaction, which increased by 28% to over 1.2 million (Note 4). All major investment product types recorded significant sales growth in 2024. Sales of authorised collective investment schemes (CIS) grew 96% to $1,400 billion and unauthorised CIS grew 50% to $844 billion. Sales of structured products and debt securities increased by 30% and 29% year-on-year, respectively. Respondent firms generally observed stronger investor sentiment compared with the previous year as investors actively pursued products that suit their risk appetites and investment goals. Equity-linked products thrived amidst strong market momentum and remained the top-selling structured product category with sales of $1,729 billion, up 43% year-on-year. Meanwhile, money market funds and sovereign bonds remained attractive to investors due to their perceived lower risks and decent returns under the prevailing high interest rate environment in 2024. The survey showed an increase in the sales of money market funds, which accounted for 80% of the total transaction amount of the top five CIS reported by the large firms, up from 76% in 2023. Sovereign bonds also gained popularity, making up 49% of total debt securities sold last year, compared with 44% in the year before. “The remarkable surge in product sales underscores the dedication of firms and the trust investors place in our financial markets,” said Dr Eric Yip, the SFC’s Executive Director of Intermediaries. “The SFC is steadfast in fostering a robust regulatory framework that enables businesses to grow while protecting investor interests.” “The strong growth in investment transactions reflects heightened investor confidence and interest in the vibrancy of Hong Kong’s investment market, and supports the continuous growth and development of the ecosystem,” said Mr Alan Au, Executive Director (Banking Conduct) of the HKMA. “The survey result enables regulators to better coordinate and implement our supervisory activities in light of market developments, thus according protection to investors.” Other major observations from the survey included: Structured products remained the top product type sold by the respondent firms, accounting for 42% ($2,567 billion) of the total transaction amount in 2024. CIS and debt securities rounded out the top three spots, making up 37% ($2,244 billion) and 15% ($941 billion) respectively. Equity-linked products made up 67% of all structured products sold in 2024, up from 61% in 2023. The major underlying equities of the top five products reported by the large firms were from the technology (42%), automotive (23%) and internet (22%) sectors. Online sales accounted for 17% (2023: 12%) of the aggregate transaction amount reported by all respondent firms. The number of respondent firms that distributed investment products online continued to grow in 2024, increasing 13% to 104. CIS remained the top product type sold through online platforms, making up 77% of the total online sales, followed by debt securities at 21%. Notes: The annual survey questionnaires were sent to 2,368 LCs and 109 RIs licensed or registered for Type 1 (dealing in securities), Type 4 (advising on securities) or both regulated activities, and more than 99% of them responded. The survey covered the sale of non-exchange-traded investment products from 1 January to 31 December 2024 (the reporting period) by respondent firms to non-professional investor clients, individual professional investors (PIs) and certain corporate PIs. The first SFC-HKMA joint survey was published in 2021. Transaction amount refers to the amount paid or payable by investors for investment products. For structured products and derivative products, the transaction amount refers to the maximum exposure of the contracts at the point of sale. Respondent firms were requested to report only one side of the transaction. Rollovers, redemptions and position close-outs were not included. Large firms refer to LCs and RIs with total transactions of $1 billion or more and $30 billion or more respectively during the reporting period. They were requested to provide details about the investment products sold, including the transaction amount by investor type and the details of the top five products ranked by transaction amount. The numbers of clients of LCs and RIs who completed at least one transaction in non-exchange-traded investment products during the reporting period were 493,829 and 714,926 respectively.

Robust investor protections are the foundation of the success of the U.S. securities markets, ensuring market integrity and investor confidence. While modernization and tailoring of existing rules will be necessary to accommodate new technologies, existing investor protections must be extended to any markets that issue and trade tokenized securities. Doing so is critical to establishing investor confidence in markets for tokenized securities, ensuring broad participation and their long-term success. It is particularly important that investor protections derived from the current broker-dealer, exchange and custody frameworks under the federal securities laws—including structural limitations on vertical integration and separation of core functions—be applied to tokenized securities markets in order to mitigate potential conflicts of interest. These long-standing conflicts of interest requirements have deep foundations, yet have also evolved as new technologies, market participants, and other market factors have changed. Investor protections also require a clear understanding of when a token is and is not a security. It is critical that policymakers adopt consistent taxonomies and definitions rooted in the underlying economic characteristics of an asset or transaction, rather than its technological form. A carefully designed innovation exemption or regulatory sandbox framework can help supplement, though not replace, a broader process of regulatory modernization across all asset classes to accommodate tokenized securities. Guardrails on such a framework and projects that operate under it are also necessary to protect investors and maintain market integrity. The Foundational Role of Investor Protections in the U.S. Securities Markets The U.S. securities markets are not only the largest but also the deepest, most liquid, and most efficient in the world. Their strength is built on broad investor confidence in the efficiency, resiliency, and integrity of the markets. This investor confidence derives from the well-established set of protections that both retail and institutional investors enjoy under U.S. securities laws and regulations. As business models and markets evolve with the introduction of new technologies and products, policymakers’ commitment to protecting investors from conflicts of interest must remain paramount, so that the U.S. can maintain its competitive advantage among global markets. The core investor protections embedded in market structure for equities and other asset classes provide the baseline for digital markets in general and must be reflected in markets and platforms that facilitate issuance or trading of tokenized securities. Without these protections, it will be difficult for these markets to build long-term investor confidence in digital asset innovations and blockchain-based operating models, undermining the potential benefits offered to investors. In a recent letter to the SEC’s Crypto Task Force, we discussed the important benefits and protections that current securities regulation and market structures provide for investors, issuers, and other market participants. These protections are based on several key principles, including: Market Interconnectivity and Fair Access: trading venues should be linked within the same asset class to reduce market and liquidity fragmentation, and market services (e.g., listings and trading) should be open to all eligible participants on objective, non-discriminatory terms. Price and