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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.”

In a letter filed today with the Commodity Futures Trading Commission (CFTC) and the Securities and Exchange Commission (SEC), PTG expresses support for the Commissions’ efforts to expand portfolio margining and cross-margining programs. PTG argues that modern financial markets are highly interconnected and that margin requirements should better reflect genuine risk offsets across related securities and derivatives positions. According to PTG, well-designed portfolio and cross-margining frameworks can improve risk management, reduce unnecessary collateral requirements, enhance capital efficiency, and support market liquidity while maintaining market resilience.

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.