PTG Responds to Proposed Changes to Definition of Trading Platform
Oct 5, 2026
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.
PTG’s central argument is that single-dealer platforms are fundamentally different from the multilateral venues currently covered by the definition, namely registered exchanges, alternative trading systems, and electronic communications networks. Those venues bring together orders from multiple, generally unaffiliated participants and match them according to established rules. By contrast, on a single-dealer platform, a dealer receives a customer order and decides whether to execute against its own book. PTG therefore contends that such a platform is neither an “order matching” venue under the plain language of the proposal nor sufficiently similar to the multilateral venues specifically enumerated in the definition. PTG also questions why the Exchanges expressly identify single-dealer platforms while remaining silent about other bilateral trading arrangements, warning that the resulting ambiguity could permit inconsistent or discriminatory application of fees.
PTG recommends that the SEC summarily suspend the proposals and require the Exchanges to revise the catch-all so that it applies only to multilateral venues that match orders of multiple, unaffiliated participants. The letter further recommends removing the reference to single-dealer platforms. If the Exchanges believe single-dealer platforms or other bilateral arrangements should pay Trading Platform-level fees, PTG argues that they should establish a separate, clearly defined fee category with its own justification and apply it consistently to similarly situated arrangements. More broadly, PTG asks the Commission not to permit a definition with significant fee consequences to remain effective until its scope and application are clear.