Market Transparency: investors must have real-time and post-trade transparency regarding the prices and sizes available to trade; there should also be transparency around order routing and execution quality, including any financial incentives related to investor orders or trades received from third parties. Proprietary Trading / Trading Ahead: platforms that permit proprietary trading by entities owned by or affiliated with the platform should disclose the nature, purpose, and timing of such trading activity and have procedures to prevent trading ahead of investor orders. Best Execution: investors should be able to obtain the most favorable overall terms reasonably available for orders they place with brokers or platforms that include broker functionality, based on factors such as price, transaction costs, speed and likelihood of execution and settlement, and market impact. Best execution should be demonstrated through public disclosures (e.g., around order routing and execution quality statistics that are based on common objective measures). Market Surveillance, Books-and-Records & Audits: market surveillance mechanisms, together with robust books-and-records and auditing requirements, are necessary to prevent market manipulation and other misconduct that could harm investors. Investment Recommendations: any recommended transactions or strategies must be in the best interest of retail customers and any entity making investment recommendations should clearly disclose the nature of its relationship with the investor. Conflicts of Interest/Separation of Functions: conflicts of interest that could harm investors should be mitigated through separation of core functions and limits on vertical integration, as well as other controls and investor disclosures. Customer Optionality: investors should be able to choose how and where their orders are handled and executed without being steered into a single broker, venue, order type or custody / clearing arrangement. Disclosure Requirements: issuers and intermediaries must disclose accurate, timely and material information to investors to allow them to make informed investing decisions. Custody, Financial Responsibility, and Clearing / Settlement: customer assets should be protected through the segregation of assets and financial activities from those of the custodian, and such assets should be subject to proper controls. Customer assets should be further protected through financial responsibility / prudential controls, such as capital and liquidity requirements (e.g., as provided for in the SEC’s 15c3-3 rule), as well as requirements to mitigate clearing and settlement risk. Anti-Fraud/Financial Crimes: investors need to be protected against bad actors and financial criminals through anti-fraud and other requirements, such as AML / KYC rules. Any modernization of the securities markets and rulebooks to accommodate blockchain technology and tokenization must reinforce these core investor protections, not remove them. While blockchain networks can support new models of securities issuance and trading, and while tailoring of certain requirements will be needed to reflect the unique features of these assets, it should not come at the cost of sacrificing investor protection. Failure to incorporate these core protections would pose significant and unnecessary risks to investors, issuers, and market quality. By contrast, incorporating these core protections in markets that trade digital securities (including those that may trade digital securities alongside other types of assets) provides for the long-term viability of new operating models. It is therefore in the interests of all market participants, including both new and existing market entrants, that digital asset markets include these protections, albeit with tailoring as necessary to reflect the unique features of blockchain technology. Broker-Dealers Play a Critical Role in Protecting Investors and Other Market Participants The core investor protections identified above originate in large part from the regulatory responsibilities broker-dealers are required to undertake. For example, broker-dealers are responsible for ensuring best execution and appropriate disclosures to clients about investor risks and conflicts of interest, thereby giving customers sufficient information to confidently make choices about how to direct their investments, typically at the touch of a button and with very little, if any, transaction fees. Broker-dealers are also bound by customer protection and safekeeping rules that ensure client assets are held securely, and other requirements that deter bad actors and financial criminals from exploiting investors and disrupting markets. Broker-dealers as underwriters also provide important protections to issuers in capital markets. These protections arise from having to meet due diligence and offering conduct standards; underwriting and distribution responsibilities; responsibilities for orderly trading in the secondary market; and conflict management to ensure fair treatment for individual issuers and investors. More broadly, participation of issuers in capital markets is supported by a range of requirements governing their ongoing disclosures to investors. It has been posited by some that broker-dealers, alongside other types of intermediaries, are unnecessary for distributed or decentralized operating models that are often found in markets for natively issued digital assets.1 Leaving aside the question of whether all these operating models are truly “decentralized” and intermediary-free, these critiques fail to establish how the investor protections associated with broker-dealer regulation, which have facilitated decades of successful economic growth, market performance, and widespread investor participation in the U.S. securities markets, would be replicated in these markets. It is crucial that policymakers consider these implications before providing exemptions from current broker-dealer registration requirements or shifting broker-dealer responsibilities to other actors with more limited capacities (such as transfer agents, a subject we discuss at greater length in our recent letter to the SEC). The Importance of Custody Protections for Investors Another set of core investor protections relates to the safekeeping of customer assets. Custodial services offered by banks and other qualified institutions have been critical to the success of modern capital markets for over 80 years, helping to manage conflicts of interest, ensure high levels of investor protection, and promoting the efficiency and stability of the markets. The custody function is premised on three key principles: Segregation of Client Assets: client assets, other than cash, must be segregated from the custodian’s proprietary assets and the assets of other clients at all times; Separation of Financial Activities: the safekeeping function must be separately maintained and operated from trading, asset management, and other similar market-facing activities; and Proper Control: the custodian must have control over the assets of its clients and the ability to transfer assets held for its clients based on the receipt of proper instructions. These principles are technology agnostic, meaning that the manner in which safekeeping is provided will continue to evolve with new technologies, as it has done over the past several decades. They also do not preclude new entrants or new business models from offering these services, nor does this prevent “self-custody” of digital assets by clients (though, as we have noted elsewhere, self-custody is likely to be impractical and inefficient for the vast majority of investors, and should also be narrowly defined as referring to situations in which clients truly hold both their own assets and keys2). It is critical that any entity offering digital asset safekeeping services adhere to these principles in order to protect