Market Leadership

Market Structure Implications of Removing Order Protection

Oct. 07, 2025

Guests: Hubert De Jesus, Managing Director, Head of Global Market Structure and Electronic Trading, Blackrock; Doug Clark, Managing Director, Head of Product, TMX Group and James Angel, Professor, Georgetown University McDonough School of Business

Host: Peter Haynes, Managing Director and Head of Index and Market Structure Research, TD Securities

In Episode 73, we recap the recent United States Securities and Exchange Commission (SEC) Roundtable on Rule 611 (aka the Trade Through or Order Protection Rule). SEC Chair Paul Atkins has long been opposed to the rule that forces linkages between exchanges to ensure investors always receive the best price. In his view, Atkins believes 611 stifles innovation and limits competition.

Joining us for the discussion are two of the roundtable participants, Hubert DeJesus of Blackrock and Professor James Angel from Georgetown University, both market structure experts, along with the TMX's Head of Product Doug Clark, an interested observer from his perch in Toronto. The group discusses the need for the rule, the lack of apparent opposition to its removal, the likelihood the rule disappears and market structure implications if it does get eliminated.

The group also discusses the elephant in the room, tokenization of equity trading, and how the crypto market might benefit if 611 is removed.

Chapters:
2:30	Why Rule 611 is Like Scaffolding?
6:11	Why No Market Participants Spoke Out in Support of the Rule?
17:32	What is An IBBO And EBBO?
21:20	Laundry List of Issues to Address if Rule is Eliminated
38:45	How Changes to SIP Fees are Implemented
44:21	Can Trad-Fi and De-Fi Co-exist in a Global Equity Ecosystem?
48:00	Using Exemptive Relief "Sandbox" For Equity Tokens and Potential For Litigation

This podcast was recorded on October 2, 2025.

Full transcription

Full transcript to come.

Disclaimer

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Peter Haynes

Managing Director and Head of Index and Market Structure Research, TD Securities

Peter Haynes
Managing Director and Head of Index and Market Structure Research, TD Securities

Biography

Peter joined TD Securities in June 1995 and currently leads our Index and Market Structure research team. He also manages some key institutional relationships across the trading floor and hosts two podcast series: one on market structure and one on geopolitics. He started his career at the Toronto Stock Exchange in its index and derivatives marketing department before moving to Credit Lyonnais in Montreal. Peter is a member of S&P’s U.S., Canadian and Global Index Advisory Panels, and spent four years on the Ontario Securities Commission’s Market Structure Advisory Committee.