PTG Supports Eurex Request to Allow Direct Access to Foreign Equity and Equity Options Markets
Sep 23, 2026
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.
PTG explains that the current framework imposes significant risk-management, operational, and competitive costs on U.S. QIBs. Because firms generally must access Eurex-listed equity and equity-index options through non-U.S. affiliates operating during European business hours, they may be unable to hedge positions after approximately 1:00 p.m. Eastern, even as U.S. markets continue trading. The restriction also requires duplicative overseas infrastructure and capital, limits U.S. firms’ ability to provide liquidity, and places them at a disadvantage relative to non-U.S. competitors. PTG contends that permitting direct access would improve market efficiency and risk management while advancing the SEC and CFTC’s broader goal of regulatory harmonization.
Finally, PTG argues that recent changes in European regulation have widened the competitive imbalance. Germany now permits U.S. exchanges to provide direct access to German market participants without the prior licensing regime, while European venues remain prohibited from offering comparable direct access to U.S. QIBs. PTG therefore characterizes the requested relief as a targeted modernization that would enhance U.S. competitiveness and market liquidity while preserving the existing safeguards limiting participation to sophisticated institutional investors and eligible foreign options.