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      Franklin Templeton Adds Infrastructure Solutions for Retail

      Franklin Templeton, a global investment leader with more than $1.6 trillion in assets under management, together with three leading institutional infrastructure investment firms: Actis, the Sustainable Infrastructure business of General Atlantic; Copenhagen Infrastructure Partners (“CIP”); and DigitalBridge, announced a strategic partnership to deliver private infrastructure solutions to individual investors.

      This partnership seeks to provide private wealth clients with differentiated access to high-growth infrastructure opportunities, thematically focused on energy security, electrification, and digitalization, as well as sectors including data centers and hyperscaler development, renewable energy, fiber and towers, and digital power.

      “We are excited to partner with three leading firms: DigitalBridge, CIP, and Actis, in response to a compelling market demand for allocations to infrastructure,” said Jenny Johnson, President and CEO, Franklin Templeton. “The trends shaping the private markets present an opportunity to broaden access to capital and advance the availability of investments in energy security, electrification, and digitalization, and this is a unique opportunity for investors to unlock that potential.”

      By 2040, global infrastructure needs are expected to surpass $94 trillion, representing an estimated $15 trillion capital opportunity for private investors.1 Through this strategic partnership, Franklin Templeton, together with three leading managers, will bring together complementary expertise to address this demand and deliver attractive investment opportunities:

      • DigitalBridge (AUM: USD$106 billion2) is a leader in global-scale digital infrastructure investing, which provides opportunities to capitalize on the ever-growing digital evolution, including artificial intelligence, by deploying capital across five key verticals: data centers, cell towers, fiber networks, small cells, and edge infrastructure.
      • Copenhagen Infrastructure Partners (AUM: USD$37 billion2) is the world’s largest dedicated fund manager within greenfield energy investments. Through its broad portfolio of energy infrastructure projects and industry expertise, CIP enables the partnership to take full advantage of the opportunities emerging from the global energy transition.
      • Actis (AUM: USD$16 billion3), the Sustainable Infrastructure business of General Atlantic, a leading global investor (USD$114 billion), is a growth market specialist. For over two decades, Actis has invested in critical infrastructure assets with defensive profiles across power, transmission, transport, and digital sectors worldwide.

      “Digital infrastructure is a core driver of the global economy, and private wealth investors are increasingly seeking access to opportunities that have traditionally been reserved for institutions,” said Marc Ganzi, CEO of DigitalBridge. “Partnering with a global distribution leader like Franklin Templeton allows us to broaden access to this asset class at a pivotal moment, as artificial intelligence, electrification, and next-generation connectivity accelerate demand for digital and energy infrastructure. By combining our sector expertise with Franklin Templeton’s reach in private wealth, we are creating a platform designed to deliver institutional-quality opportunities to a broader set of investors.”

      “We are delighted to join this partnership for the development of critical global infrastructure, and energy infrastructure in particular,” said Christian Skakkebæk, Senior Partner at CIP. “As pioneers in providing energy and electrification solutions, we look forward to contributing our distinct industrial approach to value creation, based on investing in greenfield projects and developing them from the ground up. This collaboration is the first of its kind, marking a significant milestone for investors looking to strengthen their portfolios with private infrastructure.”

      “We are building critical infrastructure across energy, digital, transport, and other high-growth sectors, supported by disciplined, hands-on investment capital,” said Torbjorn Caesar, Chairman of Actis. “Investors today are seeking resilience, scale, and relevance – qualities that define Actis’ sustainable infrastructure platform in growth markets. Through this strategic partnership, we look forward to expanding access to our investment platform and delivering long-term value.”

      Once launched, the expanded suite of private wealth offerings will seek to deliver institutional-quality private infrastructure access. The investment profile is expected to provide stable inflation-linked cash flows. These solutions are intended to be built for resilience through economic and market cycles, with exposure to high-growth sectors driving the future of energy, transport, and digital connectivity.

      Source: Actis

      Trade-Through Prohibitions: The Future

      On September 18, the U.S. Securities and Exchange Commission (SEC) hosted a roundtable to discuss trade-through prohibitions in the National Market System stock and listed options markets. Eleven panelists took part in Panel Three – Forward Thinking to debate the future of Rule 611 under Regulation NMS.

      The rule has been around for almost 20 years, originally designed to protect investors and keep markets fair. But with all the changes in the market since then, panelists were asked whether Rule 611 still makes sense today.

      The conversation made it clear there’s no simple answer, and opinions were mixed. While many believe the rule needs serious reconsideration, there’s no clear agreement on how to approach it.

      Is Rule 611 Outdated?

      Matt Billings

      Matt Billings, Vice President of Brokerage and President of Robinhood Financial and Robinhood Securities, said markets have changed so much that Rule 611 is now more of a burden than a help. Trading costs are lower than ever, more people participate, and technology has advanced to the point where the rule’s original purpose feels less relevant. Billings argued that Rule 611 forces brokers and exchanges to manage a complicated web of protections and connections that add cost—costs that ultimately fall on everyday investors.

