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In a letter filed today, PTG supports FINRA’s preliminary conclusion that Rule 5310’s principles-based best execution framework remains sound, but argues that the related guidance should be modernized, particularly if the SEC rescinds Regulation NMS Rules 611 and 610(e). Because those changes could significantly affect venue connectivity, order routing, displayed quotations, and the role of the NBBO, PTG urges FINRA to coordinate closely with the SEC and solicit public comment before adopting materially revised guidance. PTG also recommends an ongoing best-practices program featuring periodic thematic reviews, anonymized examples of effective and problematic conduct, and recurring industry consultation.

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.

In a letter filed today with the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), PTG urges the Commissions to preserve and strengthen transparency in the U.S. swaps markets as they review swap and security-based swap data reporting requirements. PTG argues that broad and timely public access to transaction and pricing information enhances market efficiency, competition, liquidity, and price discovery while reducing information asymmetries among market participants. The letter emphasizes that the transparency gains achieved through the CFTC’s real-time reporting framework have benefited market participants and should remain a cornerstone of derivatives market regulation.

In a letter filed today with the Securities and Exchange Commission (SEC), PTG expresses qualified support for Cboe Clear U.S. (CCUS) receiving temporary registration as a clearing agency for Binary KPI Options, but strongly opposes any effort to make that registration permanent. PTG views CCUS as a short-term solution that can help bring innovative products to market while the Options Clearing Corporation (OCC) develops the capability to clear them. The letter argues that OCC remains the appropriate long-term clearing venue and notes that OCC has already established a framework for clearing binary options, making a permanent alternative clearing structure unnecessary.

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.