Mar. 16, 2026
Rakuten Securities, Inc. respectfully submits this letter in support of the request by 24X National Exchange for temporary exemptive relief to permit the commencement of overnight exchange trading. Rakuten Securities, Inc. appreciates the Commission’s ongoing efforts to maintain fair, orderly, and efficient markets while considering the continued evolution of market structure. As a brokerage serving a diverse range of investors with access to global markets, we have observed increasing interest among market participants in the ability to access U.S. equity markets outside traditional trading hours. In this regard, we believe the proposal by 24X National Exchange represents a thoughtful and measured approach to addressing evolving investor needs. The proposal appears to utilize modern market infrastructure and consolidated overnight data while seeking to maintain appropriate regulatory safeguards and transparency. Providing temporary relief while consolidated SIP functionality continues to be developed may allow regulators and market participants to gain practical experience with overnight exchange trading and to evaluate its operation and potential impacts in an orderly manner. In our view, such a carefully considered step could support the continued accessibility and global competitiveness of the U.S. capital markets. Rakuten Securities, Inc. appreciates the Commission’s consideration of this request and respectfully supports the granting of temporary exemptive relief as proposed. We would welcome the opportunity to continue engaging with the Commission and other market participants as the development of overnight trading frameworks progresses. Respectfully submitted, Rakuten Securities, Inc.