| The Administrator function will be delivered by DataCT, a new independent affiliate of DataBP, under the direction of the CT Plan Operating Committee |
| New York, NY – December 17, 2025 — DataBP, LLC today announced that DataCT has been selected by the Operating Committee of the Consolidated Tape Plan (CT Plan) to serve as its Independent Administrator, pending the outcome of negotiations. The new CT Plan, which is expected to launch in early 2027, will be the unified successor to the three existing consolidated equity market data plans for Tape A, Tape B and Tape C securities in the U.S. In accordance with the CT Plan’s independence requirements, the Administrator function will be delivered through DataBP’s new independent affiliate, DataCT LLC; established specifically to operate the CT Plan Administrator role. DataCT is structured with its own governance, management, controls, and accountability, and operates independently under the direction and oversight of the CT Plan Operating Committee. The appointment follows a competitive selection process conducted pursuant to the Securities and Exchange Commission’s (SEC) approval of the CT Plan. During the transition period, Mark Schaedel, Chief Executive Officer of DataBP, will serve as Acting Chief Executive Officer of DataCT, providing executive continuity and oversight as DataCT completes staffing and operational readiness. This role is transitional and supports the planned handover to a permanent DataCT Chief Administrative Officer in line with CT Plan governance requirements. To support a disciplined transition and ongoing operational resilience, DataCT has entered into a services arrangement with Deloitte, under which Deloitte will support the transition program and provide ongoing shared services. Deloitte acts solely in a service-provider capacity and does not participate in CT Plan governance, policy-setting, or administrative decision-making. Through DataCT, the Independent Administrator will be responsible for subscriber onboarding and account management, licensing administration, usage reporting, billing and collections, audit and compliance oversight, revenue allocation administration, public and subscriber communications, and coordination with the Securities Information Processors (SIPs). While SIP processing functions will remain with the existing processors, the new Independent Administrator will be responsible for managing the transition from the current CTA/CQ and UTP Plan Administrators, which are expected to be retired following CT Plan’s go-live. “This appointment reflects the need for an administrator with deep operational experience and the ability to execute a complex transition without disruption to the market,” said Mark Schaedel, CEO of DataBP and Acting CEO of DataCT. “DataCT was established to provide a neutral, purpose-built administrative vehicle, combining independence, operational rigor, and modernized infrastructure, while remaining fully accountable to the Operating Committee.” The transition to the new unified CT Plan Administrator will proceed in defined phases, with full operational cutover occurring in accordance with the SEC-approved CT Plan timeline. -ENDS- About DataBP DataBP, LLC is a provider of market data administration technology and services supporting exchanges, index providers, and regulated market utilities. DataBP delivers infrastructure and operational expertise across licensing, billing, compliance, and governance for complex market data ecosystems. About DataCT DataCT LLC is an independent affiliate of DataBP established to administer regulated market data plans and utilities, including the U.S. Consolidated Tape Plan. DataCT operates with dedicated governance, management, and controls to meet strict independence, transparency, and regulatory requirements. |
DataCT Selected as Independent Administrator of the U.S. Consolidated Tape Plan
Trading Technologies Adds Margin Analytics, Intelligence With OpenGamma Purchase
On Wednesday, December 17, Trading Technologies International, Inc. (TT) expanded its platform by acquiring OpenGamma, a firm specializing in derivatives margin analytics for buy-side and sell-side firms. The integration will combine OpenGamma’s margin and capital management tools with TT’s multi-asset platform, giving traders real-time insights. The combined system will help trading desks act quickly on margin efficiency opportunities, manage risk more effectively, and free up capital to pursue additional trades across global markets. Justin Llewellyn-Jones, CEO of TT, spoke with Traders Magazine about what this acquisition means for traders and how it will change day-to-day trading operations.
How will integrating OpenGamma’s margin analytics into TT’s platform change the way traders manage liquidity risk in real time?
Over the last few years, regulatory changes have focused heavily on counterparty risk, which has driven a significant increase in initial margin requirements. Traditionally, margin optimization happens in treasury or collateral teams after trades have been executed. Those recommendations are then passed to traders or operations teams to act on. But the longer it takes to act, the less valuable the recommendation becomes because the market environment is constantly changing.
With OpenGamma integrated into our trading platform, those recommendations will appear directly in front of the trader the moment they’re generated. This immediacy is key. Traders can act right away, freeing up margin and reducing the cost of capital, while operations teams can execute position transfers faster. The benefits are twofold: it lowers the cost of trading and, at the same time, frees up capital, allowing traders to trade more. It’s about giving traders actionable intelligence in real time, rather than letting valuable insights sit idle in a back office system.