      “I think we’re at a point where market forces should take over,” Billings said. “We don’t need rules that pick winners and losers anymore.”

      Daniel Gerhardstein of FIA Principal Traders Group and Jump Trading Group, agreed that Rule 611 is “too rigid”. It treats all orders the same, ignoring factors like speed, order size, and liquidity, which matter to investors. In his view, the rule can lead to worse outcomes because it overlooks these differences.

      Gerhardstein suggested a principles-based best execution framework, where brokers are responsible for delivering the best overall outcome—not just the best protected price. He stressed that more transparency and reporting from FINRA could help investors better understand execution quality.

      Concerns About Liquidity and Fragmentation

      Mehmet Kinak, Global Head of Equity Trading at T. Rowe Price, argued bluntly: “We should just get rid of it.” He questioned whether Rule 611 truly improves liquidity or market quality. Kinak noted that sometimes being “traded through” isn’t a bad thing—if someone else offers a better price, why not take it? He also warned the rule might encourage more exchanges to pop up, increasing fragmentation and complexity.

      Mehmet Kinak, T. Rowe Price
      Mehmet Kinak

      “Without the rule, the number of exchanges could easily double or more over the next decade,” Kinak said.

      But not everyone agreed. Joe Saluzzi, partner and co-founder of Themis Trading, raised concerns that removing Rule 611 might hurt retail investors, whose limit orders could be ignored or traded through more often. Saluzzi also disputed that Rule 611 is a major driver of exchange proliferation, pointing instead to factors like market data and complex order types.

      Saluzzi suggested a compromise: keep Rule 611 but apply it only to exchanges that reach certain thresholds, similar to Canada’s approach. That way, smaller venues wouldn’t be shielded by the rule, but protections would remain for bigger players.

      Virtu Financial’s Andrew Smith also defended the rule, emphasizing the National Best Bid and Offer (NBBO) as a “north star” for price transparency. He worried that without Rule 611, the NBBO could break down, confusing retail investors and possibly increasing costs if exchanges decide to charge more without protected status.

      “There’s a real risk that costs could go up for investors if the NBBO falls apart,” Smith said. He doubted scrapping Rule 611 would make things cheaper for brokers or traders.

      Debbie Toennies, Managing Director and Head of Regulatory Affairs at J.P. Morgan, echoed those concerns, warning that removing Rule 611 without a clear plan for other regulations would create a “messy transition.” The rule supports best execution enforcement, and removing it could introduce uncertainty and risk.

      Looking Beyond Rule 611: Exchanges, Revenue, and Market Structure

      The discussion then shifted to how changes to Rule 611 might affect exchanges and the overall market structure.

      Jon Herrick

      Jon Herrick of the New York Stock Exchange emphasized that if Rule 611 is changed or removed, regulators must closely examine how market data revenue is shared through the SIP (Securities Information Processor) system. Exchanges currently have financial incentives to promote displayed trades because of how that revenue is allocated.

      Removing the protected/unprotected framework could encourage exchanges to innovate more and “put their money where their mouth is,” Herrick said.

      He also highlighted non-displayed trades, which make up about half the daily volume but are less transparent and slower to show up.

      “We should be looking at these trades and how we can improve market efficiency and transparency overall,” Herrick said.

      He added historical context, noting the current exchange landscape developed over decades, with industry groups forming new venues to meet demand.

      “This is a shared problem,” Herrick said. “It’s not going to fix itself without regulators stepping in and providing guidance.”

      Cameron Smith, Global Head of Trading and Co-President of the Texas Stock Exchange, took a different view on fragmentation. He wasn’t convinced Rule 611 drives the creation of new exchanges. Many Alternative Trading Systems (ATSs) have emerged despite lacking order protection.

      Cameron said building a new exchange is about proving value, not relying on regulatory protections. New exchanges often start with limited order flow routed through them but can build direct connections over time if they add value.

      “I don’t think we’re seeing exchanges popping up just because of Rule 611,” he said. “Fragmentation is way more complicated and tied to things like antitrust history and market forces.”

      What’s Next?

      The SEC’s roundtable showed how complex the debate over Rule 611 is. Many agree the rule is outdated and causes challenges, but there’s no consensus on how to move forward.

      Herrick stressed a holistic approach: “If we rescind 611, we have to look at the SIP revenue share construct. We need to incentivize displayed trades and improve transparency.”

      Toennies warned of unintended consequences: “Removing 611 without adjusting related rules risks destabilizing a healthy market.”

      Virtu’s Smith highlighted investor trust: “Pulling the thread on 611 risks unraveling important parts of market structure. Without a universal benchmark like the NBBO, investor trust could suffer.”