customers and ensure the long-term stability of these markets. These protections are critical to preventing the types of customer losses seen when these structural protections do not exist, as seen in the cases of FTX and Voyager. Separation of Functions and Limits to Vertical Integration are also Critical to Protecting Investors Separation of core functions is another cornerstone of investor protection and market quality. By assigning distinct roles and responsibilities to broker-dealers, exchanges, custodians, and clearinghouses, today’s regulatory framework disperses financial, operational, and default risks and manages conflicts through a system of checks and balances. While there are some limited use cases in which broker-dealer and trading venue functions operate in adjacent structures (e.g., broker-dealer–affiliated ATSs), protections for investors are achieved in those cases through procedures, controls, and obligations that address investor suitability, manage conflicts and operational risks, and ensure robust disclosures. By contrast, permitting broad vertical integration that combines all these core market functions in a single “one-stop-shop” would strip away protections that are currently achieved through separation, effectively re-introducing major risks and undermining investor trust—as illustrated by some integrated models in native digital-asset markets (e.g., FTX). A better approach in our view would be to expand existing programs and requirements for the trading and issuance of tokenized securities to allow market participants to take advantage of efficiencies offered by new technologies, while utilizing the protections for investors that the existing separation of functions structure provides. The Need to Ensure Investor Clarity Around Tokenized Securities: The Technology used Does Not Change the Fundamental Characteristics of the Underlying Asset All the protections discussed above help to ensure that investors clearly understand what they are buying when they enter a securities transaction. Moving forward, it will be critical that investors in tokenized securities markets continue to enjoy this same level of understanding and confidence. Here, we wholeheartedly agree with Commissioner Peirce that “tokenized securities are still securities”3 ; that is, a security whose ownership is recorded using a blockchain-based token should be regulated in a manner that is consistent with other securities. The technology used does not change the fundamental characteristics of the underlying asset. Where specific requirements prove impractical when applied to tokenized securities, the SEC should consider narrow, carefully tailored adjustments that incorporate the core investor and market protections discussed above. Moreover, as Commissioner Peirce noted in her statement entitled “Enchanting but Not Magical: A Statement on the Tokenization of Securities,” it must be clear to investors that they are purchasing a tokenized security with legal and beneficial ownership of an operating or investment company and not, as is the case in certain models, a token that mirrors the value of the underlying security but does not grant those legal and economic rights (i.e., essentially a specific type of derivative known as a “security-based swap”). This highlights the importance of policymakers adopting a standard industry taxonomy that clearly and consistently classifies digital assets according to their underlying economic characteristics, thus allowing for the correct regulatory treatment to be applied to those assets.4 A Carefully Designed Innovation Exemption or Regulatory Sandbox Can Support Innovation Without Harming Investors or Markets In our recent letter to the SEC, we noted that a carefully structured “innovation exemption” or “regulatory sandbox” framework could offer important benefits. A properly designed framework would allow firms and other innovators to test novel digital-asset products and business models in a flexible yet controlled environment, giving the SEC real-time visibility into these products and services. These insights could, in turn, be used to better design tailored regulatory regimes that foster innovation while maintaining existing investor protections and market integrity. However, it is critical that any innovation exemption or regulatory sandbox framework act as a supplement to a broader policymaking process and not as a backdoor mechanism for rewriting key elements of the existing market structure regime. Major structural changes to market structures or core investor protections should be addressed through a normal notice-and-comment rulemaking process, not through the granting of exemptive, no-action or safe harbor relief from existing rules – or through an innovation exemption framework. In addition, as Commissioner Peirce has stated5 , it is critical that any framework should be open to all market participants; that is, it should not result in a single institution or group of firms gaining effective monopolies over a specific innovation. It is also critically important that any innovation exemption or regulatory sandbox framework operate within clear guardrails to avoid potential harm to investors or disruptions to the markets. Absent clear guardrails, an innovation exemption could become a way to issue and trade tokenized securities outside the core protections of the federal securities laws and regulations, increasing exposure to fraud, manipulation, and conflicts of interest, especially if issuance, trading, and settlement functions were to be vertically integrated within a single intermediary. Operating tokenized markets on platforms decoupled from the existing regime would also fragment liquidity, degrade price transparency, and impair execution quality—with knock-on negative impacts on overall market liquidity and investor outcomes. To ensure that the appropriate guardrails are put in place, the innovation exemption itself should be subject to a transparent, substantive notice-and-comment process that allows for broad industry input and engagement on its design and operation. In addition, significant project applications should also be subject to public input prior to being approved. As part of this process, each project should make minimum public disclosures; such disclosures should include the identity of the issuer, key structural features of the project, the venue where tokenized securities will be traded, and the types of disclosures that will be available to investors. Allowing public input on both the innovation exemption itself and specific project applications, as well as public disclosures, will result in better policymaking and ensure an appropriate level of transparency in the process. In terms of guardrails: there are three types of restrictions common in other jurisdictions with regulatory sandbox style regimes, such as the UK, that should apply to projects temporarily operating outside of the normal securities regulatory regime. First, there should be limits on the pool of investors that may participate in an innovation project, with an initial focus on more sophisticated institutional and accredited investors; this will help limit any potential adverse consequences for investors. Second, there should be caps on the size and volume of transactions and the number of customers that can participate, to mitigate against the possibility of regulatory arbitrage and market fragmentation. Third, there should be duration limits, which are essential to avoiding firms operating outside of the normal securities law framework for indefinite periods. The SEC should retain flexibility to adjust limits and phase up participation as systems demonstrate resilience; guardrails will also likely differ depending on which part of the securities lifecycle a particular project is focused, as discussed in our August 7th letter. Finally, it is also crucial that there be a “smooth exit ramp” into