How will the combined platform improve day-to-day trading for buy-side and sell-side clients?
It really comes down to efficiency and visibility. When trading desks hit limits on margin or capital allocation it prevents them from participating in the markets. By bringing OpenGamma’s analytics into the trading platform, traders can get immediate visibility into how much margin has been posted, freed up, or is available.
This real-time data will allow them to manage risk more accurately and continue trading without unnecessary delays. It’s similar to how traders monitor clearing status today. Once they know a trade has cleared, they can move on. With margin insights integrated, traders gain the same real-time awareness for capital utilization. This translates into faster decisions, smoother operations, and the ability to trade more effectively across multiple asset classes.
Beyond margin optimization, what new workflows will traders be able to use?
The integration opens up opportunities both on the trading desk and in clearing workflows. Sometimes the key action isn’t placing a new trade but transferring an existing position efficiently. By surfacing OpenGamma’s recommendations in real time, traders can act on margin optimization, and operations teams can execute position transfers seamlessly.
OpenGamma already supports over 100 different margin models across many different CCPs and brokers. Combining that capability with TT’s distribution allows us to explore interesting reconciliations paradigms, and also allows us to consider extending into areas such as collateral and cash management tools, reducing the need for traders and operations teams to switch between multiple systems. TT’s focus has always been about creating a more cohesive end-to-end workflow, from trade execution, through allocation and clearing, and now we can include margin management so desks can operate more efficiently and with greater clarity.
What new tools will traders have across different asset classes?
Initially, traders will see alerts and notifications for actionable margin recommendations directly in the trading platform. These recommendations provide guidance on trades, position transfers, and capital allocation. Over time, we could automate this workflow further by creating ‘memo orders’ that traders can act on directly by pre-populating the order tickets with the required information.
This approach moves us toward an exceptions-based workflow, where traders intervene only when necessary, rather than monitoring everything manually. It will apply across asset classes – from commodities and energy to financials and fixed income – and provide a unified view of capital and margin utilization, giving traders confidence to act quickly and efficiently no matter what they’re trading.
How does OpenGamma enhance counterparty risk management?
One of the biggest challenges for banks is ensuring the correct, optimized level of margin is posted by their clients. OpenGamma sits across buy-side, sell-side, and central counterparties (CCPs), so it can provide a single, consistent view of margin for all parties. This creates a kind of ‘golden source’ of data.
Traders and operations teams benefit because everyone is working off the same numbers, reducing reconciliation issues and giving a clearer picture of exposures in real time. This visibility is critical, especially in periods of market stress or rapid change, when margin and counterparty risk need to be monitored closely. It helps traders make informed decisions while maintaining safeguards around risk.
With TT’s global reach, how will traders in different regions benefit?
Through its trading platform TT provides access to more than 100 global exchanges and venues, while OpenGamma has a strong presence in Europe and growing coverage in the Americas, with limited exposure in APAC. By combining our distribution, OpenGamma can expand its reach, and our clients benefit from a more complete, global picture of margin and capital requirements.
This is especially important as exchanges implement new margin methodology changes. Traders need to adapt, and our combined platform is well positioned to ensure they get those global insights that allow them to do just that. Beyond geography, it’s also about keeping pace with market innovation—shorter settlement cycles, new trading hours, and the increasing need for intraday visibility. These are all areas where TT and OpenGamma together can provide solutions. Our goal is to ensure that traders anywhere can act with the same speed, clarity, and confidence.
Outlook 2026: Jim Kaye, FIX Trading Community
Jim Kaye is Executive Director, FIX Trading Community.
What was the highlight of 2025?
FIX was, as always, busy on many fronts around the world in 2025, but one area that brought a long-term piece of work to fruition was the publication of our recommended practices for the European Consolidated Tape.
The new recommended practices were the result of years of work with hundreds of industry participants. For years we have been working toward the launch of the consolidated tape, knowing it would an ideal moment to correct some systemic issues that have been dragging on European markets for decades. This publication of these marks the culmination of a huge cooperative effort and I’m very proud of the work that so many people have done to bring us to this point.
FIX also published a whitepaper outlining the broader issues that should be solved by the European consolidated tape: FIXing Europe – How the European Consolidated Tape can radically improve the image of European capital markets, in October.
What trends are getting underway that people may not know about but will be important?
FIX has established a workstream on AI Governance, to interrogate the issues that are likely to arise from the use of AI in trading and establish a neutral territory where firms can come together to address these for the benefit of the entire industry.
