Welcome to the September edition of The Monitor, our monthly look at the evolving trade compliance and analytics landscape.
This month, we take a closer look at how firms are preparing for the SEC’s upcoming Rule 605 amendments. Many are now reviewing their processes and systems to avoid any last-minute compliance scrambles that could come with the new compliance requirements.
We’re also seeing surveillance programs expand their scope as markets evolve. Extended 24/5 trading is prompting teams to adapt their oversight to ensure it remains effective around the clock.
At the same time, crypto continues to raise unique oversight challenges. Systems need to evolve to flag behaviors associated with crypto market abuse, ensuring surveillance frameworks can extend to digital assets without losing rigor.
Finally, we’ll share what’s on our regulatory radar, from Rule 605 enhancements to the SEC’s ongoing work around digital assets.
Taken together, these developments continue to highlight the need for integrated, flexible tools. Firms that can simplify regulatory demands, surface actionable insights and adapt quickly will be best positioned to stay ahead in today’s dynamic market environment.
I hope you find this issue both timely and useful as you navigate what’s next for trade compliance and analytics.
– Lisa Balter Saacks, President at Trillium Surveyor
Trading Newsbeat
Anticipated 605 Updates: From Shares to Notional Buckets
The SEC’s expected changes to Rule 605 would replace share-based order buckets with notional-based categories, a shift that could reshape how execution quality is measured and reported. Firms are already running simulations on historical data to understand how venue performance, price improvement, and fill rates might redistribute under the new framework.
While final specifications aren’t yet released, firms should consider whether their current data capture systems and vendors are adaptable to incoming changes. Even modest preparation now can help.
24/5 Market Access: Adjusting for After-Hours Dynamics
As more firms expand trading hours beyond the traditional day session, risk and performance profiles are shifting. After-hours markets often have thinner liquidity, wider spreads, and more volatility, all of which can impact both execution outcomes and surveillance alerts.
Trading and compliance teams should assess whether their current oversight frameworks account for these differences.
We recently spoke with Wedbush about the operational challenges of 24/5 trading. As early adopters in extended-hours markets, both Wedbush and Trillium Surveyor have firsthand insights into what it takes to operate and oversee trading outside traditional hours.
Read the full conversation here: https://trilliumsurveyor.com/trillium-surveyor-wedbush-lessons-from-the-frontlines-of-24-5-trading/.
Crypto Markets: Expanding Surveillance for New Asset Classes
As trading activity grows in digital assets, firms are facing unique surveillance challenges. Crypto markets operate 24/7, are more fragmented, and often exhibit greater volatility than traditional markets. These factors can increase the risk of manipulative activity and unusual trading patterns.
Leading firms are adapting by adding crypto-specific monitoring to identify behaviors such as wash trading, spoofing, and price manipulation. Building these capabilities into existing frameworks can reduce false positives while keeping oversight effective across asset classes.
Regulatory Radar
- Rule 605 Enhancements Coming Soon
Be prepared for expanded reporting requirements, including odd lots, fractional shares, and time-to-execution metrics. Expected compliance date: December 14, 2025. - SEC’s Project Crypto, Compliance in Digital Markets
The SEC’s launch of Project Crypto signals a more innovation-friendly approach to digital assets, including tokenized securities and streamlined broker-dealer oversight. The initiative also emphasizes clearer classification of digital assets and modernized custody rules, aiming to reduce uncertainty for firms operating in blockchain-based markets. - 24/5 & Crypto Trade Surveillance, Staying Ahead
Market hours are no longer limited to the traditional trading day. As trading stretches across global time zones and into digital assets, firms need surveillance that keeps pace. Around-the-clock coverage and crypto-specific monitoring are becoming essential to stay protected in always-on markets. - Regulation Best Execution Withdrawal
The SEC’s withdrawal of its proposed Best Execution framework underscores that there’s no ticking mandate yet firms with strong, documented execution oversight will still be rewarded.
Poll: False Positive Tagging
Did you know you can tag alerts as false positives on Surveyor Trade Surveillance to help us better refine our logic and increase meaningful output?
Once tagged, we systematically improve how our alerts work. This makes your surveillance more precise while continually reducing noise.
Even if you’re not a Surveyor client yet, we’d still love your perspective.
Do you currently use false positive tagging in your surveillance program?
- Yes
- Not yet, but planning to
- No
- Not sure what this means [message us to learn more!]
Products and Services
Best Ex Surveyor – Feature Highlight
Best Ex Surveyor is a powerful best execution analytics engine designed to simplify complexity. It transforms raw trade data into clear, actionable insights through instant calculations and intuitive visualizations. The result: firms can not only meet regulatory requirements but also elevate execution quality and generate measurable ROI through smarter, data-driven routing decisions.
Daily Analytics
Unlike quarterly reports that look backward, Best Ex delivers daily analytics across key factors such as trade price, speed, associated costs, and probability of execution. This cadence enables faster adjustments, sharper oversight, and more confident decision-making in today’s fast-moving markets.
Why it Matters
With SEC Rule 605 enhancements on the horizon and scrutiny around execution quality intensifying, firms can no longer afford to rely on slow, manual reviews. Best Ex Surveyor equips trading and compliance teams with the timely, granular visibility needed to demonstrate defensibility, identify opportunities for price improvement, and align strategies with both regulatory and commercial goals.
Our Social Calendar
Team Surveyor saddled up and kicked off event season in Dallas at the Texas Traders Convention! A few key takeaways:
- Clearing and settlement delays for 24/5 trading: real-time clearing may not arrive until 2027. Firms that invest in surveillance today will be better prepared.
- Digital assets testing infrastructure limits: scalability is constrained without consolidated data and clearing improvements.
- Retail crypto evolution and regulatory focus: customer adoption is diversifying, while regulators signal more clarity ahead.
- Regional shifts in market centers: Texas is emerging as a capital markets hub with the planned TXSE and growing investment in digital assets and AI.
Coming up next, we’d love to connect in person if you’ll be at:
STA Georgia • FINRA Small Firm Conference • STA Annual Market Structure Conference • NSCP Conference • Carolina STA 2025 Annual Conference• FIA Expo
Let’s Connect
Curious how Surveyor can help your firm overcome your unique challenges and meet your goals? Contact us here and we’ll set up some time to discuss. Contact us here and we’ll set up some time to discuss.
