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In a letter filed today with the Securities and Exchange Commission (SEC) PTG strongly supports the SEC’s proposal to rescind Regulation NMS Rule 611 (the trade-through rule) and Rule 610(e) (the prohibition on locked and crossed markets), arguing that these rules have contributed to excessive market fragmentation, exchange proliferation, complex order types, and significant connectivity, routing, and compliance costs. The letter contends that while Rule 611 originally promoted displayed liquidity and price competition, it also created regulatory incentives that enabled the growth of numerous exchanges that add limited trading value while generating market data and connectivity revenues. PTG believes rescission is an important step toward a simpler and more competitive market structure but cautions that many of the underlying incentives created by the current regulatory framework will remain unless related reforms are addressed simultaneously.

In a letter filed today with the Securities and Exchange Commission (SEC), PTG supports the CT Plan Third Amendment’s 5:1 cap on quote-related versus trade-related revenue allocations as a corrective step but argues it is too narrow to fix the deeper structural problems in the SIP revenue allocation formula. The letter contends that the current formula over-rewards quoting activity relative to executed trades, creating incentives for exchange proliferation and revenue extraction rather than genuine contributions to liquidity, price discovery, or market quality.

In a letter filed today with the Securities and Exchange Commission (SEC), PTG opposes the proposal to permit optional semiannual reporting by public companies. PTG supports efforts to reduce unnecessary public-company burdens, but contends that reducing the frequency of mandatory, auditor-reviewed disclosures would weaken the transparency, consistency, comparability, and accountability that support U.S. market quality and investor confidence.

In a letter filed today with the Securities and Exchange Commission (SEC), PTG urges the Commission to take direct control over Consolidated Audit Trail (CAT) funding and governance. The letter recommends the SEC fund CAT through the existing Section 31 fee process by incorporating CAT costs into the Commission’s Congressionally approved budget. PTG argues this would add legislative oversight, fiscal discipline, and accountability while still allowing the industry to cover costs through the existing fee mechanism.