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In a letter filed today, PTG urges the U.S. Securities and Exchange Commission (SEC) to suspend proposed rule changes by Cboe BYX Exchange, Inc., Cboe BZX Exchange, Inc., Cboe EDGA Exchange, Inc., and Cboe EDGX Exchange, Inc. that would expand the definition of “Trading Platform” for purposes of exchange-direct market data fees. The proposals add a catch-all category for a “similar order matching execution venue or decentralized platform,” which the Exchanges state is intended to be interpreted broadly enough to include single-dealer platforms. PTG argues that this approach creates an unclear and internally inconsistent standard that could lead to disputes over fee obligations and fail to satisfy the Exchange Act’s requirements for the fair and equitable allocation of fees.

In a letter filed today, PTG supports FINRA’s preliminary conclusion that Rule 5310’s principles-based best execution framework remains sound, but argues that the related guidance should be modernized, particularly if the SEC rescinds Regulation NMS Rules 611 and 610(e). Because those changes could significantly affect venue connectivity, order routing, displayed quotations, and the role of the NBBO, PTG urges FINRA to coordinate closely with the SEC and solicit public comment before adopting materially revised guidance. PTG also recommends an ongoing best-practices program featuring periodic thematic reviews, anonymized examples of effective and problematic conduct, and recurring industry consultation.

In a letter filed today with the Securities and Exchange Commission (SEC), PTG expresses qualified support for Cboe Clear U.S. (CCUS) receiving temporary registration as a clearing agency for Binary KPI Options, but strongly opposes any effort to make that registration permanent. PTG views CCUS as a short-term solution that can help bring innovative products to market while the Options Clearing Corporation (OCC) develops the capability to clear them. The letter argues that OCC remains the appropriate long-term clearing venue and notes that OCC has already established a framework for clearing binary options, making a permanent alternative clearing structure unnecessary.

In a letter filed with the Securities and Exchange Commission (SEC) today, PTG argues that the SEC’s existing regulatory framework for ETFs, particularly Rule 6c-11, is generally working as intended and should continue to govern so-called “Novel ETFs” without imposing broad new restrictions. PTG emphasizes that ETFs have successfully expanded investor access to innovative and previously difficult-to-access asset classes while fostering competition, efficiency, and innovation. PTG contends that the regulatory focus should remain on whether ETF structures function effectively rather than on whether a product is labeled “novel.”