Member Poll Results: Evolving Investor Protections for 24-Hour Trading
Jul 16, 2025
24-hour exchange trading is on the horizon with key pieces of market infrastructure, including the securities information processors (SIPs)1 and The Depository Trust and Clearing Corporation (DTCC),2 recently announcing plans to support this activity. However, additional work should also be done to ensure that our investor protection framework can be successfully applied to extended trading hours. To get a better sense of how the trading community is thinking about these questions, we recently conducted a member poll that asked market participants to share their views on potential changes to Limit Up-Limit Down (LULD), Market-Wide Circuit Breaker (MWCB), and clearly erroneous rules.
Our new white paper, Evolving Investor Protections for 24-Hour Trading, reports the result of our poll and shares thoughts on how the industry can enhance investor protections alongside the move to 24-hour trading.
Here are some of our key recommendations, which are based on the poll and analysis of overnight trading data:
- Extend volatility protections, i.e., price bands, to cover additional exchange trading hours, including new pre-market trading starting at or around 9:00 p.m.
- Apply 10% (Tier 1) or 20% (Tier 2) price band with static reference price to stocks that do not trade or that trade de minimis volume during extended trading hours.
- Apply dynamic reference price calculation for more liquid securities that account for majority of overnight volume. Consider use of notional volume threshold instead of time window in reference price calculation.