a permanent regulatory environment, though only once a project proves it can meet the full suite of investor-protection and market-operations requirements. Projects should not be transitioned into a temporary (or permanent), lighter-touch regulatory regime e.g., one subject to exemptive relief or no-action measures. Conclusion To ensure their long-term viability, it is critical that tokenized securities markets incorporate the robust investor protections that have helped to make the U.S. securities markets the largest, deepest, most liquid, and most efficient in the world. This includes ensuring that investor protections derived from the current broker-dealer and asset safekeeping frameworks are utilized in tokenized securities markets, and that the protections arising from limits on vertical integration and separation of core functions are included in these markets. It also means clearly defining what tokenized securities are and what they are not in order to provide greater certainty to investors. At the same time, existing rules and market structures need to be modernized to accommodate the unique features of new technologies such as blockchain and tokenization. As discussed here, a carefully designed innovation exemption or regulatory sandbox framework can help supplement a broader process of regulatory modernization, a process that should involve widespread consultation with a diverse group of stakeholders to ensure that it is promoting innovation while also protecting investors and market integrity. If this approach is taken, the result will be a strong, durable U.S. tokenized securities market that fosters innovation and widespread investor confidence. Authors Peter Ryan is a Managing Director and Head of International Capital Markets and Strategic Initiatives at SIFMA. Charles DeSimone is a Managing Director and Deputy Head of the Technology, Operations, and BCP group at SIFMA. Footnotes For example, see DeFi Education Fun and Andreessen Horowitz, “Recommendations Regarding a Safe Harbor from the Broker Registration Requirements of the Securities Exchange Act of 1934,” August 13, 2025, available at: https://www.sec.gov/files/ctf-written-a16z-def-safe-harbor-proposal-applications-081325.pdf. [↩] https://www.sifma.org/wp-content/uploads/2025/05/SIFMA-SEC-Crypto-RFI-Initial-Response-May-2025.pdf. [↩] https://www.sec.gov/newsroom/speeches-statements/peirce-statement-tokenized-securities-070925. [↩] As discussed in our May letter to the SEC’s Crypto Task Force, a good example of such a taxonomy is the one developed by our global affiliate, the Global Financial Markets Association (“GFMA”), which was subsequently endorsed by the CFTC’s GMAC Digital Asset Markets Subcommittee. [↩] https://www.sec.gov/newsroom/speeches-statements/peirce-old-flames-071625. [↩] Related Resources SIFMA Letter Request for Comment on Statement by Commissioner Hester M. Peirce Re: Crypto RFI (SIFMA and SIFMA AMG)   Commissioner Hester M. Peirce Statement Enchanting, but Not Magical: A Statement on the Tokenization of Securities

Today, Nasdaq proposed a new set of enhancements to its initial and continued listing standards, reinforcing its long-standing commitment to capital formation while ensuring investor protection and upholding market integrity. These proposed updates introduce enhanced requirements for minimum company public float and capital raised during initial public offerings, alongside stricter suspension and delisting procedures for companies failing to meet Nasdaq’s continued listings standards. The revised standards include: A $15 million minimum market value of public float, applicable to new listings on Nasdaq under the net income standard. An accelerated process for suspending and delisting companies with a listings deficiency that also have a Market Value of Listed Securities below $5 million. A $25 million minimum public offering proceeds requirement for new listings of companies principally operating in China. “Investor protection and market integrity are central to Nasdaq’s mission,” said John Zecca, Executive Vice President and Global Chief Legal, Risk & Regulatory Officer. “These enhancements reflect our ongoing commitment to evolve our standards in step with market realities and to lead by example in promoting fair and orderly markets. By increasing our standards for the minimum public float and the public offering raise in certain new listings, it provides a healthier liquidity profile for public investors, while still making emerging companies available to investors through our exchange. These new listing standards represent one step in a necessary, industry-wide effort—alongside regulators, U.S. exchanges, and market participants—to closely examine trading behaviors in small company securities, with the goal of safeguarding market integrity and enhancing protections for investors.” The actions announced today follow Nasdaq’s proactive review of trading activity, particularly emerging patterns associated with potential pump-and-dump schemes in U.S. cross-market trading environments. The proposed updates are also reflective of how market dynamics and company valuations have evolved over time, prompting the need to recalibrate Nasdaq’s minimum liquidity standards to suit today’s environment. These enhancements ensure that the thresholds for public listings remain relevant and effective as markets evolve. As part of these changes, Nasdaq is reintroducing a minimum public offering proceeds requirement specifically for companies principally operating in China, building on previous standards set for “restrictive markets,” in which the Public Company Accounting Oversight Board (PCAOB) could not inspect auditors.1 By applying this threshold, Nasdaq strengthens investor protections and enhances the liquidity profile of companies to reflect today’s market environment. In addition to the enhanced listing standards, Nasdaq will continue to actively refer cases to the Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) on potentially manipulative trading activities, while strengthening our cooperation with both domestic and international regulators to reinforce effective oversight and maintain high standards across U.S. markets. Nasdaq is submitting the proposed rules to the SEC for review and, if approved, is proposing to implement the changes to the initial listing requirements promptly. Nasdaq is proposing to give companies already in the initial listing process a period of 30 days to complete the process under the prior standards, and thereafter all new listings will have to meet the new requirements. Regarding the accelerated process for suspending and delisting companies, Nasdaq is proposing to implement the new requirements 60 days after SEC approval. These changes build upon Nasdaq’s history of regulatory leadership that have been followed by others, including prior changes aimed at improving liquidity, tightening compliance timelines, and curbing abusive practices such as excessive reverse stock splits. Previous changes include: Restrictive Markets: In May 2020, Nasdaq proposed, and the SEC approved in October 2021, new rules for IPOs from “restrictive markets” that imposed higher requirements for companies, mainly from China, to list on its markets. The rules required that companies from restrictive markets have a minimum public offering size of $25 million, or 25% of the value of their securities. The new rule that Nasdaq is currently proposing regarding the $25 million minimum public offering proceeds is consistent with the $25 million standard established in the 2020 rule change. Liquidity requirement changes: In July 2019, Nasdaq changed its liquidity requirements to exclude restricted holdings from the shareholder count and public float calculation, and to require at least half of the minimum number of round lot holders to own unrestricted securities with a minimum value of $2,500. This change also requires