AI brings many opportunities but there are pitfalls that we have identified at this early stage – and there will be many more. The undocumented nature of an AI training itself is an obvious one – where things go awry there is not the documentation trail we would expect from a traditional tech implementation. It’s clear to us as a community that we need to manage this very carefully from a governance perspective to ensure we can keep our markets orderly.
This concern is illustrated in Singapore, where the Monetary Authority of Singapore has launched a consultation paper, closing in January, on Proposed Guidelines on Artificial Intelligence Risk Management for Financial Institutions. FIX is responding to this consultation together with a range of member firms.
What are your clients’ pain points and how have they changed from 1 year ago?
A significant pain point for firms trading bonds, while not new and probably not significantly changed from a year ago, is the issue of axes – a traders’ indication of interest in buying or selling a security. FIX is working with the International Capital Market Association (ICMA) on this issue.
The growing prevalence of electronic trading in fixed income platforms has heightened demand for axes, however this had also led to a reduction in quality. As a result, axes have become less effective for price discovery and more difficult to trade, according to some buyside traders. Solving this issue would better support best execution.
Both buy- and sell sides had experienced frustrations with axes, which are an important part of bond trading, in an increasingly electronic world.
This is not a new issue but it’s one that has irritated both sides for years. FIX is ideally placed as a neutral, independent space for all members of the bond trading community to come together to sort this out and improve the bond trading experience for everyone.
Mike Poole from Jupiter Asset Management said for the buy-side, axes were crucial for understanding liquidity. “I’m confident this initiative will identify how we can improve data standards in ways that are practical for both sides,” he said. “By doing so, we’ll be able to improve execution outcomes which will benefit the entire market.”
Optimizing the Trade Lifecycle: The Key to AI and Regulatory Readiness in 2026
By Michiel Verhoeven, CEO, Xceptor
Big picture
In 2026, capital markets firms will face continued regulatory pressure, operational complexity, and the need to keep pace with rapid technological change while demonstrating ROI. As a result, we expect a shift away from simple cost-cutting, tech for tech’s sake, and quick compliance fixes. The focus should be on value creation and futureproofing, with data placed at the heart of everything.
Before investing in new AI or compliance projects, institutions must first go back to basics. It’s about ensuring secure, validated, and trusted data and optimising the entire trade lifecycle – from pre-trade to post-trade settlement, plus trace to origin. By automating the process for data standardisation, firms will accelerate readiness, reduce errors, and streamline workflows.
Adapting to regulatory change
Regulatory demands across the trade lifecycle will only get tougher.
Pre-trade, firms must ensure compliance before execution. Enhanced market data analytics and real-time risk controls are critical for best execution and effective surveillance under regulations like MiFID II and MAR.
Post-trade, the shift to T+1 settlement cycles is magnifying inefficiencies. Issues that once took two days to fix must now be resolved in one. Automation, exception handling, and adaptive rule engines are essential to avoid settlement fails and penalties, while reconciliation and reporting must be digitised and auditable for transparency across the custody chain. With the FCA’s warning about readiness for Europe’s T+1 deadline (11th October 2027), and lessons learned from the US transition, firms must not delay action.
Tax reporting is also being digitised under mandates like Germany’s MiKaDiv (1st January 2027) and the EU’s FASTER Directive (1st January 2030). Manual processes will be a huge barrier. Firms must assess their data models, reporting gaps, and custody chain transparency, then automate their tax reporting and compliance processes. This will reduce manual effort and risk, while ensuring readiness for these timelines.
Delivering measurable outcomes with AI
In 2026, AI adoption will continue to dominate headlines. Yet, without a clear strategy, institutions risk creating a money pit. Firms should ask themselves: “what are our pain points and how can we achieve the necessary outcomes with AI?”. Without the right infrastructure, data management, and clarity of purpose, technology is not a magic fix.
For example, AI can drastically reduce time spent extracting information from complex tax documents, and agentic AI could augment productivity further by proactively solving problems and triggering downstream actions. But without addressing inconsistent data formats, firms will face more errors and time spent correcting them, or even financial and non-compliance risks. Issues with data reliability, quality, and flow are common causes of failed AI projects – flawed data creates flawed AI. Firms must invest in platforms that normalise, enrich, and validate data across fragmented systems before scaling AI projects.
Partnering for success
Optimising the trade lifecycle is about more than compliance – it’s about unlocking operational efficiency, reducing risk, and delivering superior client outcomes. Success in 2026 will depend on the right partnerships. Capital markets firms need technology partners with extensive industry expertise, robust capabilities, and a focus on solving real problems. In an industry with little margin for error, data automation must come with effective monitoring, visibility, and transparency. Firms will prioritise cloud-first, SaaS-ready platforms that improve data quality, reduce risk, and scale operations for the future.