      The message was clear: any changes need to balance encouraging innovation with protecting investors and maintaining market transparency. The SEC faces a difficult task updating these rules without causing new complications.

      SEC Approves IEX Options Launch

      The US Securities and Exchange Commission has greenlighted IEX’s plan to launch “IEX Options”.

      The market which features a 350-microsecond symmetric access delay and an optional Options Risk Parameter (ORP) that can cancel or reprice market-maker quotes deemed stale when the underlying stock moves to ward off picking by latency arbitrager.

      The SEC said: “After careful review, the Commission finds that the Exchange’s proposal, as modified by Amendment No. 3, is consistent with the requirements of the Act and the rules and regulations thereunder applicable to a national securities exchange”

      The decision follows a heated process. Citadel Securities, as well as other large market makers and exchanges argued the delay/ORP would enable quote “fading” and harm investors and urged the SEC not to approve. IEX, smaller market makers, and academics said it would curb latency arbitrage and improve displayed liquidity. Support also came from trading firms such as Virtu, which called the design “well-intentioned” and potentially beneficial for retail execution.

      Daniel Schalepfer had summarised the view of many mid tier liquidity providers saying: “Citadel’s intensely orchestrated campaign against IEX’s option market proposal has nothing to do with supposed concerns about fading liquidity or inaccessible quotes, or the welfare of retail investors”.

      Read more : Citadel routing argument vs IEX “doesn’t hold weight”, academics say

      Brad Katsuyama, founder and CEO of IEX Group said to Global Trading: “We appreciate the SEC’s review and approval of the IEX Options proposal and thank the broad range of industry participants who went on the record in support of our options filing. IEX remains dedicated to innovating for performance and superior execution quality and looks forward to taking the next steps towards launching our options exchange.”

      A Citadel Securities spokesperson responded to the news saying: “IEX’s quote-canceling scheme undermines the integrity of our markets, stealing money from millions of investors while IEX and a handful of market makers benefit at their expense.”

      This article first published on Global Trading, Traders Magazine’s sister publication.

      FLASH FRIDAY: Market Structure Has Evolved into an Octopus

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      (FLASH FRIDAY is a weekly content series looking at the past, present and future of capital markets trading and technology. FLASH FRIDAY is sponsored by Instinet, a Nomura company.)

      The U.S. Securities and Exchange Commission held a roundtable to discuss trade-through prohibitions in the National Market System (NMS) stock and listed options markets on 18 September 2025. 

      This was a reminder that 20 years ago Paul Atkins, the current chairman of the SEC, voted against the adoption of Reg NMS and its Rule 611, which acts as an order protection rule requiring brokers to obtain the best available price for a stock order.

      Atkins said in a statement: “Reg NMS and its Rule 611 have not served investors or broker-dealers well, given the market distortion and resulting gamesmanship by those that seek to take advantage of the Reg NMS structure.”

      Katie Kolchin, SIFMA

      The first panel focussed on market participants’ experience with trade-through prohibitions over the past 20 years. Katie Kolchin, head of equity and options market structure at industry body SIFMA, detailed on the panel how markets have changed in the last two decades.

      She said one of the original objectives for Reg NMS was to correct market inefficiencies and create the national automated, connected market system. 

      “20 years later you cannot argue against the fact that we are automated and connected,” Kolchin added. “However, the market landscape has changed significantly.”

      • Back in 2004 average daily volume was just around $4 billion => now it is over $17bn

      • 90% was traded on-exchange => now 50% is off-exchange

      • Total U.S. equity market cap was $15 trillion => today it is over $60 trillion 

      • There were seven exchanges in 2004 => there are 16 today, with more in the pipeline. 

      • There were 10 alternative trading systems (ATSs) =>  there were 33 ATSs in the second quarter of this year and market participants can route orders to over 250 OTC venues today

      • Average trade size in 2024 on an exchange was 440 shares => versus 140 shares today

      • Average trade size off-exchange in 2024 was over 1,300 shares => versus just over 200 shares today

      • Retail investors were under 10% of the market in 2024 => it is between 20% and 30% according to SIFMA’s latest survey 

      • Execution speeds have dropped from milliseconds => microseconds => nanoseconds => goal of zero latency

      As markets have changed, brokers have to potentially connect to up to 16 exchanges as well as all the other trading venues offering liquidity and they incur hefty connectivity and market data costs. 

      Joe Mecane, Citadel Securities

      Joe Mecane, head of execution services at Citadel Securities, estimated that the increased cost to the industry of having to connect to so many venues is about $375m a year. He said on the panel: “We also think that removing the trade through rule would not do a lot to impact that cost.”

      Kolchin compared market structure to an octopus with its many tentacles that can move in multiple directions and change shape in a variety of ways. 

