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There has never been a better time to be an investor. U.S. equity market structure is highly competitive and retail investors, in particular, enjoy the greatest access, best execution quality and lowest cost to investing that they have ever experienced.
 

On December 14, 2022, the SEC issued four proposals to completely rewrite the regulations governing the structure of our equity markets, including how orders are priced, executed and displayed to the public. Taken together, they total over 1,600 pages of proposed rulemaking. What is lacking, in our view, is any evidence of market failure that would necessitate the wholesale revamping of the U.S. equity markets.

Investor protection is an essential consideration. Any changes should be subject to a robust cost-benefit analysis, and considered holistically with a view to ensuring there are no negative, unintended consequences for investors. Instead of rushing to finalize all four rules at the same time, the SEC should first update Rule 605 to obtain the baseline data needed to accurately assess market quality. Then, after analyzing the new data, determine whether more rulemaking is needed.

SIFMA has long called for a review of equity market structure. We continue to be engaged on these issues to ensure we meet the shared goal of regulators and market participants: to promote market resiliency and ensure the U.S. equity markets continue to benefit investors and play a vital role in capital formation.