Welcome to the November edition of The Monitor.
Many trading and compliance teams are taking a close look at their oversight environments heading into 2026. The market has become more complex, trading activity is stretching well beyond traditional sessions and expectations for how oversight is demonstrated are rising. In that context, firms are simplifying where possible and consolidating where it creates clarity.
That direction is what led us to provide trade surveillance and best execution analytics on the same platform. When the data and review workflows align, it becomes easier to understand trading intent, support decision-making, and document oversight in a way that saves teams time and resources.
This month’s developments reinforce that trend. FINRA’s recent actions highlighted the importance of aligning surveillance programs with real trading behavior and maintaining review workflows that clearly document how conclusions are reached. The Senate’s proposal to bring crypto spot trading under CFTC oversight and IOSCO’s report on tokenization risks show that digital assets are gradually being brought under the same regulatory frameworks that govern traditional markets. Meanwhile, the SEC’s temporary relief under Regulation NMS serves as a reminder for firms to align best execution analytics and venue documentation with updated implementation timelines.
At the same time, AI-driven trading strategies are increasing message volume and extended sessions are becoming more active. Many firms are tuning alert logic for overnight conditions, preparing for new transparency under Rule 605, and evaluating whether current routing and review frameworks scale with changing market structure.
We hope the insights in this edition support your planning and approach to trading oversight for 2026.
— Lisa Balter Saacks, President at Trillium Surveyor
Regulatory Radar
- FINRA fines First Trust for supervisory documentation failures
FINRA fined First Trust Portfolios $10 million for supervisory and recordkeeping deficiencies related to non-cash compensation practices, reinforcing expectations that oversight programs reflect actual business conduct and maintain clear documentation. (FINRA, Nov 2025) - Senate draft would place crypto spot markets under CFTC oversight
A new bipartisan draft aims to clarify who regulates crypto spot markets by assigning primary authority to the CFTC. Crypto trading oversight could soon resemble other regulated markets with clearer expectations for surveillance and documentation. (Senate.gov, Nov 2025) - SEC provides temporary relief on certain Reg NMS implementation dates
The SEC granted timing relief on select market structure changes, giving firms additional room to align venue evaluation, routing workflows, and best execution committee materials. (SEC, Oct 2025) - SEC extends compliance date for amended Rule 605 disclosures
The SEC extended the compliance date for the amended Rule 605 execution quality disclosures to August 2026, giving firms more time to adjust reporting and analytics workflows. The updates will require significantly more granular data on execution quality across venues and order types, increasing the importance of clear routing rationale and consistent documentation across oversight teams. (SEC, Oct 2025)
Trading Compliance Newsbeat
AI is flooding markets with unprecedented message volume… is your surveillance framework ready?
In a recent Fortune article, NYSE President Lynn Martin noted that AI-driven order flow is now generating more than a trillion market messages per day, and that this activity cannot be monitored through manual review. Automation is reshaping how liquidity appears and moves across venues, expanding the size and speed of the environment that surveillance teams must oversee.
This shift is prompting firms to reassess whether their surveillance frameworks are built for today’s scale. The challenge is not simply absorbing additional alerts. It is tuning detection logic to evolving trading behaviors, ensuring review workflows remain meaningful, and documenting conclusions clearly for committee and exam visibility. Many legacy tools were designed for a different pace of market activity. Surveillance now needs to evolve at the same pace as the trading patterns it monitors.
Oversight expectations around automated alerts are tightening
A recurring theme across regulatory statements that was also echoed at recent industry events, including discussions at FINRA Small Firm and NSCP, has been the shift in how firms demonstrate the effectiveness of their alert handling processes. It is no longer just about having automated surveillance alerts in place. The focus is now on how those alerts are reviewed, what drives escalation, and how conclusions are documented in a way that supports supervisory oversight.
In practice, teams are formalizing alert review ownership, standardizing the reasoning notes used when closing or escalating an alert, and preparing concise summaries for surveillance or best execution committees. The goal is to show a clear line between what triggered the alert, what was evaluated, and why a particular decision was made. Firms are working toward consistency and clarity, not volume of review. Tools like Surveyor are resonating because alerts come with a natural-language storyboard that plainly explains why each alert was generated, making the process more straightforward and consistent.
Sneak Peek – Surveyor Perspective
The New Trading Edge: Unified Surveillance and Execution Analytics
When markets whipsawed in early April 2025, several broker-dealers saw outages that left oversight and execution systems struggling to keep pace. One platform froze mid-sell-off, while another’s surveillance alerts stalled for hours, slowing compliance reviews and creating oversight gaps. These disruptions left firms exposed to financial penalties and reputational damage by creating blind spots in trade data and delaying surveillance reviews. In fragmented environments, a single failure can quickly ripple across desks, compounding operational and regulatory risk.
Firms relying on disconnected surveillance and execution analytics platforms risk not only compliance gaps but slower insights, increased manual handoffs, and missed operational efficiencies and alpha generation. The convergence of volatility, rising regulatory pressure, and a trading day that increasingly stretches beyond normal hours is prompting firms to rethink their approach. Legacy and current systems built in silos—one for surveillance, another for best execution analytics—slow teams down and leave value on the table. The solution gaining traction and providing a competitive edge: unifying the two. Stay tuned, the full perspective is coming next week.
Poll: Unified Oversight Preferences
As trading oversight evolves, teams are reconsidering which systems work best when they share the same data and context.
Poll: Which system combination is most beneficial to have on one platform?
Response choices:
- Surveillance + Best Ex
- Surveillance + E-Comms
- Best Ex + TCA
- Surveillance + 605/606
Why it matters: When systems share context, oversight becomes more consistent, review times shorten, and committees have a clearer view of trading intent and outcomes.
Products and Services
Feature Spotlight: One Platform for Surveillance and Best Execution Analytics
Many firms are reassessing how review workflows connect when they rely on the same underlying trade data. When surveillance and best execution analytics draw from a shared dataset, teams do not need to recreate context or piece together narratives across systems. Instead, they can move between surveillance review and execution analysis as needed, using consistent information to support oversight decisions.
On Surveyor, trade surveillance and best execution analytics are built on the same source of trade data, with the ability to toggle between views depending on the review. This allows teams to:
- Review a surveillance alert, then shift views into execution analysis using the same trade records
- Evaluate routing decisions and market behavior without rebuilding context in a separate system
- Prepare clearer, committee-ready documentation because the trade narrative is consistent across views
Instead of fighting data silos, teams can interpret trading behavior, understand intent, and document oversight using a shared source of truth.
If you’d like to see how firms use this in daily reviews and committee discussions, we can walk through a short example.
Our Social Calendar
On the Road
Recent
- NSCP National Conference
Upcoming
- CSTA Nov 12-14 in Charleston
- FIA Expo- Booth 214 Taste of Expo: Monday, 4:00–5:30 PM; stop by the booth for a quick hello.
Surveyor in the News
- Traders Magazine, Executive Leadership Profile
- TabbFORUM, 40 Innovators in Financial Markets
- 2025 U.S. Women in Finance Leadership Awards Recognition
Let’s Connect
Interested in how unified surveillance and best execution analytics can support your oversight goals? Contact us to schedule a brief discussion.