      “Its arms are incredibly flexible, enabling infinite and complex yet precise movements,’ she added. “Its arms can move independently, yet are interconnected. In fact, an octopus’s nerves do not just run the length of a single arm, but can also connect to an arm two arms away. Its arms can even continue to move after death.”

      She used the analogy that like the octopus, market structure involves many moving interconnected pieces, and Rule 611 represents the head of this octopus. 

      “If you move or change one piece, other parts could move as well,” she added. “Before making any changes it is important to identify and analyze interconnected market structure pieces and study what corresponding changes could stem from any intentional change, as well as the cumulative net effect of changes as U.S. capital markets are the envy of the world.”

      One interesting fact about an octopus is that over two thirds of their 500 million neurons reside within their arms according to the UK’s Natural History Museum. Researchers have found that octopuses can move their arms independently, without waiting for the brain to instruct them to do so – although interaction with the central brain is still needed to help interpret the information acquired by the arms.

      The complexity of octopus biology seems like an apt analogy for the complexity of U.S. market structure for equities and options. As a result of their decentralized nervous system, octopus limbs can continue to move even after the animal has died. 

      The industry needs to make sure that killing off the trade-through rule does not lead to the same challenges persisting, or even worse, that in another 20 years market structure is more fragmented, complex and expensive for investors.

      Trade-Through Prohibitions: The Present

      What’s the role of trade-through prohibitions in today’s electronic marketplace? 

      That topic was discussed as part of the U.S. Securities and Exchange Commission’s Roundtable on Trade-Through Provisions, in a panel sandwiched between sessions assessing the past and the future of trade-throughs.  

      The 10 panelists were in broad consensus on two aspects of the debate: one, that 20 years after Rule 611 was codified in Regulation National Market Structure (Reg NMS), it’s high time to revisit the rule; and two, in a highly interconnected market structure, any changes to Rule 611 need to be considered holistically and not in isolation. 

      To the bottom-line question of what to do with Rule 611, Chris Nagy, Co-founder of Healthy Markets Association, was generally constructive on trade-through prohibitions, while most other panelists leaned toward scrapping the so-called order protection rule.

      Nagy, a 38-year Wall Street veteran, recalled how the OPR provided “pretty extreme” price improvement for retail investors when it was implemented back in 2005. “We needed a backstop for ‘best ex’ and that’s what OPR is,” Nagy said. “The rules could be improved, but any weakening must be accompanied by improvements to best ex” provisions, he said. 

      Jim Angel, Associate Professor at Georgetown University, said the OPR served as a helpful scaffolding to a market that in 2005 was in its early days of automation and electronic interconnectivity. “We don’t need that scaffolding anymore. It adds tons of complexity to the market,” Angel said, adding that best obligation rules are sufficient for investor protection. 

      Hubert De Jesus, Global Head of Market Structure and Electronic Trading at BlackRock, said Reg NMS, including Rule 611, has been instrumental in integrating independent marketplaces into a cohesive market structure, and U.S. equity markets functions well.

      Regarding Rule 611, De Jesus noted the trade-through prohibition is closely connected to other regulations, and scrapping it by itself would be like removing the keystone from an arch. “You  would need to review other rules,” he said.  

      Adam Nunes, Head of Business Development at electronic liquidity provider Hudson River Trading, said leadership at his firm didn’t believe there was a strong rationale for Rule 611 back when it was first implemented, and the case is even weaker now since competition and innovation have solved some problems over the years.   

      MEMX CEO Jonathan Kellner said the SEC needs to review ancillary rules and broader market structure with any changes to Rule 611, with an emphasis on strengthening displayed liquidity.    

      Nasdaq was the other exchange represented on the panel. Kevin Kennedy, Head of North American Market Services, said Rule 611 stifles competition and exchanges can’t compete fairly with off-exchange market centers – scrapping the rule would reduce complexity and signal the SEC is moving away from prescriptive regulation and toward a more competition-based rules framework.

      The Ten Year Itch: Remarks at the Roundtable on Trade-Through Prohibitions

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      Commissioner Hester M. Peirce

      Sept. 18, 2025

      Good morning, and thank you all for being here. I will keep my statement short. I recently touched on the trade-through rule in a speech,[1] and I want to give as much time as possible to our impressive panelists. Today’s agenda is packed with panelists and issues for discussion.

      Today’s focus is on Rule 611 of Reg NMS, also known as the trade-through rule, the order protection rule, or simply OPR. It is not only a rule of many names, but a rule that inspires many different opinions. The rule was controversial enough when it was adopted in 2005 to prompt a lengthy 44-page dissent from Commissioner Cynthia Glassman and then-Commissioner Paul Atkins.[2] Ten years later, in 2015, Rule 611 was the subject of the very first meeting of the Commission’s Equity Market Structure Advisory Committee, which featured some of the same panelists and moderators that will speak later today.[3] Ten years later, here we are again. Rule 611 remains in our rulebook, remains controversial, and remains a hot topic in Commission corridors. By now, the top-line arguments are familiar. Critics of the rule blame it for increasing complexity, fragmentation, and costs, while defenders credit it for increasing competition and protecting investors. I am eager to hear more in-depth discussion from our panelists, many of whom have spent their careers working in a market shaped by Rule 611. 

