The World Federation of Exchanges welcomes the opportunity to respond to the Commission’s consultation on such an important topic. We welcome a review of Rule 611 (the trade-through rule) as we consider it a valuable exercise, particularly given how far markets have evolved since the creation of 611.
Rule 611 is deeply embedded within the broader U.S. market structure framework. Market participants have spent nearly twenty years designing systems, order routing practices, compliance processes, and, above all, commercial arrangements around the requirements of the Trade-Through Rule. As a result, its removal should not be viewed as a simple deregulatory measure. Rather, it would represent a significant structural change that would create a fundamentally different market environment from the one that exists today.
For this reason, the merits of rescinding Rule 611 should not be considered in isolation. The case for removing the Trade-Through Rule is compelling only if accompanied by a broader review of the regulatory framework.
Source: WFE
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