On December 14, 2022, the Securities and Exchange Commission released four sweeping rulemaking proposals that would change market structure as we currently know it and introduce a new federal standard for a broker-dealer’s duty of best execution. We have summarized the key provisions of the proposals and provide some of the Commissioners’ initial reactions, including particularly divergent views with respect to the proposed Order Competition Rule and Regulation Best Execution. Given their length and breadth, we are continuing to review the proposals—please stay tuned for additional updates with our key takeaways. The comment period for each of the proposals ends on the later of March 31, 2023, or 60 days after publication in the Federal Register.
SEC Holiday Reading List: Four Rule Proposals That Would Overhaul Market Structure and How Retail Orders Are Executed
Authors
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Andre E. Owens
Partner
Chair, Broker-Dealer Compliance and Regulation Practice
Co-Chair, Securities and Financial Regulation Practice
[email protected] +1 202 663 6350+1 202 663 6350
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Susan Schroeder
Partner
Vice Chair, Securities and Financial Services Department
[email protected] +1 212 230 8865+1 212 230 8865
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