      The insights gained from today’s discussions should help the Commission determine whether to move forward with amendments to Rule 611, and if so, what form those amendments should take. Should Rule 611 be retained, repealed outright, or amended, so as to apply only to exchanges above a certain volume threshold? If a volume threshold is appropriate, what should that threshold be? And if Rule 611 is amended or repealed, should other NMS rules, such as the access fee cap in Rule 610 or the minimum tick size in Rule 612, also be changed? Should our thinking on the trade-through rule apply equally with respect to the joint industry plan equivalent in the options market? Does that market’s experience with its trade-through rule mirrors the experience of the equity market?[4] On these matters we will benefit greatly from the wisdom of the panelists. 

      Even with the wisdom of our panelists, and the expertise and diligence of our staff, changing these rules will not be an easy task. Our markets are dynamic systems made up of, among others, investors, exchanges, ATSs, broker-dealers, proprietary trading firms, and technology providers, each of whom operates with different incentives, business models, technical and operational capabilities, and risk tolerances. This complexity is wonderful and keeps our markets vibrant and competitive. But it makes the task of writing, amending, or repealing rules that regulate this market structure challenging. Compounding this challenge is the rapid pace of technological innovation, which alters the markets in ways that we cannot foresee. Any amendments we undertake must try to account for technological changes we can anticipate, such as currently ongoing efforts regarding tokenization, as well as those we cannot. That the task is hard should not foreclose Commission action, but will require us to be careful, deliberate, and collaborative. Only then can we create durable and beneficial change to our markets. 

      Thank you again. I am looking to a fascinating, productive discussion—so productive that you do not find yourselves back here discussing this same topic in 2035. 


      [1] Commissioner Hester M. Peirce, Horses and Bourses: Remarks at the 12th Annual Conference on Financial Market Regulation (May 16, 2025), https://www.sec.gov/newsroom/speeches-statements/peirce-remarks-financial-market-regulation-051625.

      [2] Dissent of Commissioners Cynthia A. Glassman and Paul S. Atkins to the Adoption of Regulation NMS (June 9, 2005), https://www.sec.gov/files/rules/final/34-51808-dissent.pdf.

      [3] See Equity Market Structure Advisory Committee Meeting Transcript (May 13, 2015), https://www.sec.gov/spotlight/emsac/emsac-051315-transcript.txt; see also Equity Market Structure Advisory Committee Archives, https://www.sec.gov/spotlight/emsac/emsac-archives.htm  

      [4] The options market is fascinating and merits its own more comprehensive roundtable.

      SEC, CFTC Extend Form PF Compliance Date

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      Washington D.C., Sept. 17, 2025 —

      The Securities and Exchange Commission and U.S. Commodity Futures Trading Commission each voted to further extend the date for investment advisers to comply with amendments to Form PF, the confidential reporting form used by certain private fund advisers.

      The Commissions extended the compliance date to Oct. 1, 2026.

      The Form PF amendments were adopted in February 2024 and the original compliance date was March 12, 2025. The compliance date was previously extended to June 12 and then October 1, but this further extension will provide time to complete a substantive review of Form PF in accordance with a Presidential Memorandum and take any further appropriate actions, which may include proposing new amendments to Form PF.

      Is T+0 the Next Frontier for U.S. Equity Markets?

      With the successful shift to T+1 now behind the U.S. equity markets, attention is turning to a more ambitious target: same-day settlement, or T+0. As crypto markets embrace near-instant settlement and investors expect real-time experiences, the traditional equity settlement model is being reevaluated.

      Rich Robinson

      “The appeal of T+0 is straightforward,” said Rich Robinson, Chair of ISITC. “In theory, it reduces counterparty risk, frees up margin, and aligns capital markets with the ‘instant’ experience investors expect elsewhere.” 

      “Broker-to-broker exchange transactions are already highly automated, so you can see why T+0 might be feasible in that limited context,” he told Traders Magazine.

      While the move to T+1 in the US “was a success,” according to Valentino (Val) Wotton, Managing Director and Global Head of Equities Solutions, DTCC, it is important to note that a full-scale, industry move to T+0 would require a fundamental transformation of market infrastructure, processes, and operations.

      He further said that while there are benefits to operating on a T+0 settlement cycle, such as a reduction in clearing fund capital and counterparty risk, it is important to note that it is not without trade-offs and challenges, including the potential for settlement cycle mismatches with most global markets considering or working towards a T+1 settlement cycle. 

      Additional alignment around foreign exchange and securities lending practices would likely also need to be addressed, he said.