Trading Technologies Acquires OpenGamma, Leader in Margin and Capital Optimization Analytics
CHICAGO / LONDON, Dec. 17, 2025 – Trading Technologies International, Inc. (TT), a global capital markets technology platform services provider, today announced it has acquired OpenGamma, a market leader in derivatives margin analytics for buy-side and sell-side clients. Terms of the transaction were not disclosed.
The integration of OpenGamma’s sophisticated margin optimization and capital efficiency tools directly into the TT platform will allow for automated trading and position transfer workflows that reduce risk and increase efficiency and will significantly enhance TT’s multi-asset platform.
Justin Llewellyn-Jones, CEO of TT, said: “The acquisition of OpenGamma is a transformative step that immediately deepens the value proposition we will offer our combined customer base. Global derivatives markets have undergone profound structural changes in recent years, particularly in the realm of margin requirements, resulting in an acute need to manage margin-driven liquidity risk without weakening safeguards around counterparty risk. OpenGamma’s real-time insights empower firms to maximize leverage and free up precious capital. This is a crucial strategic addition that aligns perfectly with our mission to provide the best multi-asset platform experience across the entire trade life cycle.”
Peter Rippon, CEO of OpenGamma, said: “Joining forces with Trading Technologies provides us with a massive opportunity to accelerate our growth. Leveraging TT’s scaled go-to-market and distribution capabilities will unlock new opportunities for the OpenGamma platform across the Americas, Europe, the Middle East and Asia-Pacific regions. Our team is excited to integrate our leading analytics into the TT platform, bringing new capital efficiencies to a much broader audience. I would like to thank the OpenGamma team and our investors for their unwavering commitment and support over the last 10 years.”
OpenGamma’s platform boasts a significant footprint, with top-tier clients across hedge funds, commodities trading firms and sell-side banks. TT will leverage OpenGamma’s strong client relationships to accelerate its opportunities in the hedge fund and energy sectors, while TT’s extensive network will provide OpenGamma with access to a larger pool of sell-side bank clients.
The TT platform handled more than 2.9 billion derivatives transactions so far in 2025. Through its Execution Management System (EMS), TT provides access to more than 100 global exchanges and venues for cross-asset trading. Through TT’s Order Management System (OMS), firms can accept, manage and execute orders and conduct post-trade confirmations and allocations. The expansion of the platform to deliver multi-asset functionality enables clients to utilize sophisticated order and execution management tools in the E/OMS for high-, low- and no-touch workflows across their global trading operations in each of the asset classes. TT’s open architecture allows users to integrate their systems with TT to access their own market connections, private liquidity or execution algorithms and import data from external sources enterprise-wide.
Houlihan Lokey served as exclusive financial advisor and Gunderson Dettmer as legal advisor to OpenGamma. Goodwin Procter served as legal advisor to Trading Technologies, Thoma Bravo and 7RIDGE.
About Trading Technologies
Trading Technologies (www.tradingtechnologies.com) is a global capital markets platform services company providing market-leading technology for the end-to-end trading operations of Tier 1 banks, brokerages, money managers, hedge funds, proprietary traders, Commodity Trading Advisors (CTAs), commercial hedgers and risk managers. With its roots in listed derivatives, the Software-as-a-Service (SaaS) company delivers “multi-X” solutions, with “X” representing asset classes, functions, workflows and geographies. This multi-X approach features trade execution services across futures and options, fixed income, foreign exchange (FX) and cryptocurrencies augmented by solutions for data and analytics, including transaction cost analysis (TCA); quantitative trading; compliance and trade surveillance; clearing and post-trade allocation; and infrastructure services. The award-winning TT platform ecosystem also helps exchanges deliver innovative solutions to their market participants, and technology companies to distribute their complementary offerings to Trading Technologies’ clients.
About OpenGamma
OpenGamma is a derivatives analytics firm with unparalleled expertise in over-the-counter (OTC) and exchange-traded derivatives (ETD) and prime broker margin methodologies. Its teams bring together a unique mix of practitioner, quantitative and software engineering expertise. Today, OpenGamma is trusted by the largest and most sophisticated global banks and fund managers, with thousands of users depending on its analytics. OpenGamma has been backed by Accel, CME Ventures, Dawn Capital, Allianz X and Cristóbal Conde.
Media Contacts:
For Trading Technologies:
Ellen G. Resnick
Crystal Clear Communications
+1 312-399-9295
Elise Fleischaker
Trading Technologies
+1 312-476-1139
Outlook 2026: Stephen Callahan, Firstrade
Stephen Callahan is Trading Behavior Specialist at Firstrade.
