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In a comment letter filed with the Treasury Department today, PTG argues that the proposed rules create significant uncertainty for principal trading firms that buy, sell, and provide liquidity in stablecoins on their own account. PTG urges Treasury to clarify that proprietary trading firms are not “Digital Asset Service Providers” (DASPs) when they trade solely for their own account and do not provide services to customers. The letter contends that the statutory term “digital asset service provider” was intended to capture intermediaries such as exchanges and custodians, not firms engaged in independent market-making, inventory management, or secondary-market trading. PTG warns that failing to make this distinction could discourage liquidity provision and undermine the effectiveness of the U.S. stablecoin framework.

In a letter filed today with the Securities and Exchange Commission (SEC) PTG strongly opposes the request by CAT LLC and the self-regulatory organizations (SROs) for an exemption from Financial Accountability Milestone 4 (FAM 4), arguing that the request would improperly shift more than $260 million in CAT implementation costs from the SROs to broker-dealers and investors. PTG contends that the SEC established the Financial Accountability Milestones specifically to hold the SROs financially accountable for delays in implementing the Consolidated Audit Trail (CAT). According to the letter, the SROs missed the FAM 4 deadline by more than 560 days, far beyond the 270-day grace period established by the SEC, causing their right to recover those costs from industry participants to be reduced to zero under the framework intentionally adopted by the Commission.

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 the Commodity Futures Trading Commission’s (CFTC) effort to establish a consistent regulatory framework for conflicts arising from affiliations between exchanges and market participants, while arguing that affiliate principal trading creates a uniquely structural conflict of interest. PTG’s preferred approach is a prohibition on principal trading by an exchange affiliate because the exchange has an inherent economic interest in its affiliate’s trading that cannot be fully addressed through disclosure, information barriers, or governance controls. If the Commission retains an exception for affiliated market makers, PTG recommends significantly stronger safeguards, including quantitative market-making requirements, equal incentives for unaffiliated firms, order-priority subordination, independent oversight, point-of-transaction disclosure, and phased limits on affiliate trading. PTG also recommends excluding affiliated market makers entirely from request-for-quote, auction, combination, and package markets, where traditional order-priority protections are less effective.

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 submitted to the U.S. Securities and Exchange Commission (SEC) today, PTG urges the SEC to remove Condition No. 4 of its 2013 no-action relief, which prevents foreign options markets from providing direct electronic access to U.S.-based qualified institutional buyers (QIBs). PTG supports Eurex Deutschland’s request to eliminate this restriction while retaining the other investor-protection conditions and adding oversight requirements modeled on the Commodity Futures Trading Commission’s (CFTC) foreign-board-of-trade framework. PTG argues that the existing restriction creates unnecessary barriers for sophisticated U.S. market participants without providing meaningful additional protection to retail investors.