Roundtable on Trade-Through Prohibitions

SEC Commissioners and the Director of the SEC's Division of Trading and Markets will give opening remarks.

Staff in the Office of Analytics and Research within the SEC's Division of Trading and Markets will give a data presentation.

Presenters

• Dan Mathisson
• Arun Manoharan
• Jesse Brady

Panel One will focus on market participants’ experience with trade-through prohibitions over the past 20 years. Areas for discussion will include: the effects of trade-through prohibitions on market participants and market structure including unintended consequences of trade-through prohibitions; the effects of trade-through prohibitions on retail and institutional trading; the cost of compliance with trade-through prohibitions for different market participants; differences in experiences with trade-through prohibitions in the equity market versus the options market; and experiences in markets without a trade-through prohibition.   

Moderators:

• Michael Piwowar (Milken Institute) 
• Jamie Selway (Director, SEC Division of Trading and Markets)

Panelists:

• Julie Andress (Securities Traders Association and KeyBanc Capital Markets)
• Ari Burstein (IntelligentCross)
• Peter Haynes (TD Securities)
• Chris Isaacson (Cboe Global Markets, Inc.)
• Katie Kolchin, CFA (Securities Industry and Financial Markets Association)
• Dave Lauer (Urvin Finance and We the Investors)
• Joe Mecane (Citadel Securities)
• Maureen O’Hara (Cornell, SC Johnson Graduate School of Management)
• Pankil Patel (Bank of America)
• Chris Solgan (MIAX Exchange Group)

A one-hour lunch break will occur between Panel One and Panel Two.

Panel Two will focus on a trade-through prohibition’s role in today’s highly automated and connected market structure. Areas for discussion will include: whether a trade-through prohibition is necessary and what objectives it achieves; how a trade-through prohibition intersects with the fulfillment of best execution obligations; the ancillary rules that support a trade-through prohibition such as rules restricting locking or crossing quotations and access fee caps; and whether a trade-through prohibition creates unnecessary complexity within the current market structure.

Moderators:

• Andre Owens (WilmerHale)
• Jamie Selway (Director, SEC Division of Trading and Markets)

Panelists:

• Jim Angel (Georgetown University)
• Allison Bishop (Proof Trading)
• Hubert De Jesus (BlackRock)
• Armando Diaz (PureStream)
• Jonathan Kellner (MEMX)
• Kevin Kennedy (Nasdaq)
• Matt MacKenzie (Optiver)
• Chris Nagy (Healthy Markets Association)
• Adam Nunes (Hudson River Trading)
• Jeff Starr (Schwab)

A break will occur between Panel Two and the Chairman's remarks. 

SEC Chairman Paul Atkins will give remarks following the break.

Panel Three will focus on potential paths forward for trade-through prohibitions. Areas for discussion will include: maintaining the status quo; exemptions from, or modifications to, the trade-through prohibitions (e.g., market share thresholds for protected quotes or block trade exceptions); or rescinding trade-through prohibitions.  The discussion will also include other necessary changes if trade-through prohibitions are limited or rescinded such as amending or rescinding other rules, or providing guidance to market participants (e.g., additional best execution guidance).

Moderators:

• Elad Roisman (Cravath, Swaine & Moore)
• Jamie Selway (Director, SEC Division of Trading and Markets)

Panelists:

• Robert Battalio (University of Notre Dame)
• Matt Billings (Robinhood)
• Robert Colby (FINRA)
• Daniel Gerhardstein (FIA Principal Traders Group and Jump Trading Group)
• Jon Herrick (New York Stock Exchange)
• Vlad Khandros (OneChronos)
• Mehmet Kinak (T. Rowe Price)
• Joe Saluzzi (Themis Trading)
• Andrew Smith (Virtu Financial)
• Cameron Smith (Texas Stock Exchange)
• Debbie Toennies (J.P.Morgan)

The roundtable will conclude at 4:15 p.m.