Proposed Rule Change to Extend the Exchange’s U.S. Equity Trading Hours to 23 Hours a Day

Summary

SIFMA provided comments to the SEC in response to the proposal by The Nasdaq Stock Market LLC to amend its rules to expand its trading hours for equity securities and exchange traded products ("ETPs") to 23 hours per day, five days per week.

Excerpt

We respectfully request that the Commission approve this proposal. Nasdaq has met with SIFMA and its members to discuss the exchange's plans for extending trading hours ahead of this Proposal. The Proposal is consistent with what was shared with SIFMA previously and is also harmonized with other exchange plans around defining the trading day, inclusive of overnight hours. Specifically, the Proposal will adopt the 8:00 PM ET trade date rollover time and one-hour technical pause between 8:00 PM and 9:00 PM ET. While the industry has open questions to resolve as the equity markets transition to near full U.S. overnight hours - in particular questions around corporate actions - we are generally supportive of Nasdaq's Proposal as it relates to harmonization of the trading day and the exchange pause.

The Proposal confirms that trading will not commence until the Securities Information Processors ("SIPs") are operable to disseminate consolidated market data to the public during overnight hours. ¹ This quotation and transaction transparency is necessary to facilitate price transparency on national securities exchanges. Price discovery and transparency are foundational in equity markets, shaping execution quality, portfolio performance, and investor protections.

SIFMA supports the Proposal, as it aligns with the trade date definition defined by the SIPs, adopts a one-hour exchange pause, and will not take effect until the SIPs are operable overnight. Consistent with our comment letters on other similar exchange proposals, below we raise additional questions and issues for broader consideration outside the context of a single exchange rule filing. ²