By Ellen Greene, Managing Director, Equity and Options Market Structure, SIFMA
On Wednesday, April 19, SIFMA will host a second Equity Market Structure Roundtable to discuss the four released by the U.S. Securities and Exchange Commission:
- Disclosure of Order Execution Information;
- Tick Sizes, Access Fees, and Transparency of Better Priced Orders;
- Regulation Best Execution; and
- Enhancing Order Competition.
At SIFMA, we strive to foster meaningful, substantive discussions that support effective and resilient capital markets. To provide a forum for robust discussion on these far-reaching proposals, SIFMA’s Roundtable will convene representatives from the buy-side, sell-side, exchanges, academics and other interested parties to holistically examine the impact on investors and equity market structure.
A fireside chat with the SEC’s Jessica Wachter and Vanderbilt University’s Craig Lewis will open the Roundtable on April 19 at 10:00 a.m. ET. Our program continues with discussions that outline the SEC proposals and make arguments for why Rule 605 should come first; tick sizes and tick-constrained stocks, access fees and transparency of better-priced orders; the Regulation Best Execution proposal; and the Order Competition proposal.
Our Roundtable includes views from a diverse group of speakers including:
- Ashley Banfield, Co-Head, US Sector Trading, Fidelity Investments
- Robert Battalio, Professor of Finance, University of Notre Dame
- Gregg E. Berman, Ph.D., Director of Market Analytics & Regulatory Structure, Citadel Securities
- Matt Billings, Senior Vice President, Trading Services, Two Sigma
- Michael Blaugrund, CFA, Chief Operating Officer, NYSE
- Stephen Cavoli, Executive Vice President, Global Head of Execution Services, Virtu Financial
- Diwa Cody, Vice President, Head Equities Market Structure and Strategic Partnerships, Goldman Sachs
- Michael Costley, Vice President, Equity, Option & Advisory Trading, Ameriprise
- Jessica D’Alton, Executive Director, Head of America’s Market Structure and Liquidity Strategy, UBS
- Hubert DeJesus, Global Head of Electronic Trading & Market Structure, BlackRock
- Dan Gallagher, Chief Legal Officer, Robinhood; Former SEC Commissioner
- Alan Goldberg, Associate Director, Susquehanna
- Christopher Gwozdz, Head of Order Flow Management, Fidelity Capital Markets, Fidelity Institutional
- Terrence Hendershott, Professor & Faculty Director, Haas School of Business, UC Berkeley
- Adam Inzirillo, Head of US Equities, Cboe Global Markets
- C. Annette Kelton, Senior Counsel & Co-Head of Equities, Goldman Sachs
- JJ Kinahan, CEO of IG North America, tastytrade
- Mehmet Kinak, Global Head of Systematic Trading & Market Structure, T. Rowe Price
- Chris Larkin, Managing Director, Digital Brokerage Product E*TRADE, Morgan Stanley
- Nicholas Losurdo, Partner, Goodwin Procter LLP
- Chuck Mack, Head of US Equities, Nasdaq
- James Martielli, CFA, CAIA, Head of Investment & Trading Services, Vanguard
- Michael Masone, Director, Head of Americas Equities Market Structure, Citigroup
- Rick McDonald, Director of Compliance, Susquehanna
- Joe Mecane, Head of Execution Services, Citadel Securities
- Ovidio Montemayor, Managing Director, Financial Markets Services, Charles Schwab | TD Ameritrade
- Sapna C. Patel, Head of Americas Market Structure & Liquidity Strategy, Morgan Stanley
- Elad L. Roisman, Partner, Cravath, Swaine & Moore LLP; Former SEC Commissioner
- Charles A. Sommers, Partner, Securities Enforcement and Regulatory Practice, Sidley
- Chester Spatt, Professor of Finance, Carnegie Mellon University
- Debbie Toennies, Managing Director, Head of Regulatory Affairs, JPMorgan Chase & Co.
- Andrew Upward, ETF Strategist, Jane Street
Representing the views of our broker-dealer, investment bank and asset management members, SIFMA has filed three comment letters with the SEC. Individually and together, SIFMA believes the proposals raise serious concerns that would result in fundamental changes with uncertain and consequential results. As a baseline matter, the SEC failed to identify any market failure that would justify these dramatic structural changes. They also failed to provide an analysis of their cumulative and interactive effects.
Our views are supported by independent academic research, which challenges the SEC’s asserted benefits, and in fact not only underscores the competitive nature of our current equity market structure but identifies substantive costs to investors that could result from these proposals.
We believe a more prudent course would be for the SEC to adopt proposed changes to Reg NMS Rule 605, which SIFMA and our Asset Management Group support with suggested recommendations. As a starting point, that would provide better baseline data to inform the SEC and stakeholders to consider what, if any, structural changes may be necessary.
Participation in the Roundtable is complimentary and open to all. We hope that you will virtually join us for what promises to be a crucial discussion. Pre-registration is required and closes at 12:00 p.m. ET on Tuesday, April 18. To join us, register here.