      Understanding Real-Time T+0

      However, as Larry R Tabb, Head of Market Structure Research at Bloomberg Intelligence, explained, the road from T+1 to T+0 is far more complex than it may appear.

      Tabb pointed out that the term T+0 isn’t as “clear-cut as it sounds”. “There’s T+0 end-of-day, and then there’s T+0 real time,” he said, noting that the two represent fundamentally different market behaviors. End-of-day T+0 would still allow for netting—a process where trades are offset against each other to reduce the number of final settlements. Real-time T+0, however, means instant settlement for each individual trade, also known as atomic or gross settlement.

      “It telescopes the investor’s intention,” Tabb warned, particularly when discussing large institutions like Fidelity or BlackRock. If those firms had to pre-fund trades—holding either stock or cash before execution—it could inadvertently leak market-moving information, he said. That, he explained, could become a serious risk for institutional investors, both from a strategic and regulatory standpoint.

      Larry R Tabb

      One of the major challenges in moving to real-time settlement is the role of market makers, who provide critical liquidity by continuously buying and selling securities, often going short or long in the process, Tabb said.

      Under a real-time T+0 system, market makers could no longer sell shares they don’t already own, he explained. That would fundamentally break their current model, forcing them to either pre-buy securities or borrow in advance, he added.

      In today’s market, high-frequency trading firms execute thousands of trades a day, many of which cancel each other out, Tabb said, adding that these are netted and settled in bulk at the end of the day. “Under a real-time regime, each trade would need to settle individually, leading to massive operational overhead and infrastructure strain,” he said.

      Wotton noted that T+0 settlement is distinct from atomic settlement, which moves away from clearing practices since there is no longer counterparty risk enabled as settlement is handled instantaneously. 

      “While atomic settlement and asset tokenization, enabled by DLT, could create new value by adding use cases for intraday/afterhours collateral and trading, real-time gross settlement (RTGS) may not necessarily be more efficient than the current netting system for existing activity, which provides significant benefits that reduce settlement cost, complexity and the need for pre-funding each trade,” he said.

      Lessons from T+1 

      When the U.S. moved to T+1 settlement, many expected operational headaches, especially for foreign investors trading in U.S. markets, but the transition proved surprisingly smooth, Tabb noted.

      “We thought it was going to cost a lot more,” Tabb said. While settlement fail rates briefly ticked up, they quickly normalized. Whether banks extended intraday credit or lent out securities behind the scenes is unclear—but challenges were minimal, he noted.

      However, Tabb stressed that T+1’s success shouldn’t be mistaken for T+0 readiness. “The leap from T+2 to T+1 was largely evolutionary. T+0, particularly real-time T+0, would be revolutionary, requiring a complete overhaul of how trades are processed, cleared, and settled,” he said.

      According to Robinson, more than a year into T+1, a few frictions stand out. He mentioned that cross-border FX funding was a major one, especially for Asia-Pacific investors who, in practice, were already on a T+0 basis for U.S. trades because of the time-zone difference. “That led to pre-funding challenges and, in some cases, higher costs,” he said.

      “We also saw that exceptions – mismatched or incomplete trades – became much more painful under T+1. With less than a full day to fix breaks, the pressure on custodians, counterparties, and operations staff increased significantly,” Robinson said. 

      “Small and medium-sized managers in particular often relied on manual or portal-based processes that don’t scale well under tighter deadlines. Those frictions would be magnified under T+0, where there is virtually no buffer to resolve issues if something goes wrong,” he added.

      Val Wotton, DTCC
      Val Wotton

      While the US’ move to T+1 was smooth, post-implementation reviews revealed some areas still in need of improvement – particularly in foreign exchange, corporate actions, stock lending, fund settlement cycles, time zone challenges and the need for greater automation across the post-trade lifecycle, Wotton said.

      DTCC believes the immediate focus should be on global harmonization around T+1, including the modernization of key systems as well as broader adoption of automation, as pockets of manual processes and inefficiencies remain, he said.

      “By focusing on these areas, we will help unlock greater efficiency, reduce risks, and lower cross-market friction within a T+1 settlement cycle,” he added.

      Where the Industry Stands Today

      When asked if real-time T+0 is even feasible, Tabb said: “In traditional equities, no. If you had a tokenized version of an equity, then yes.”

      He added that for T+0 to be even remotely viable, funds would need far greater control over their cash and securities. That could mean consolidating brokerage and custody relationships—something many asset managers are wary of due to potential conflicts of interest.

      Alternatively, blockchain-based platforms could facilitate direct, atomic settlement across firms—but integrating such systems with existing bank infrastructure would be a monumental challenge. “That’s not going to be easy,” Tabb cautioned.

      “There’s a fair amount of thinking about T+0,” Tabb said. “But I don’t think there are a whole lot of people in the equities world seriously looking at real-time gross settlement.”

