Chamber Submits Comments to the SEC on Equity Market Structure

The U.S. Chamber of Commerce’s (“the Chamber”) Center for Capital Markets Competitiveness (“CCMC”) submits these comments in response to the four proposed rulemakings regarding equity market structure issued by the Securities and Exchange Commission (“SEC”) in December 2022 (“Proposed Regulations”). Although the Chamber does not object to pragmatic, cautious, and targeted efforts to enhance the structure of the U.S. equity markets – which by all accounts function extraordinarily well and are, as Chairman Gensler rightfully remarked, the “gold standard” for the world-– the Chamber is alarmed that the Proposed Regulations go far beyond what circumstances require. The Proposed Regulations do so in a manner that is needlessly radical and disruptive, and which fails to appreciate the potential for these new rules collectively to cause more harm than good.