average daily volume requirements for companies that uplist from the Over-the-Counter market. In September 2022, Nasdaq enhanced its review of smaller IPOs to help ensure underwriters are focused on placing shares in a manner expected to provide adequate liquidity. In July 2023, Nasdaq proposed a new rule, approved in March 2024, providing additional oversight of a principal underwriter in a Nasdaq IPO. In April 2025, Nasdaq required newly listed companies to satisfy adjusted rules related to meeting market value thresholds solely from shares sold in the IPO, thereby excluding shares held by selling shareholders. These adjustments were made to increase liquidity of the new securities in the marketplace. Enhancements addressing non-compliance: In September 2021, Nasdaq implemented a new rule that limited companies’ ability to effect excessive reverse stock splits. Nasdaq also made rule changes that would allow it to move a company into the delisting process immediately if its share price is below $0.10 for ten consecutive trading days. In November 2023, Nasdaq made additional changes to require additional disclosures regarding reverse splits and the process for halting stocks undergoing reverse splits. In October 2024, Nasdaq further limited the time provided to companies to cure a listing deficiency if that deficiency was caused by a reverse split enacted to regain compliance with bid price requirements. In January 2025, Nasdaq decreased the time a company could trade on Nasdaq while below $1 to 360 days and prohibited further compliance periods to any company that effected a reverse stock split within the prior year. In August 2025, Nasdaq proposed new rules to suspend and more quickly delist companies trading below $0.10, for ten consecutive trading days, even if they are not otherwise already in a compliance period. Additionally, today, Nasdaq has responded to the SEC’s request for comments regarding the eligibility of foreign companies trading in the U.S. to benefit from less burdensome U.S. reporting obligations. In the letter, Nasdaq emphasized the need to balance the interest in attracting foreign companies to the U.S., with the need to protect all investors in the U.S. public markets, which are the envy of the world. Together, these efforts underscore Nasdaq’s leadership in fostering a resilient and transparent marketplace that supports appropriate listing standards for issuers and safeguards investor interests. The official filings related to the proposed changes can be accessed via the following links: https://listingcenter.nasdaq.com/assets/rulebook/nasdaq/filings/SR-NASDAQ-2025-068.pdf https://listingcenter.nasdaq.com/assets/rulebook/nasdaq/filings/SR-NASDAQ-2025-069.pdf

On Wednesday, September 10, Secretary of the Treasury Scott Bessent will preside over a meeting of the Financial Stability Oversight Council (Council) at the Treasury Department. The meeting will consist of an executive session and an open session. The preliminary agenda for the executive session includes an update on the Council’s focus and priorities; a briefing on a recent interagency financial market infrastructure cybersecurity tabletop exercise; the Council’s 2025 annual report; and the Council’s fiscal year 2026 budget.* The preliminary agenda for the open session includes an update on banking supervision and regulatory reforms; votes to rescind the charters of two Council committees focused on climate-related financial risk; and a vote on the Council’s fiscal year 2026 budget. The Dodd-Frank Wall Street Reform and Consumer Protection Act requires the Council to convene no less than quarterly, but the Council has historically convened on a more frequent basis. The meetings bring Council members together to discuss and analyze emerging market developments and financial regulatory issues. The Council is committed to conducting its business as openly and transparently as practicable, given the confidential supervisory and sensitive information at the center of its work. Consistent with the Council's transparency policy, the Council opens its meetings to the public whenever possible. Open session Council meetings are made available to the public via live webcast and can also be viewed after they occur. Upcoming Council meeting dates and times are posted following the official notification to Council members of an upcoming meeting. Meeting minutes and readouts for past Council meetings are available below. Meeting minutes for the most recent Council meeting are generally approved at the next Council meeting and posted online soon afterwards. * In accordance with the Council’s Transparency Policy, which is available at www.fsoc.gov, this portion of the meeting will be held in a closed session to prevent the potential disclosure of information contained in or related to investigation, examination, operating, or condition reports prepared by, on behalf of, or for the use of, an agency responsible for the regulation or supervision of financial markets or financial institutions; information which would lead to significant financial speculation, significantly endanger the stability of any financial market or financial institution, or significantly frustrate implementation of a proposed agency action; information exempted from disclosure by statute or by regulation, or authorized under criteria established by an Executive Order to be kept secret; trade secrets and commercial or financial information obtained from a person and privileged or confidential; and inter-agency and intra-agency memoranda or letters which would not otherwise be available by law. 

Thank you to Aaron Klein, Miriam K. Carliner Chair—Economic Studies, Senior Fellow—Center on Regulation and Markets and Brookings Institute for kindly inviting me to join you this afternoon. Thank you for your thoughtful introduction. A Critical, High-Stakes Moment  There is no better place to close out my tenure as a Commissioner at the Commodity Futures Trading Commission (CFTC or Commission) than with a conversation on the future of financial regulation.[1] It is a privilege to join you at Brookings. You have demonstrated an unparalleled commitment to convening stakeholders and the public to explore significant questions such as—what does the future of financial markets look like? As someone who spent part of my career as a lawyer in private practice, in-house at a large financial institution, as an academic, and now a regulator—I know exactly how important great conversations are for developing transformative policy insights.  We gather at a critical moment in the history of our nation and a unique time in the evolution of financial markets and the role of financial markets regulation.  It has never been more important for the public to be engaged and have a voice in the role of financial market regulation. The decisions that Congress and regulators will make during the next few years will shape our national economy, the global economy, and the role of the United States in the global economy for generations to come.  