      From ISITC’s perspective, the more complex investment manager to broker flows are where the real challenges lie, Robinson said.

      “T+1 already showed how difficult it is to manage FX funding, securities lending, and corporate actions in compressed timeframes,” Robinson stressed. 

      For small and mid-sized firms without the budgets to overhaul infrastructure, shortening the cycle again could mean higher costs and more operational risk, he noted. 

      “So while there are strong arguments in favor, we need to be realistic about what it would mean for the broader ecosystem, not just the most automated segments,” he said.

      Robinson added that there’s been a lot of energy around distributed ledger and AI pilots, and they’ve proven useful in showing what’s possible. 

      DLT, for example, he said, can support instantaneous settlement in controlled environments: “AI is helping firms detect and route exceptions faster. And clearing infrastructure continues to evolve to handle shorter cycles.”

      “But pilots aren’t the same as production at scale. What T+1 taught us is that when something goes wrong – a block allocation issue, a securities loan recall, an FX mismatch – those problems still require people and processes to resolve,” he said.

      “Technology can highlight issues more quickly, but it can’t eliminate them. That’s why, for the foreseeable future, T+0 may be possible for certain broker-to-broker transactions, but much less realistic across the full investment management workflow,” he added.

      Wotton stressed that DTCC stands ready to support the industry with the infrastructure, expertise, and collaboration needed to navigate future advancements in settlement cycle timeframes while remaining committed to ensuring market stability and enabling innovation across the financial ecosystem. 

      “Should the industry coalesce around a move to T+0, and with regulatory support, DTCC will advance efforts to meet this need,” he said. 

      “At the same time, as the market ecosystem evolves, we may see more RTGS capabilities that support lending, for example, which may decrease the costs associated with pre-funding and could make RTGS more attractive over time,” he concluded.

      Joe Wald Leverages Entrepreneurship to ‘Challenge the Status Quo’

      For more than three decades, Joe Wald has combined trading and technology with an entrepreneurial mindset. From his early days co-founding EdgeTrade to his current venture, Mosaic Platforms, he has kept entrepreneurship at the core of his career.


      Wald joined The Open Order Podcast, a Traders Magazine production, to talk through that journey.

      Wald grew up in an entrepreneurial household in Brooklyn, New York, and credits that experience with sparking his interest in building businesses. “For me, entrepreneurship wasn’t just about starting a business,” he said. “It was about identifying inefficiencies, challenging the status quo, and creating something that made people’s lives or businesses better.”

      That instinct carried into his finance career. While still in college, Wald began working at a broker-dealer that became a hub for innovation. Soon after, he co-founded EdgeTrade, at a time when algorithmic trading was still in its early stages. “That was the ‘lemonade stand’ moment for me,” he said. “Except instead of paper cups, it was algorithms, routers, and market structure.”

      The company evolved over a decade and was acquired by Knight Capital in 2008. Wald later co-founded Clearpool, developing a modular, customizable algorithmic trading platform that gave broker-dealers transparency and control. Clearpool was acquired by BMO in 2020.

      However, not every venture has been a straight line. Wald acknowledged some of the misses along the way, such as building products before the market was ready. “Timing, storytelling, and team alignment are just as critical as product-market fit,” he said.

      Wald also discussed intrapreneurship — bringing an entrepreneurial mindset into large firms such as Knight and BMO — and emphasized that conviction and team balance are key to moving from idea to execution. “I think another most important key is surrounding yourself with people who balance your strengths and blind spots. Entrepreneurship isn’t a solo sport. It’s a team effort, and the right partners can turn risk into reward.”

      Looking ahead, Wald is channeling those lessons into Mosaic Platforms, his current entrepreneurial venture. He described it as an effort to “unlock the full picture of trade performance,” a response to what he sees as markets too narrowly focused on speed and short-term outcomes.

      “Markets today focus on child order speed and short-term outcomes, not whether the entire trade was good for the investor or liquidity provider,” he explained. “At Mosaic, we’re not just building another venue — we’re creating a virtuous cycle where both sides win and where the best trading behavior is rewarded by design.”

      Retail Investors Fuel Push Toward 24-hour U.S. Equity Trading

      By Brandon Tepper, SVP & Global Head of Data, Nasdaq

      The U.S. equity market has long centered around a fixed window, but that window is widening. Not just because technology allows it, but because investor behavior demands it.

      At the center of this shift is the retail investor. Once considered peripheral to institutional flows, today’s retail participants are not only more active, but they’re also reshaping the very structure of market access.

      Retail’s Rise Is Structural, Not Cyclical

      The surge in retail trading during the pandemic wasn’t a temporary spike, it was the start of a structural shift in how markets operate and who participates in them. This shift is underpinned by lasting changes in technology access, commission-free trading, and investor education, factors that won’t reverse with market cycles.