What was the highlight of 2025?
One of the standout highlights of 2025 was the launch of our Invest 3.0 platform. It marked a major step forward in making trading faster, smarter, and more intuitive for our clients. Beyond just technical upgrades, Invest 3.0 reflected our commitment to understanding what traders really need, like tools that help them act confidently, analyze markets efficiently, and manage their portfolios seamlessly. Seeing our clients actively adopt these tools and provide feedback has been incredibly rewarding, and it sets a strong foundation for continued innovation. We’re looking forward to continuing this momentum in 2026 as we continue meeting traders where they are in their investment journey.
What are your expectations for 2026?
Looking ahead to 2026, we anticipate a continued acceleration in the adoption of digital trading solutions and smarter investment tools. Traders are far more advanced than in years past and are searching for a series of tools that analyze markets from all angles. Our focus will be on providing clients with advanced functionality while keeping the platform simple and accessible so they can navigate their investment strategies efficiently. We expect trends like personalized trading insights and enhanced portfolio management tools to become more mainstream. At the same time, education and guidance will remain central for us at Firstrade as we continue helping clients navigate markets with confidence even as technology and market conditions evolve.
What trends are getting underway that people may not know about but will be important?
There are a few emerging trends we’re closely watching. First, micro-products and smaller, more digestible investment options are gaining traction, making trading accessible to new audiences. Second, AI and data-driven insights are starting to play a bigger role, not just for professional traders, but for retail investors who want actionable recommendations without being overwhelmed. Finally, we’re seeing a push for more transparency and real-time analytics, giving traders the tools to respond quickly to market shifts. These trends may feel subtle now, but over the next year they will likely reshape how people approach trading. We stand ready to meet traders where they are and supply them with cutting edge tools so they can approach markets how they see fit.
What are your clients’ pain points and how have they changed from 1 year ago?
Over the past year, we’ve noticed a shift in what our clients are looking for. Previously, speed and usability were the top priorities. Clients wanted faster order execution and simpler interfaces. Today, expectations have evolved toward more personalized insights, smarter tools for managing risk, and seamless integration across devices and account types. Clients want a platform that not only executes trades efficiently but also helps them make informed decisions, anticipate trends, and adapt quickly to changing market conditions. That’s why we’re making this a major focus in 2026 at Firstrade. We only expect this trend to continue.
How will AI impact the trading industry next year?
AI is set to be a game-changer in trading over the next year. We’re starting to see it used to analyze vast amounts of market data, identify trends, and provide predictive insights that were previously only available to institutional traders. For retail clients, this means more personalized recommendations, automated research tools, and smarter alerts that save time and reduce guesswork. AI won’t replace human decision-making, but it will make trading faster, more informed, and more efficient, helping investors of all experience levels feel more confident in their choices.
Regional Banks Contend with OTC Derivatives
The vast majority — more than 97% — of derivative holdings and trading activity in the US banking community is concentrated among a small group of large, global systemically important banks (G-SIBs). While this has long raised concerns over systemic risk and interconnectedness, the 2023 banking crisis in the US was triggered by the collapse of small regional players Signature Bank and Silicon Valley Bank.
Both were impacted by rapid interest rate hikes as well as significant deposit withdrawals which exposed vulnerabilities in their balance sheets, including derivatives exposure and risk management practices. It also emphasised the complexities in unwinding derivative contracts and prompted several industry discussions on liquidity, interest rate risk, and regulatory oversight for banks dealing with complex financial instruments like interest rate swaps.
Fast forward to today, lessons has been learnt and more robust frameworks are in place, but navigating derivatives markets is still complicated for regional banks. This is especially the case given the turbulence over the last few years. There have not only been ongoing geopolitical tensions and shifting macroeconomic dynamics, but more recently President Trump’s vacillating tariff policies.
As Isaac Wheeler, managing director of balance sheet strategy at Derivative Path notes, the last few years have seen several volatility events in rates markets, all of which highlighted the importance of hedging to regional and community banks. He points out that unlike typical swap market participants, these smaller players conduct the majority of their hedging activities with bilateral OTC derivatives.
The challenges, according to Wheeler, is that in contrast to their larger peers, regionals do not typically have dedicated groups to manage rate risk. Hedge modelling, strategy development, and execution often falls to individuals juggling liquidity, capital, and risk management simultaneously. “For hedging to happen, institutions need to see it as a top priority above other competing demand. Volatility has done a lot to clarify that prioritisation,” he adds.
He points out that there has been a marked increase in hedge adoption among regional and community banks as a result. “Mentions of hedging strategies on earnings calls have increased 4x over the last five years, and institutions have become more sophisticated in their hedging practices,” he says. “Many have migrated from large one-time transactions to the ongoing programmatic approaches of their larger peers.”
