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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 Commodity Futures Trading Commission (CFTC), PTG supports allowing standard energy futures contracts to trade on a continuous 24/7 basis and supports the development of perpetual energy contracts under the CFTC’s regulatory framework. The letter argues that demand for around-the-clock energy risk management already exists and that much of this activity is occurring on offshore venues that lack the safeguards of regulated U.S. markets. PTG contends that bringing continuous trading onshore would enhance liquidity, improve price discovery, strengthen customer protections, and provide market participants with regulated tools to manage energy risks that arise overnight and on weekends.

In a letter filed today with both the Securities Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) PTG supports the Commissions’ efforts to clarify the distinction between swaps and security-based swaps and encourages the agencies to adopt clear, principles-based standards that can be applied consistently across products. PTG argues that regulatory classifications should reflect the actual risks and consequences associated with a product, rather than relying solely on its form.

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 with the Commodity Futures Trading Commission (CFTC) today, PTG supports the CFTC’s proposed framework for evaluating prediction market event contracts and commends the Commission for adopting a design-first, factor-based approach centered on manipulation resistance, objective settlement criteria, and market integrity. PTG agrees that prediction markets can serve important functions in information aggregation, price discovery, and risk transfer when they are built on transparent governance, reliable settlement processes, fair access to information, and appropriate regulatory oversight. The letter also supports the Commission’s preliminary conclusion that contracts based on aggregate outcomes—such as game results, tournament advancement, and statistical performance—are generally consistent with the public interest because they are less susceptible to manipulation and better support competitive liquidity and efficient pricing.