Sep. 21, 2026
From: kelvin.to databoiler.com Subject: Request for Web Meeting: Preparations for 24-Hour Trading (File No. 4-913) Dear Hon. Chairman Atkins, Hon. Commissioner Peirce, Hon. Commissioner Uyeda, Director Selway, Deputy Director Jon, Peggy, Dan, and Patrick, We at Data Boiler submitted a 24-page comment letter on 24-Hour Trading and attended the Roundtable in-person in DC yesterday. You may review our full letter at: https://www.databoiler.com/index_htm_files/DataBoiler%20SEC%2024H%2020260917.pdf Yesterday's event was a big turnout and a great catch-up time with many market structure fellows. I wish the discussion can get deeper into deciphering market dynamics and some technical aspects. Please see below for a highlight of topics we like to discuss with the Commissions: The "Overnight Paradox" & Illiquidity Tax: While overnight volume is low (90-95% remains anchored to daytime), the volatility risk of order bursts is extremely high. Without a derivatives safety net overnight, market makers will widen spreads drastically, penalizing retail investors with a built-in "Illiquidity Tax". The "Blind Weekend" Credit Vacuum: Matching transactions over weekends when central bank payment rails (Fedwire and NSS) are closed creates an uncollateralized credit vacuum, exposing clearinghouses to hidden insolvencies if a geopolitical shock hits. The "Phantom Halt" Loophole: The public SIP is legally prohibited from aggregating non-exchange ATS quotes overnight. This fragments liquidity into private pools, allowing a stock to be locked at a ceiling on one platform while trading freely on another - enabling predatory algorithms to weaponize "Phantom Halts". The 32-Bit Crash Risk: The sheer volume of continuous overnight algorithmic traffic could cause traditional 32-bit tracking numbers to overflow and crash downstream processors mid-session. While major exchanges are upgrading, smaller brokers and dark pools face catastrophic data bloat. Also, the SEC and FINRA need to review the dynamics when options are not available for hedge at night, futures and other exotic products, portfolio compression are used instead... How would surveillance be ready if not reviewing the other leg of the hedge? Again, and per our comments on Consolidated Audit Trail (CAT), the SEC and CFTC should jointly consider modernizing market monitoring with our 3-Tiers distributed Agentic solution for a more robust cross-markets cross-assets surveillance that runs 24x7 in real time. We also submitted a 35-page comment letter on August 31 in response to the joint RFC on Portfolio Margining and Cross-Margining. If time permits, I would like to also cover this related topic as well. Appreciate your kind consideration for a web meeting with me. *** Best, Kelvin To Founder and President Data Boiler Technologies, LLC Phone: (617) 309.7119 Email: kelvin.to@databoiler.com We see big to continuously boil down the essential improvements until you achieve sustainable growth!