The stakes are high. And, if I only have one piece of wisdom to share, it would be the following—Get it right. Measure twice, cut once. Deciding the course for financial markets and financial markets regulation simply requires remembering why we regulate and the catastrophic consequences that may follow if we fail to regulate well. Throughout my tenure as a Commissioner at the CFTC, I have prioritized two pillars that anchor the foundation of financial markets regulation—consumer protection and market stability. Consumer Protection and Growth—Twin Pillars, Anchoring Values   Some may try to challenge the notion that these values work together and argue that sustainable growth and consumer protection are in tension, at odds, or mutually exclusive. I reject the notion that these anchoring values are in conflict and instead argue that each is a necessary component of a healthy financial system. Recall, in 2008, on a September day, similar to the cool, crisp weather we are enjoying today, lawyers for Lehman Brothers entered a federal court building, and one of the most storied financial institutions in our nation’s history filed for bankruptcy protection. The filing served as a catalyst, precipitating the events of a global financial crisis. According to the Federal Reserve Bank of New York, around the same time “[i]n September 2008, the Federal Reserve extended credit to American International Group, Inc. (AIG) to preserve the stability of an already fragile U.S. economy and to protect the U.S. taxpayer from the potentially devastating consequences of the company's disorderly failure. From that initial intervention, the New York Fed and the U.S. Department of the Treasury worked with AIG to stabilize the company so that it no longer posed a systemic risk and to ensure repayment of taxpayer assistance.”[2] A little over a decade later, on a similar day in the fall of 2022, after cascading losses and multiple collapsed crypto firms, lawyers for FTX marched into a federal court building seeking bankruptcy protection. What should we take away from these crises? Lessons Learned from Crises  If we fail to rightly prioritize consumer protection or market stability on the road to capturing the benefits of innovation or growth, the results can be devastating. When I share the story of Lehman or AIG or the more contemporary story of FTX, I emphasize that certain guardrails or safety measures may well have helped prevent the 2008 financial crisis and certainly could go a long way to ensuring that developing digital asset markets function in a manner that is consistent with consumer protection and market stability and integrity. To achieve sustainable growth and get it right, we must measure twice, cut once. The Costs of Risk Management and Corporate Governance Failures Crises have the potential to create catastrophic costs for customers, creditors, investors, markets, and the domestic and global economies. The factors that lead to corporate governance and risk management failures are often clearly identifiable, easily predicted, and often preventable. Firms that experience significant corporate governance and risk management failures often seek bankruptcy protection, only to later re-emerge from bankruptcy to solicit and expose new customers to devastating losses because the firms continue relying on the same deeply deficient (and possibly non-existent) governance, compliance, and risk management programs. Unfortunately, unless these firms learn from this experience and adopt a culture of compliance that effectively alters behavior and closes gaps in risk management and corporate governance, they will find themselves repeating the same cycle. We’ve Seen This Movie (or Bankruptcy) Before For almost a decade, but with increasing frequency in recent years, international media headlines repeatedly (sometimes weekly, and sometimes almost daily) present a new cautionary tale. The cautionary tales are woven together by a set of common threads. An almost 30-year-old CEO launches an international crypto-exchange. Within a few years, the founder and the exchange achieve crypto-celebrity status. At its peak, the exchange captures significant market share—processing a sizable percentage of global coin or token transactions. The firm, organized in a jurisdiction outside of the United States, lacks many aspects of traditional corporate governance including oversight by a qualified, informed, engaged and independent board of directors. All too often, the corporate governance and, compliance systems—including anti-money laundering and know your customer programs, and conflicts of interest policies that prohibit or limit certain transactions (particularly self-serving loans)—may be weak or may not exist at all. Like lightning striking, in an instant, the exchange suspends trading, shutters the windows for withdrawals, silences traffic on its website, and files for bankruptcy protection—leaving customers infuriated, investors stunned, and creditors scrambling in a footrace to the courthouse. Interconnectedness among crypto-firms amplified by fragile or non-existent risk management, corporate governance failures, and conflicts of interests at individual firms fuels the likelihood of crises. In the late spring of 2022, a “run” on the fourth largest stablecoin and tenth largest cryptocurrency, TerraUSD (“UST”), led to a precipitous decline in the value of UST and, in tandem, a sell-off of LUNA, its companion token. A broad market sell-off and cascading losses followed. With the onset of a “crypto winter,” a number of highly-influential and central crypto-firms lunged toward bankruptcy. With significant exposure to the TerraLUNA ecosystem, Three Arrows Capital (“3AC”), a Singapore-based crypto-hedge fund, defaulted on a loan to crypto-lender Voyager Digital. On July 1, 2022, less than one week after the default, 3AC filed for bankruptcy protection. Almost on cue, within a week, Voyager halted trades, deposits, and withdrawals and filed for bankruptcy protection. Eight days later, another crypto-lender, Celsius Network, also filed for bankruptcy. In November 2022, FTX and BlockFi joined the list of crypto-firms seeking bankruptcy protection; and the list continued to grow. A week after FTX filed for bankruptcy, I delivered a keynote address at the annual meeting of the Federal Reserve Bank of Chicago Financial Markets Group. I emphasized the need for proactive adoption of internal governance and risk management measures that introduce important know-your-customer and customer identification program obligations, financial resource requirements, limitations on the use and treatment of customer funds, internal controls and conflicts of interest policies designed to address transactions with affiliates. I admonished firms that have failed to implement recovery and resilience programs. Businesses operating in our markets must have a day-one plan for how to address a capital shortfall. Later that same week, at Stanford Law School’s Crypto-Policy Conference, I explained the need for the Commission to have a seat at the table as the court and creditors considered an appropriate buyer in the sale of non-debtor LedgerX. While there has been a general acknowledgement of the need for any buyer to be “familiar with” the Commodity Exchange Act (CEA) and CFTC regulations and a historic acquiescence to Commission inquiries, regulations only provide that the CFTC receive notice of the transfer of equity ownership. Particularly in times of crises, such a low threshold may not be sufficient to ensure that the Commission receives meaningful access and material information regarding all relevant aspects of the transaction in real time. Customer Protections Look Similar in Most Markets  Don’t lie. Don’t cheat. Don’t steal. Customer protection is a foundational and core principle of our market regulatory framework. Several specific provisions of the CEA direct the CFTC to adopt regulation to this effect. Customer funds consist of margin collateral posted by customers of futures commission merchants (FCMs) to cover exposure under their futures contracts. Section 4d(a)(2) of the CEA requires each FCM to segregate from its own assets all money, securities, and other property deposited by futures customers to margin, secure, or guarantee futures contracts and options on futures contracts traded on designated contract markets. In addition, Section 4d(a)(2) of the CEA requires an FCM or the custodian of customer funds to treat and deal with customer funds as belonging to the customer, and prohibits an FCM from using the funds deposited by a futures customer to margin or extend credit to any person other than the futures customer that deposited the funds. After the collapse of MF Global and Peregrine Financial Group, the Commission thoughtfully and meticulously supplemented the protections embedded in Commission regulations 1.20 through 1.30, and 1.32 to enhance customer protections and transparency at the FCM level. Two Hard Truths First, governance and risk management failures can and often do lead to crises, including liquidity crises. Second, apart from undermining the reputational integrity of the industry and fueling calls for harsh regulatory and legislative action, these failures all too often impose tremendous costs that fall disproportionately on customers. In my final months at the Commission, we also witnessed a surge in new applicants and registered market participants in prediction markets. These prediction market contracts enable retail investors to take a position on everything from U.S. elections to whether Michigan would take New Mexico in the season opener in Ann Arbor last weekend (as an alumnae of the law school, I will admit that I am glad to see that Michigan did secure that win).  