      Nasdaq data shows that retail investors are now net buyers of ETFs nearly every day. Their gross trading activity, across both ETFs and individual equities, continues to grow steadily. While they still account for less than 4% of total market value traded[1], their influence is outsized when measured by volume, behavioral impact, and platform expectations.

      Consider ETF trading: retail participation has increased from 5.2% to 6.4% of total ETF volume in recent years[2]. But volume alone doesn’t capture the full picture. According to Nasdaq’s 2025 ETF Retail Investor Survey, daily and weekly trading activity among retail investors rose 6% and 8% year-over-year, respectively. Gen Z is leading this shift, with 49% trading weekly and 25% trading daily, behavior that increasingly mirrors institutional engagement patterns.

      This cohort isn’t just more active, they’re more deliberate. Nearly 70% of retail ETF holders now prioritize risk, market conditions, and price trends when researching investments. Long-form content engagement is up 4%, suggesting a move toward deeper analysis and more informed decision-making.

      One of the clearest signals of this evolution is the growing demand for extended and overnight trading. Retail investors are reacting to macroeconomic data, earnings releases, and geopolitical events in real time, and they expect the market to be accessible when the news breaks, not just when the bell rings.

      Extended Hours Are Expanding—And Retail Is Leading the Charge

      Extended-hours trading (4 a.m. – 9:30 a.m. ET and 4 p.m. – 8 p.m. ET) now accounts for approximately 11% of total daily volume, with more than 1.7 billion shares traded outside of the traditional session[3]. That’s more than double the volume seen in early 2019.

      But the composition of that volume tells a more nuanced story. Pre-market trading has grown 15-fold since 2019, while post-market activity has increased just 2.3 times. Today, pre-market sessions account for over 55% of extended-hours volume, up from 37% five years ago[4].

      This shift reflects a growing global investor base, many of whom are retail participants engaging from outside the U.S. time zone. Overnight trading (8 p.m. to 4 a.m. ET), while still a small slice of total volume, just 0.2%, is gaining traction[5]. Much of this activity is driven by retail investors reacting to earnings releases, macroeconomic data, and geopolitical events that occur outside of regular hours. In today’s global information cycle, market-moving news doesn’t wait for the opening bell, investors are responding in real time, around the clock.

      Infrastructure and Transparency Must Keep Pace

      The move toward 24 hour trading is not without its challenges. As retail investors continue to shape market structure, transparency must evolve to reflect how they actually trade. Today, over half of all trades on U.S. exchanges are odd lots, a direct result of the shift toward notional and fractional share trading. These smaller orders, once considered peripheral, now represent the core of retail behavior. Ensuring visibility into odd lot activity is essential to building trust and enabling smarter decision-making in a 24 hour environment.

      As exchanges and regulators work to modernize clearing, settlement, and data infrastructure, investor protection must remain a top priority. Sophisticated, real-time data delivery, via API-first, cloud-native platforms, is essential to ensure that all participants, regardless of when they trade, have access to the insights they need. In a 24 hour environment, data isn’t just a tool, it’s critical infrastructure. It underpins price discovery, risk management, and investor protection in real time.

      The Future Is Already in Motion

      Activity outside traditional market hours is accelerating, driven by retail investors who expect flexibility, immediacy, and access to actionable data whenever they choose to engage. But to truly meet investor expectations, the industry must modernize the data infrastructure that powers these markets, ensuring it is fast, connected, and resilient enough to support continuous, global participation.

      Nasdaq® is a registered trademark of Nasdaq, Inc. The information contained above is provided for informational and educational purposes only, and nothing contained herein should be construed as investment advice, either on behalf of a particular security or an overall investment strategy. Neither Nasdaq, Inc. nor any of its affiliates makes any recommendation to buy or sell any security or any representation about the financial condition of any company. Statements regarding Nasdaq-listed companies or Nasdaq proprietary indexes are not guarantees of future performance. Actual results may differ materially from those expressed or implied. Past performance is not indicative of future results. Investors should undertake their own due diligence and carefully evaluate companies before investing. ADVICE FROM A SECURITIES PROFESSIONAL IS STRONGLY ADVISED.


      [1] Nasdaq. “Retail Trading Growth: A Perspective.” https://www.nasdaq.com/articles/retail-trading-growth-perspective

      [2] Nasdaq. “2025 ETF Retail Investor Survey” https://www.nasdaq.com/solutions/nasdaq-etf-retail-study

      [3] Nasdaq. “Looking at All-Day Data: 24-Hour Trading.” https://www.nasdaq.com/articles/looking-all-day-data-24-hour-trading

      [4] Nasdaq. “Looking at All-Day Data: 24-Hour Trading.” https://www.nasdaq.com/articles/looking-all-day-data-24-hour-trading

      [5] Nasdaq. “Looking at All-Day Data: 24-Hour Trading.” https://www.nasdaq.com/articles/looking-all-day-data-24-hour-trading