Subject: File Number 4-913
From: Tomas Graungaard
Affiliation:

Aug. 18, 2026

Dear SEC Commissioners and Staff,
I am writing to you as an independent retail investor and swing trader who actively participates in the US equity markets from Europe.
While I understand that Nasdaq's approved transition to a 23/5 trading model aims to modernize the market and increase global accessibility, I am writing to express my deep concern regarding the structural risks this implementation poses to retail investors. In practice, this transition heavily favors algorithmic market makers at the direct expense of retail participants.
As a swing trader who holds positions over longer periods, my primary concerns regarding the overnight sessions are:
- Artificial Volatility and Stop-Loss Hunting: The severe lack of liquidity during overnight sessions creates an environment ripe for artificial price gaps. Algorithmic traders can easily push prices down to trigger resting retail stop-loss orders, only for the price to recover by the time regular trading hours begin.
- Extreme Slippage: Due to widened spreads and thin order books, retail investors using market orders or standard stop-loss orders risk executing trades at highly distorted prices that do not reflect the actual fundamental value of the underlying asset.
- Psychological and Practical Burden: A market that practically never closes fundamentally undermines the ability of retail investors to manage risk without resorting to 24/7 monitoring, essentially forcing us to either take on unquantifiable overnight risks or rely entirely on algorithms.
My requests to the SEC: Before the technical rollout of the 23/5 system is completed, I strongly urge the SEC to implement robust safeguards for retail investors.
Brokers must be mandated to make "Regular Trading Hours Only" the strict, unchangeable default for all retail stop-loss and standard market orders.
The SEC must demand that brokers provide highly visible warnings about the specific risks of overnight slippage before a retail client is allowed to opt-in to extended-hours execution.
Overnight circuit breakers must be tightened to prevent algorithmic flash crashes in illiquid environments.
Or the easy way: Don't go forward with this
The US market has historically been the gold standard for investor protection. Please ensure that this transition does not turn the market into a predatory environment for everyday investors.
Thank you for your time and for considering the perspective of the retail community.
Sincerely,
Tomas