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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.

In a letter filed today with the Securities and Exchange Commission, PTG expresses support for Nasdaq’s proposed rule change establishing a new continued listing requirement for companies whose market capitalization falls below $5 million. PTG agrees with Nasdaq’s view that such low valuations generally reflect more than temporary challenges and make continued listing on a national securities exchange inappropriate.

In the brief, filed today, PTG contends that the Securities and Exchange Commission’s (SEC) 2026 CAT funding order (the Order) should be set aside for three main reasons.

In a letter filed with the Securities and Exchange Commission (SEC) today, PTG supports FINRA’s proposal to expand the affiliate–principal transaction indicator so it also covers qualifying trades between member affiliates, arguing this is consistent with existing treatment of similar non-member affiliate trades.