I am disappointed that during my time at the Commission we were not able to successfully advance a final rule that addressed the introduction of political event contracts. Activity in markets in most recent months underscores my concerns and the concerns of others about prediction markets. As of today, we have too few guardrails and too little visibility into the prediction market landscape. Because the target audience for these contracts is retail customers and some market participants seem to be marching down a path to offer leveraged, margined prediction market contacts to retail investors, there is an urgent need for the Commission to express in a clear voice our expectations related to these contracts. A bi-partisan group of members of Congress indicated that they agreed with that the CFTC should not be required to police election contacts and expressed concerns about betting on the outcome of democratic elections. There are also a number of legal questions surrounding these contracts that the Commission should use the rulemaking process with embedded notice and comment period obligations to create effective regulation to address. Finally, the “rent or buy” my license in derivatives markets is booming as prediction markets promise to eclipse crypto markets in volumes of retail customers’ cash captured. The Commission has recently witnessed a number of newly created and legacy firms seeking licenses to offer event contracts. In a number of instances, these businesses approach the Commission seeking licenses to offer traditional products, only to quickly shift once a license is in hand and seek to self-certify prediction market contracts. In other contexts, firms that have received a license quickly auction their newly minted license to others. Never Let a Good Crisis Go to Waste I referenced the financial crisis of 2008 earlier. As I return to academia, I appreciate that some of my students were not yet born when Enron collapsed and others may have been in elementary school during the 2008 global financial crisis. One of my goals as a teacher is to ensure that our students are well-versed in the history of financial markets regulation and that they understand my commitment to never let a good crisis go to waste. Innovation, Cutting-Edge Technologies Impacting Market Stability and Market Integrity To that end, during my time at the Commission, I have worked diligently to ensure that we advance our understanding of the innovation and cutting-edge technologies that have the potential to disrupt markets and create systemic risk concerns. While I will focus on cyber threats here, I have regularly advocated for financial market regulators to think critically about operational resilience and third-party risk management as well as concentration risks among third parties. As I explained earlier, innovation and market stability should work together—enabling one to foster the other. I can identify at least a dozen of valuable use cases for artificial intelligence in financial markets—surveillance and compliance use cases immediately spring to mind. However, as we integrate AI into financial markets, we must be aware of bad actors’ ability to use AI to perpetuate fraud. We must also be aware of risks that arise as hackers integrate or embed AI into necessary technology, facilitating cyber threats. I have advocated for the CFTC and other U.S. federal regulators to collaborate in convening conversations regarding the integration of AI in financial markets. I worked with the Commission staff to develop the Commission’s request for comment on AI. I also supported Treasury in developing a request for information on the integration of AI in financial markets. I have also advocated for some specific policy interventions that I believe may separate the wheat from the chaff. First, for U.S. financial market regulators, coordination and cooperation are imperative. We must harmonize expectations. Second, we should enhance information sharing. Third, we need to strengthen crisis recovery and response. Finally, we must tackle concentration risk and supply chain vulnerabilities. Even for these complex issues, the adage offered at the outset of my remarks still replies. Get it right—Measure twice.  Conclusion In closing allow me to acknowledge the Commission’s most significant asset, its secret weapon—a Navy-seal styled (in some cases, literally) team of the most capable and talented lawyers, economists and professionals that I have had the privilege of working with—the CFTC staff. In a moment in time when it is easy to forget, it was the Commission staff that worked around the clock during the financial crisis to help get our markets back on track and to build the blueprint for a regulatory framework that has stood the test of a pandemic and significant geopolitical conflicts. Facing these issues alongside persistent inflation, our markets have demonstrated resilience. I credit markets’ resilience, at least in part, to the regulatory reform that followed the financial crisis in 2008 and the individuals who built those reforms by hand. I also deeply grateful to President Biden and the many Senators that supported me during my confirmation process for my current role as a Commissioner at the CFTC as well as my nomination to join the U.S. Department of Treasury. I am also thankful to everyone in my village. When I think of your support and sacrifices, I am overwhelmed with gratitude. I am hopeful that I made you proud and served you well. [1] The views I share today are my own and not the views of the Commission, my fellow Commissioners or the CFTC staff. A portion of this speech is adapted from previously delivered remarks. [2] Federal Reserve Bank of New York, Actions Related to AIG, available at https://www.newyorkfed.org/aboutthefed/aig/.

Cboe Global Markets, Inc. (Cboe: CBOE), the world's leading derivatives and securities exchange network, announced today that Craig Donohue, Chief Executive Officer, will present at the Barclays Global Financial Services Conference in New York City on Monday, September 8 at 10:30 a.m. ET. The live webcast and replay of the presentation will be accessible at ir.cboe.com, under Events and Presentations. The archived webcast is expected to be available within an hour of the presentation.

Nasdaq (Nasdaq: NDAQ) today reported monthly volumes for August 2025 on its Investor Relations website. A data sheet showing this information can be found at: http://ir.nasdaq.com/financials/volume-statistics.

