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
- We note that the Commission’s past approvals of two separate national securities exchanges to operate during U.S. overnight hours were dependent upon the SIPs being operational concurrent with exchange overnight hours. At the end of February 2026, 24X National Exchange requested that the Commission grant it a temporary, conditional exemption to commence operations prior to the relevant SIPs being operable overnight to collect, consolidate, process, and disseminate quotation and transaction information at all times during the overnight session. See Release No. 34-104894 (Feb. 25, 2026), 91 FR 10169 (Mar. 2, 2026). As SIFMA commented on the two prior exchange applications to trade overnight – and consistent with the Commission’s past approvals of expanded exchange trading hours – we view the SIPs being operational as a requirement for exchanges to expand trading hours to cover U.S. overnight hours.
- See SIFMA Letters re: 24X application dated June 27, 2024 (https://www.sec.gov/comments/10-242/10242-485831-1388714.pdf) and Oct. 29, 2024 (https://www.sec.gov/comments/10-242/10242-535475-1535542.pdf); SIFMA Letter re: NYSE Arca application dated Dec. 16, 2024 (https://www.sec.gov/comments/sr-nysearca-2024-89/srnysearca202489-548255-1570802.pdf).