At tomorrow’s meeting of the SEC’s Equity Market Structure Advisory Committee (EMSAC), committee members and panelists will discuss a proposed framework for a potential access fee pilot.
We appreciate that the SEC and the EMSAC are beginning this process with a public discussion of this framework, because transparency is critical to good policy making. FIA PTG is a strong advocate for data-driven decision-making, and well-constructed pilot programs are a valuable way to gather data on potential market implications of new policies.
Our initial read of this framework has raised some concerns about the structure of this pilot, however, particularly about its degree of complexity. Pilot programs are expensive to implement, so we have practical concerns about the costs that could be imposed by a program this complicated. More broadly, we believe that market structure is already too complex and have called for a principles-based approach to improve transparency, reduce complexity, and ensure fairness and accessibility in our markets.
We will be listening to the discussion at Tuesday’s EMSAC meeting and look forward to providing more detailed input once we have had a chance to consider the details of this pilot.