Smaller banks are also having to deal with legacy systems which unsurprisingly has given rise to banks outsourcing various OTC functions to better manage costs, access specialised technology, and meet regulatory requirements. The most recent example is Frost Bank turning to Derivative Path’s platform for managing its OTC derivatives business, with an initial focus on commodities and interest rates.
However, larger banks can face the same issues with outdated technology and despite the deeper pockets it can be easier to hand over parts of the business as HSBC UK did to Delta Capita earlier in the year in a multi-year post-trade OTC derivative agreement.
Why Platforms Will Drive the World’s Fastest Markets
By Anthony Amicangioli, Founder and CEO, HPR
The universe of high-performance capital markets infrastructure is highly fragmented today, with many trading stacks built on stitched-together legacy software. Typically assembled from a combination of in-house and outsourced solutions with a mash-up of programming languages and design philosophies, these stacks can struggle with spotty performance, difficult upgrades, and uncertain interoperability.
Based on decades of experience as a founder, capital markets CTO, and designer of high-performance networking systems, my conclusion is that these challenges can be solved by providers willing to adopt a comprehensive, true platform—built through a hyper-unified approach to development.
For market participants looking to address critical needs like pre-trade risk, enterprise trading risk, market access, high-speed market data delivery and consumption, or matching engine technology, a platform-as-a-service solution seamlessly integrates and unifies all solutions across these firms and product sets.
This is the approach we have taken since I launched HPR in 2011. Through rigorous engineering discipline, it can deliver unmatched reliability, scalability, and performance in all areas of trading infrastructure.
Advantages of a True Platform
The use of unified platforms in the development and deployment of complex solutions has proved successful across a number of major industries, including technology, healthcare and telecommunications. It offers advantages that ultimately result in greater power and efficiency for users.
Platforms can dramatically speed up the development of new products and features. Working from a singular codebase allows engineers to immediately leverage new capabilities across an entire product suite. Code can be reused extensively, reducing bugs and incompatibilities while promoting greater agility and collaboration across teams. This also makes maintenance and upgrades far simpler, as updates to shared code are deployed in one stroke across an entire ecosystem.
Other benefits include a unified and improved client experience, as there is no need to learn different user interfaces or workflows for each application. Data is aggregated across the platform, enabling seamless analysis and insights. Greater scalability and reach are also facilitated, as are systemwide security and compliance.
Google and Amazon, two of the biggest names in technology, are widely regarded as pioneers in the use of platforms. Google’s diverse product suite, which includes search, Gmail, YouTube, Google Maps and Google Cloud, is built mostly on shared infrastructure and unified services. Central to its platform, Google largely maintains a monolithic source-code repository, an increasingly popular approach among leading technology companies.
Early on, Amazon implemented the renowned Bezos API Mandate, which required every team to connect through shared interfaces, breaking down silos, and driving integration at scale. This is often cited as central to Amazon’s ability to scale so dramatically, so quickly. AWS was born out of Amazon’s platform approach.
The Dangers of Fragmented Architectures
In contrast, the trading stacks operated by many capital markets firms today consist of products cobbled together from legacy software and written in multiple programming languages. Legacy software faces multiple downsides that can impact performance, including:
- Inconsistent and error-prone system designs often caused by turnover in the CTO seat and M&A activity
- Slower lead time in new feature implementation
- Performance degradation and maintenance challenges causing undue pressure on engineering resources
- Disparate applications leading to poor interoperability
- Higher integration or upgrade costs driven by stitched-together applications
Any of these issues can interfere with trading activity and be responsible for trading interruptions.
Lessons from a Comprehensive Approach
I have learned a great deal from building, creating, and operating a comprehensive, true platform, and am convinced today more than ever that this is the future of high-performance capital markets infrastructure.
The advantages of a platform approach stem from building on a singular, highly unified codebase that functions as the common language and fabric of the ecosystem. From such a codebase, it is possible to build a comprehensive, centrally controlled suite of applications that work in concert across the high-performance trading universe.
For example, a broker-dealer may need to access a broad range of trading venues as well as enable ultra-low-latency direct market access and gain access to low-latency, deterministic market data. A true platform can easily meet those varied needs. Because these solutions are designed to operate together, many of the friction points commonly experienced in legacy software would be eliminated.
Such an approach allows low latency, throughput, and determinism to be prioritized in a world where nanoseconds matter. Inefficiencies caused by disparate applications don’t exist. It becomes far easier for clients to scale on a true platform, accommodating greater trading volume as well as adding new services and markets. Importantly, new features can be rolled out quickly and uniformly.
