On December 14, 2022, the Securities and Exchange Commission (“SEC” or “Commission”) released four sweeping rulemaking proposals that would change market structure as we currently know it and introduce a new federal standard for a broker-dealer’s duty of best execution.

We have summarized the key provisions of the proposals and provide some of the Commissioners’ initial reactions, including particularly divergent views with respect to the proposed Order Competition Rule and Regulation Best Execution. Given their length and breadth, we are continuing to review the proposals - please stay tuned for additional updates with our key takeaways. The comment period for each of the proposals ends on the later of March 31, 2023, or 60 days after publication in the Federal Register.