PTG Comments on MEMX Application for Temporary Exemptive Relief

The letter emphasizes that Regulation NMS Rules 610, 611, and 612 function as an interdependent framework: Rule 612 governs valid quoting increments, Rule 610 addresses fair access to those quotations (including access fees), and Rule 611 (the Order Protection Rule) governs the protection of best-priced quotations across venues. PTG argues that moving forward with the scheduled changes to Rules 610 and 612 without resolving the SEC’s ongoing review of Rule 611 could create regulatory misalignment and unnecessary operational complexity, especially if Rule 611 is later amended or rescinded—changes that would likely require corresponding adjustments to fee and tick-size regimes.

PTG also notes that other major market-structure initiatives are still in progress—such as industry planning for potential 23x5 trading and the ongoing implementation of enhanced Rule 605 execution quality reporting. Given these overlapping workstreams and resource demands, PTG urges the SEC to align timing across related initiatives and adopt a coordinated, holistic implementation schedule for equity market structure changes.