In the world of high-performance trading, a true platform stands poised to drive the future of capital markets.
Remarks at the Roundtable on Rule 611 of Regulation NMS
Austin, TX
Dec. 16, 2025
Good morning, ladies and gentlemen. I am pleased to join my fellow Commissioners and Jamie Selway, director of our Division of Trading and Markets, in welcoming you to today’s roundtable. I should also like to acknowledge and thank the University of Austin for providing the setting for today’s program; our esteemed panelists for contributing their perspectives; and our audience, whether here on campus or by livestream, for taking part in this important discussion. Finally, before I share a few reflections, I must add that the views I express this morning are my own as Chairman and do not necessarily reflect those of the SEC as an institution or of the other Commissioners.
As I noted at our September roundtable, the SEC adopted Regulation NMS at a time of profound transformation. Electronic trading systems were continuing to unsettle old assumptions about how markets could function as handling and routing practices became more transparent, competition drove commissions lower, and penny pricing reshaped the mechanics of trading. Rather than meet these disruptions with a measured approach, in 2005 the Commission decided to impose prescriptive rules and dictate very specific processes to address what it perceived as ills—even as these new trends and technologies were still evolving. Worse, the staff came out with repeated rounds of FAQs to ameliorate the challenges that their problematic rules engendered.
While I fully supported then, as I do now, the worthy goal of enhancing market efficiency, then-Commissioner Cynthia Glassman and I objected to Reg NMS’s adoption because we believed that the rigidity of its regime, especially Rule 611, would hinder, rather than enhance, the long-term growth of our markets.
Two decades have given us the benefit of perspective, and the verdict is clear: Reg NMS, built on flawed foundations, has invited gamesmanship and contributed to the fragmentation of our markets, the dispersal of liquidity, and diminished transparency. The very outcomes that we feared have come to pass. Our warnings are now lessons. And Reg NMS—Rule 611’s trade-through prohibitions in particular—command a fresh look so that we can continue to strengthen our securities markets. Indeed, we must summon the courage to acknowledge when well-intended policies have produced unintended consequences.
To this end, our first roundtable engaged an array of industry participants, academics, and regulators in Washington, for a very fruitful initial discussion. Their perspectives, along with the thoughtful comment letters that we have since received, underscore a broad consensus: revisiting Rule 611 is a worthwhile and overdue endeavor. While views may vary on the scope of potential changes, a significant number of panelists and commenters believe that the rule should be modified or rescinded entirely.
In September, we also heard several potential paths forward, including volume thresholds for protected quotes, block exceptions, rescinding the locked and crossed market prohibition, adjustments to access fee caps, and revisions to the market data revenue allocation formula. Each of these proposals merits serious consideration. Yet as I cautioned two decades ago, we must take a careful, deliberative approach to any changes, lest we make the mistakes that brought us here.
So today, we take a necessary next step in that process. Of course, we will continue our discussion of the trade-through prohibitions. But we will also delve more deeply into how Rule 611 intersects with other parts of Reg NMS rules and our market structure more broadly. Specifically, our first panel will focus on Rule 610 and its requirements relating to fair access, access fees, and locked/crossed markets. Our second group of panelists will then discuss Rule 600, including the defined terms intertwined with the trade-through rule, the effects on the NBBO, as well as the incentives associated with the market data formula revenue allocation from the consolidated market data plans. Finally, our third panel will examine potential enhanced best execution guidance if the Commission modifies or rescinds the trade-through prohibitions of Rule 611.
Today’s roundtable will help to ensure that we do not saddle a future Commission—or the next generation of investors and market participants—with the same set of challenges that we left for ourselves two decades ago. We owe it to them to be thoughtful, to be rigorous, and to be reflective. So, I want to thank our panelists and moderators once more for being here. I should also like to encourage members of the public to continue sharing your perspectives through our comment file. As we undertake this reassessment of Reg NMS, your insights are indispensable.
I look forward to today’s discussions and to the takeaways that will emerge from them. Thank you all for being here, and for your continued engagement in the critical work before us.
Trading Technologies’ Year in FX
Trading Technologies has been expanding its SaaS technology platform across capital markets asset classes, including foreign exchange.
Tomo Tokuyama, EVP and Managing Director, FX at Trading Technologies, provided a snapshot of TT’s FX business earlier this year, and last week Traders Magazine caught up with him for a year-end update.
Let’s look back at the year for Trading Technologies’ FX business. One news item was TT FX connecting with EBS and FX Spot+, which was announced in May. What’s the significance?
