Dave Lauer Profile picture
Dec 14 13 tweets 4 min read
Today the SEC proposed the most significant changes to US market structure since Regulation NMS was passed, in 2005. These proposals incorporate many of the ideas that we - #WeTheInvestors - presented to the SEC earlier and repeatedly this year.
#WeTheInvestors have had a significant impact on the SEC’s actions - through our dialogue, our proposals, and our presence. These rule proposals are the culmination of those efforts.
But these proposals are only the beginning. Over the coming weeks, We The Investors plans to take seven action steps:
1. Read more than 1,600 pages of rule proposals. Yikes!
2. Write up summaries of the rule proposals with critical elements that we believe retail investors should be paying attention to.
3. Lead a comment letter campaign to ensure that our voices are not drowned out by conflicted industry firms. This will include writing up comment letters that you can use as a template, to either file in their entirety or to write your own.
4. Engage directly with you to answer any questions and discuss ways of getting involved in our effort to fight against the firms that will do everything possible to prevent these rules from being enacted.
5. Engage with the SEC Chair and Commissioners to bring your questions directly to them, and ensure that we are all being heard.
6. Plan a roundtable with industry experts to get their thoughts and opinions on both the proposals and our ideas for improvements or alternatives.
7. And, continue to promote the sign-on letter for our second effort, focused on FTDs, settlement/clearing, DRS and other issues (we’ve extended the deadline to sign).
urvin.finance/advocacy/we-th…
We're going to have many exciting announcements regarding our efforts & direct interactions w/the SEC coming soon. In the meantime, if you want to make sure that conflicted firms aren't able to write rules that advantage them, sign-up to join our efforts: urvin.finance/advocacy/equit…
Also as soon as the rules are up, I'll have links, high-level summaries, and thoughts to share! I'll be watching the SEC's open meeting, which starts at 11am and will be livestreamed: sec.gov/news/upcoming-…
So to kick things off - and I can hardly believe I'm writing these words - we'll be hosting a Twitter space with @GaryGensler this Friday, December 16th at 2pm, with our partners @tigerhillDC

twitter.com/i/spaces/1Yqxo…
The call will explicitly and exclusively focus on the rules proposals announced today. I know there are other issues and questions many of you - and I - would like to ask.
We will have the opportunity to ask those in the future, but for this week we are focused on the most significant changes to market structure in 17 years!

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More from @dlauer

Dec 14
Open Meeting has just moved on to the new equity market structure reforms, starting with Rule 605.
Big changes to Rule 605 will provide far more transparency on execution quality by broker and market center. This update is first in over 20 years and long overdue.

First - it's extended to brokers with > 100k customer accounts (retail brokers).
Second, 605 reports will be dis-aggregated to produce separate reports for various types of orders, such as retail, institutional, retail auctions, and odd lots.

Third, standardized human readable summary reports will be required - excellent addition.
Read 16 tweets
Dec 14
SEC open meeting getting ready to begin here:
sec.gov/news/upcoming-…

🧵A high-level thread with our initial view of the proposed rules, which are split into four proposals.
1. Changes to Rule 605 that will modernize execution quality disclosures and extend those disclosures to retail brokers.
This means brokers will finally have to publish standardized execution quality metrics that we can use to compare how good of a job they’re doing at executing orders, and what kind of execution quality they’re getting from their counterparties.
Read 14 tweets
Dec 13
It's going to be quite a day today! SDNY will unseal their indictment and the FTX hearing in the House will be even more interesting now. SEC has also charged SBF with securities law violations, complaint here: sec.gov/litigation/com…
The SEC complaint doesn't tell us much we didn't already know, but really lays it out simply. He diverted customer funds, Alameda had unlimited credit lines against customer funds and when Alameda couldn't satisfy their loans they raided more customer funds.
Nice use of scare quotes there SEC - it's not a loan if you have no intention of paying it back. Now, the ponzi scheme part of all of this is that maybe he thought he could pay it back with more customer funds, but doesn't much matter. Lotta fraud here, everywhere you look.
Read 7 tweets
Dec 10
I've seen so many questions about MMTLP and the FINRA halt. My understanding is that trading was halted because shares purchased on 12/9 wouldn't have settled in time - if you bought shares, you'd have simply been ripped off. This was explained by co here:
metamaterial.com/meta-materials…
I know this isn't the answer most people want, and regulators don't get the benefit of the doubt anymore, but this seems like a straightforward case of investor protection.
Trades wouldn't settle in time, regardless of buying or selling.
Read 5 tweets
Dec 7
As expected, the SEC has given notice for an open meeting in a week - Dec 14, with an aggressive agenda that will be the biggest overhaul of US market structure in 17 years.
sec.gov/os/agenda-open…
The first item on the agenda is a long-overdue update to Rule 605, execution quality disclosures. I expect we will get updated, modernized metrics (something I've been pushing for 10 years now) along with the expansion of 605 to include internalization. Image
The second item is focused on leveling the playing field between exchanges and off-exchange execution facilities, and improving the NBBO. This will hopefully mean a 50 mil tick increment (half a penny), reduced access fees, and including more orders in the NBBO. Image
Read 9 tweets
Nov 22
I can confirm I've heard similar things as has been reported publicly - the SEC is moving towards a Dec 14 vote on a proposal that will be the biggest overhaul of markets since Reg NMS in 2005. Here's what I think this will look like. 🧵
The proposal sounds comprehensive, w/ 6 main parts: Best Execution, Retail Auctions, Rule 605 Reform, Tick Increment Changes and Harmonization, NBBO Reform and Market Data changes. This lines up with what @GaryGensler has said publicly for the past 6 months since his June speech.
@GaryGensler The best execution changes should include an order-by-order standard. This strikes at the heart of current PFOF brokers/internalizers, who only focus on aggregate execution quality (& still fail to achieve best ex). That's why you see so many 1 mil PI fills - to juice the stats.
Read 15 tweets

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