SEC comment letter: order competition rule

FX options remains one of the last major asset classes still organised around the traditional dealer model. For Optiver, that has meant building deep relationships in the interdealer market, where we provide banks with additional liquidity and capacity to manage risk. Those relationships remain central to our business and to the way liquidity is distributed across the market. But as the market structure evolves, we are also starting to build more direct relationships outside the interdealer market - adding another route to liquidity.

Lit continuous trading in European equities is declining. This is a trend that needs to be understood and analysed so that we can identify the causes and potential impact on end investors and market quality. Lit continuous order books, where buyers and sellers trade against displayed quotes, are a fundamental part of how prices are formed. Their health matters to everyone who participates in European equity markets.

Despite accounting for just 4% of the EU’s population, the Netherlands has emerged as a critical gateway for European capital markets through decades of investment in market infrastructure, liquidity and participation. Its success provides a blueprint for policymakers seeking to deepen and integrate Europe’s capital markets.

For the past several years, US stock investors have hedged their portfolios largely by looking at their calendars. Fed meetings, CPI prints, elections – whenever an event appeared on the horizon, investors would look to short-dated options to protect against the possibility of volatility.

While Brazil’s securities borrowing and lending framework has its strengths, it still trails global peers. In this paper, we propose steps to modernize the country’s SBL system, without compromising safety.

UK and EU regulators are set to reverse historic ‘unbundling’ rules. But while the rules were imperfect, we believe real strides were made in getting investors to pay attention to trading costs. Now more than ever, traders need to carefully choose the right execution partners and strategy.