We connected to EBS Market, EBS Direct, EBS Spot+, and EBS FX Link. And we’ve always had CME FX futures. So I believe we are the only third-party platform that has all CME FX products under one roof, and for folks who want to trade CME products across the board, they can do so under our umbrella.
That’s been quite positive for us. EBS has been a good partner in terms of introducing us to clients who are interested in consolidating. Similar to Cboe, I think EBS is honest about their capability in the EMS [Execution Management System] space, and they are looking at us as a partner or vendor of choice. Of course they’re connected to other platforms and they don’t favor us over anyone else, but I think a big selling point for our integration with them was that they didn’t have an EMS that’s capable of doing the things that our EMS can do. So they’ve been generous in speaking to the merits of TT and the value we add.
The biggest trade this year for us, has been what we call the EFP [Exchange of Futures for Physical], or the basis trade. This is in spot metals, which trade as a currency in the FX world. So with spot gold and silver, because the basis blew out this past year in those two pairs, they’ve been using our Autospreader tool, which will trade that basis for you. We’ve had a lot of traction there because the gold, silver, platinum and palladium play has been so big this year.
We had thought that our strategy with our Autospreader was geared toward the buy side, on the premise that sell-side banks had their own platforms and systems. So we were pleasantly surprised that sell-side market makers were interested in our offering, because everyone is trading the EFP – they were just doing it synthetically using two separate systems. If they’re TT users, they trade the futures on TT and they trade the OTC FX portion elsewhere, and the lag between the two is huge because you’re clicking on one platform or screen and then clicking again on a separate platform or screen. Our Autospreader tool automates that for you, and when sell-side folks found out that they could do that on TT, it was sort of a light bulb moment, and we’re still getting a lot of inquiries regarding that product.
TT FX added support for bank algorithms in 2025?
Bank algos in FX have really come up in the past five to seven years, and today, there are FX-only platforms that will host bank algos. We made the decision to launch this out of our FX GUI [Graphical User Interface], but our users are coming from the futures and options space, so they’re multi-asset traders. That’s the power of TT in this multi-asset play.
In my last seat in trading, we had different platforms for every asset class – all of it was separate. But at TT, we’re consolidating everything. When you think about the spirit of consolidation and having one system, the idea was to integrate the bank algos directly into the classic TT space, so that multi-asset traders can click on the same drop-down bar where they see their futures algos, and the FX algos will appear. Rather than having to launch FX algos out of a separate platform, our platform will be fully integrated in one space. This is where we’re able to win a lot of clients over.
TT FX supports both full-amount and RFQ workflows?
Our FX offering is quite unique, as FX users are not used to trading FX in the traditional F&O [Futures and Options] ladders. The FX GUIs that exist today trade in what are called tile widgets, which are derived from the old EBS terminal and are the market standard in terms of view. The way we built our offering was to have sweepable markets in the ladder and full amount in the standard tile widgets. This way, we offer a unique trading experience for both traditional F&O users who want to trade FX in a ladder, and for traditional FX traders who want to trade via tile widgets for full amount FX markets – and regardless of how it’s traded, both are fully integrated with the futures and options workspace. So when users log in to TT, they see another drop-down that says TT FX, which opens essentially a new GUI, but within the same space. It’s going to give users the view that they want, and the view that they’re used to, when they trade full amount FX products.
That tile widget – the new GUI which we’re calling FX workspace – has direct LPs [Liquidity Providers] for the first time. This means we’re going to have the banks and non-bank market makers pricing directly. So for example if we go to a client that only trades with direct LPs and not on venues like EBS or Cboe, as long as they have bilateral credit they can trade with the likes of Goldman, UBS, JP Morgan and other big banks, we can aggregate all those liquidity pools from the direct LPs themselves, and we can display that in a way they’re used to seeing through the FX tile widgets.
With our full FX offering, we support spot FX, forwards, swaps, and NDFs [Non-Deliverable Forwards].
What has been the growth of TT FX?
We’ve had triple-digit growth this year compared with last year. And we have grown every quarter since we launched. We’ve increased revenue every month, and we’ve increased volumes and revenue every quarter we’ve been live.
Looking to the future, I think we’re going to have an even larger boost, because most of our large FX clients are going to require that tile widget, and I think that’s where most of our volume for next year is going to come from.
What’s in store for 2026?
The TT FX product is done, it is created. Next year is about distributing the product.
Any TT user who trades FX elsewhere, we want as a TT FX client next year. We think we have a legitimate value proposition for them to trade on TT, because we consolidate their workflow front to back. If they trade FX on a separate platform, we’re going to offer that within TT, and that’s going to allow them to get some screen real estate back that they now use today for multiple platforms.