The Securities and Exchange Commission today charged Daryl F. Heller of Pennsylvania and his companies, Prestige Investment Group, LLC and Paramount Management Group, LLC, with operating a multi-year Ponzi scheme that resulted in investor losses of approximately $400 million. According to the complaint, from January 2017 through June 2024, Heller and Prestige raised more than $770 million from approximately 2,700 investors, many of whom are retail investors, to invest in ATMs operated by Paramount. The complaint alleges that Heller used his control of Prestige and Paramount to create the false impression that they were running a successful, nationwide ATM network and paying investors fixed monthly distributions from income earned from ATM transaction fees and related charges. In reality, as alleged, the defendants misrepresented the size and profitability of the ATM network and paid distributions to investors primarily using money from new investments and high-interest, short-term loans. Heller also misappropriated more than $185 million of investor funds for his own benefit, including for a beach house and his other businesses, according to the complaint. “Heller allegedly exploited his connections to his community and deceived retail investors into thinking the ATM investments were safe and reliable, when in reality he used only a fraction of investor funds to buy ATMs and misappropriated $185 million,” said Scott A. Thompson, Associate Director of Enforcement in the SEC’s Philadelphia Regional Office. “The SEC remains committed to diligently pursuing those who prey on hard-working investors and holding wrongdoers accountable." The SEC’s complaint, filed in U.S. District Court for the Eastern District of Pennsylvania, charges Heller, Prestige, and Paramount with violations of the antifraud provisions of the federal securities laws. It seeks permanent injunctions, disgorgement of ill-gotten gains with prejudgment interest, and civil penalties against the defendants and a conduct-based injunction and officer and director bar against Heller. In a parallel action, the U.S. Attorney’s Office for the Eastern District of Pennsylvania announced criminal charges against Heller. The SEC appreciates the assistance of the U.S. Attorney’s Office for the Eastern District of Pennsylvania, the FBI, and the Internal Revenue Service. Resources SEC Complaint

The Commodity Futures Trading Commission’s Division of Market Oversight and the Division of Clearing and Risk today announced they have taken a no-action position regarding swap data reporting and recordkeeping regulations for event contracts in response to a request from QCX LLC, a designated contract market, and QC Clearing LLC, a derivatives clearing organization.   The divisions will not recommend the CFTC initiate an enforcement action against either entity or their participants for failure to comply with certain swap-related recordkeeping requirements and for failure to report to swap data repositories data associated with binary option transactions and variable payout contract transactions executed on or subject to the rules of QCX LLC and cleared through QC Clearing LLC, subject to the terms of the no-action letter.  The no-action letter applies only in narrow circumstances and is comparable to no-action letters issued for other similarly situated designated contract markets and derivatives clearing organizations.  RELATED LINKS CFTC Staff Letter No. 25-28

Today Moscow Exchange announced the results of the quarterly review for MOEX indices. All changes were made upon recommendations from the Index Committee and will be implemented from 19 September 2025. The Exchange has also set free floats and additional weighting factor for several companies. The MOEX Russia Index and the RTS Index will be modified by ordinary shares of PJSC "X5 Corporate Center" being added to the constituent list of the Index, while ordinary shares of PJSC Astra Group, ordinary shares of PJSC "RusHydro" and ordinary shares of PJSC "FGC Rosseti" will leave the Index. The constituent list of the Blue Chip Index will be modified by ordinary shares of PJSC "X5 Corporate Center" being added to the constituent list of the Index, while ordinary shares of IPJSC Headhunter will be excluded from the Index. Ordinary shares of PJSC "Rosseti Volga" will be included in the constituent list of the SMID Index. The constituent lists of the Broad Market Index and the sectoral indices will remain unchanged. The following shares will be under consideration to be added to the MOEX Russia Index and the RTS Index: ordinary shares of PJSC "Samolet Group", ordinary shares of IPJSC "Rusagro Group", ordinary shares of IPJSC CIAN, ordinary shares of Lenta IPJSC and ordinary shares of PJSC "SFI". Ordinary shares of PJSC "Unipro" will be under consideration to be excluded from the MOEX Russia Index and the RTS Index. Summary table of key changes in the Moscow Exchange Indices' Constituents Lists Index Included Excluded   MOEX Russia Index and RTS Index PJSC "X5 Corporate Center", Ordinary shares PJSC Astra Group, Ordinary shares PJSC "FGC Rosseti", Ordinary shares PJSC "RusHydro", Ordinary shares     Blue Chip Index PJSC "X5 Corporate Center", Ordinary shares IPJSC Headhunter, Ordinary shares   SMID Index PJSC "Rosseti Volga", Ordinary shares -   MOEX 10 Index IPJSC YANDEX, Ordinary shares PJSC "PIK Group", Ordinary shares PJSC "X5 Corporate Center", Ordinary shares PJSC "Mechel", Ordinary shares   Equity Subindex (EPSI) MD Medical Group IPJSC, Ordinary shares PJSC "FGC Rosseti", Ordinary shares   Summary table of changes in number of shares employed in the calculation of the Moscow Exchange Indices and included in the waiting lists, as well as free-float coefficients Ticker Issuer Current number of shares New number of shares Current free-float New free-float DATA PJSC "ARENADATA GROUP", Ordinary shares 209 160 464 209 160 464 13% 17% ETLN Etalon Group IPJSC, Ordinary shares   383 445 362 51% 44% EUTR PJSC "EvroTrans", Ordinary shares 159 148 665 159 148 665 33% 32% FIXR "Fix Price" PJSC, Ordinary shares   100 000 000 000 - 17% GAZP PJSC "GAZPROM", Ordinary shares 23 673 512 900 23 673 512 900 50% 47% KCHE PJSC "Kamchatskenergo", Ordinary shares 58 294 409 860 58 294 409 860 - 1% KRSB PJSC "Krasnoyarskenergosbyt", Ordinary shares 596 039 612 596 039 612 - 5% LSRG PJSC "LSR Group", Ordinary shares 103 030 215 103 030 215 25% 24% MBNK PJSC "MTS Bank", Ordinary shares 34 629 063 37 526 637 13% 12% MOEX PJSC "Moscow Exchange", Ordinary shares 2 276 401 458 2 276 401 458 64% 65% MVID PJSC "M.video", Ordinary shares 179 768 227 179 768 227 20% 21% NSVZ PJSC "Nauka-Telecom", Ordinary shares 15 701 562 15 701 562 4% 5% OZPH PJSC "Ozon Pharmaceuticals", Ordinary shares 1 098 571 440 1 098 571 440 10% 14% RZSB JSC "Ryazanenergosbyt", Ordinary shares 206 940 220 206 940 220 - 9% SLEN PJSC "Sakhalinenergo", Ordinary shares 1 237 175 444 1 237 175 444 - 6% SVCB PJSC "Sovcombank", Ordinary shares 20 693 945 875 22 516 228 905 15% 13% UGLD PJSC "UGC", Ordinary shares 222 778 849 052 222 778 849 052 10% 11% UNAC PJSC "UAC", Ordinary shares 994 436 434 417 1 009 366 990 290 3% 3% YKEN PJSC "Yakutskenergo", Ordinary shares 10 187 741 424 10 187 741 424 - 16% From 19 September 2025, the following shares will be under consideration: Under consideration to be added to Moscow Exchange indices: Ticker Issuer Index ABIO PJSC "Artgen", Ordinary shares Broad Market Index GTRK PJSC "GTM", Ordinary shares IVAT PJSC "IVA", Ordinary shares MRKY PJSC Rosseti South, Ordinary shares MRKZ PJSC Rosseti North-West, Ordinary shares PMSBP PJSC "PESC", Preferred shares RKKE RSC Energia, Ordinary shares TGKB PJSC "TGC-2", Ordinary shares TTLK PJSC "Tattelecom", Ordinary shares ZAYM PJSC "Zaymer", Ordinary shares CNRU IPJSC CIAN, Ordinary shares MOEX Russia Index RTS Index LENT Lenta IPJSC, Ordinary shares RAGR PJSC "Rusagro Group", Ordinary shares SFIN PJSC "SFI", Ordinary shares SMLT PJSC "Samolet Group", Ordinary shares Under consideration to be excluded from Moscow Exchange indices: Ticker Issuer Index KZOS PJSC "Kazanorgsintez", Ordinary shares Broad Market Index UPRO PJSC "Unipro", Ordinary shares MOEX Russia Index RTS Index For information regarding the lists of stocks employed in the Moscow Exchange Indices as well as the lists of securities employed in the Multi-Assets Indices of Moscow Exchange, please, follow the link.