Elizabeth Peraza Slator 02-20-2026 Vanessa A. Countryman Secretary U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549 Re: File No. 4-533 – Joint Industry Plan; Amendment to the National Market System Plan for the Selection and Reservation of Securities Symbols to Add Texas Stock Exchange LLC as a Party Thereto Dear Chair Gensler and Commissioners: I appreciate the opportunity to comment on the proposed amendment to the National Market System Plan for the Selection and Reservation of Securities Symbols (the “Symbology Plan”) to add Texas Stock Exchange LLC (“TXSE”) as a party. Although the Commission has deemed this amendment “technical or ministerial” under Rule 608(b)(3)(iii), the addition of a new national securities exchange to a core market‑infrastructure plan has broader implications for market structure, competition, and operational resilience that merit careful consideration. I. Symbol Governance as Critical Market Infrastructure The Symbology Plan is foundational to the functioning of U.S. equity markets. Ticker symbols serve as the primary human‑readable identifiers for securities, and inconsistencies or conflicts can create operational risk, investor confusion, and data‑integrity issues across trading venues, market‑data vendors, and internal risk systems. The admission of a new exchange should therefore be evaluated not only on formal eligibility criteria but also on how that exchange’s systems and governance will interact with the existing symbol ecosystem. I respectfully request that the Commission encourage the Plan participants and TXSE to provide additional public detail regarding symbol‑conflict resolution, symbol‑change coordination, and any updates to operational procedures that will accompany TXSE’s integration. II. Operational Readiness and Risk Management The notice states that TXSE has represented that it meets the Plan’s eligibility requirements. While necessary, these representations do not fully address operational readiness in a multi‑venue environment. Additional transparency would benefit market participants, including: • Testing and integration: How TXSE has tested symbol‑assignment workflows, conflict scenarios, and corporate‑action events with the Processor and other Plan participants. • Error handling: Documented procedures for detecting, communicating, and resolving symbol‑related errors. • Capacity and scalability: Whether TXSE anticipates listing or product strategies that could materially increase symbol‑reservation activity. Encouraging the publication of high‑level testing results, incident‑response procedures, and capacity planning would strengthen confidence in the integration process. III. Competition, Fragmentation, and Investor Outcomes The addition of TXSE may enhance competition among exchanges, potentially benefiting issuers and investors. However, each new venue also increases market complexity. Greater fragmentation can make it more difficult for investors—particularly retail investors and smaller firms—to understand where liquidity resides for a given symbol and how best‑execution obligations are met. While the Symbology Plan does not govern routing or execution, it is a key enabler of the multi‑venue environment. The Commission may wish to consider whether periodic, holistic reviews of the Plan’s role in supporting fair and efficient markets would be beneficial as new exchanges join. IV. Data Standards and Interoperability Beyond Ticker Symbols Modern markets rely on a variety of identifiers beyond ticker symbols, including ISINs, LEIs, and MICs. The integration of TXSE presents an opportunity to promote stronger alignment between ticker‑symbol governance and broader data‑standard practices. Public guidance on how symbols map to other identifiers would improve transparency and interoperability across the industry. V. Governance, Accountability, and Transparency of the Symbology Plan The admission of a new party is an appropriate moment to revisit the governance structure of the Symbology Plan. Greater public visibility into decision‑making processes, voting structures, and accountability mechanisms would enhance confidence in the Plan’s oversight of critical market infrastructure. Conclusion I do not oppose the addition of Texas Stock Exchange LLC as a party to the Symbology Plan. Integrating new exchanges into core market‑infrastructure plans is essential for a competitive and resilient marketplace. However, even technical amendments can have meaningful implications when they touch foundational systems such as ticker‑symbol governance. I respectfully urge the Commission to encourage greater transparency around operational readiness, risk controls, and governance as TXSE joins the Plan. Thank you for considering these comments. Respectfully submitted, Elizabeth Peraza Slator