By Jack Miller, Head of Global Execution Services, and Sean Buckley, Head of Electronic Execution Services, Baird

As we pass the 2026 midpoint, there is much to reflect upon following a volatile six months for the markets and a news-making six months on the market structure front.

What we’re watching:

–We now know the (likely) fate of NMS Rule 611 (the Order Protection Rule)610(e) – To the surprise of almost no one, the SEC announced its plans to rescind Rule 611 and 610(e), which had been in the current Commission’s crosshairs basically from day one. As we’ve said before, abolishing or significantly changing the OPR has long been the consensus view in the space but removing it altogether could be problematic. For all of its issues OPR does establish a framework, however flawed, for setting reference prices.

-Tokenization starting to get a bit more real – Rule 611 in particular had been viewed as a major hindrance for the eventual onchain trading of tokenized U.S. equities. Its elimination could harken the start of a new era of tokenized equities, something the major exchanges have all clearly been planning for given the wave of partnership and other announcements each has made this year. 

–Room for new players in the ATS space? There have been a number of successful entrants to the ATS category in recent years (including IntelligentCross, OneChronos and PureStream) so it’s not surprising to see a firm like Mosaic throw its hat in the ring with the launch of its MERIT platform. It will be an interesting one to test, as will new updates from others in this category.

–Tailored liquidity – Numerous venues are rolling out new functionality to help clients tailor liquidity further than standard matching logic or liquidity segmentation. 

-Innovation at “the layer of logic” – The layer of logic that sits above the algo engine is where there could be more innovation. On the buy side, it’s the algo wheel. On the sell side, it’s the routing rule layer. Currently the logic is more static, a set of predefined rules that select brokers/algorithms/algo configurations based on predefined conditions but there are firms, like BTON, using machine learning and other tools to potentially help traders optimize their workflow with a more predictable trading outcome.

-The rise of the mega-IPO and the ongoing democratization of private market investing – We’d talked quite a bit at the start of the year about how the excitement around increased retail access to private market investments was masking the broader failing of the public markets to provide the investment vehicles that investors want and need. SpaceX going public was clearly a watershed moment for the equity markets this year and a handful of other “mega-IPOs” appear to be in the queue. Whether they steer investor attention away from the private markets remains to be seen, but more companies going public is a welcome change.