Welcome to the October edition of The Monitor.
This month took our team from New York to D.C., Orlando, and Chicago with plenty of great conversations along the way. I really enjoyed speaking at the PREDICT conference about the importance of behavioral context and market integrity needing industry collaboration.
We rounded out the month at NSCP and FINRA Small Firm, connecting with compliance leaders on everything from preparing for extended trading hours and the growing role of AI to strengthening their oversight programs.
At STA, best execution was in focus, from the recent Rule 605 changes and Rule 606 reporting accuracy to the potential changes to Rule 611. As firms navigate these developments, having tools that simplify best execution oversight and make it easier to evaluate performance is becoming increasingly valuable. That’s a theme we’re exploring in this month’s Monitor, including how eliminating manual data preparation, instant calculations, and benchmarking can help firms adapt as requirements evolve.
Thank you to everyone we connected with this month. I look forward to continuing the conversations!
— Lisa Balter Saacks, President, Trillium Surveyor
Surveyor Product Perspective
Benchmarking: Putting Execution Quality into Perspective
We’ve enhanced Surveyor’s Best Execution Analytics benchmarking capabilities and user interface, making it easier for firms to compare execution performance against industry and internal benchmarks, set thresholds, and receive alerts when performance falls outside them.
Additional capabilities help firms analyze execution quality and make informed routing decisions:
- Order-Level Analysis: Drill down to individual orders to understand what drove an outcome and the factors behind execution performance.
- Advanced Filtering: Analyze execution quality using full depth-of-book data across order type, size, notional value, entry firm, security type, listing exchange, venue, and more.
- Instant Calculations: Access built-in calculations and intuitive visualizations without manual data preparation, with analytics available daily between formal review cycles.
- Regulatory Reporting: Generate Rule 605 reports in one click and manage Rule 606 data collection and report verification through an interactive portal.
Want to learn more about Surveyor Best Ex’s capabilities? Connect with our team.
Regulatory Radar
- SEC Rule 605-Additional Reporting Requirement Takes Effect November: Beginning November 1, 2026, firms subject to Rule 605 must begin collecting information to calculate price improvement relative to the best available displayed price, incorporating odd-lot order information. The first reports containing these statistics, covering November activity, must be publicly available by the end of December. This follows the broader Rule 605 amendments that took effect in August. (Source: SEC)
- Have you checked the accuracy of your 606 report? With greater attention on execution quality and routing practices, firms should take a closer look at the accuracy of their Rule 606 reports. Common issues include misclassified execution venues, incorrect order types, and incomplete order populations. Firms should review vendor-generated reports against their own records and ensure their verification procedures are documented. (Source: Rule 606 Perspective)
- Overnight Trade Reporting Moves Into Testing: FINRA announced on October 2 that its Trade Reporting Facilities (TRFs) are open for extended-hours testing, with weekend testing sessions running through December 4. The TRFs are scheduled to move to 23-hour operations on December 6, bringing new considerations for how firms manage trade data, surveillance, and best execution reviews during overnight hours. (Source: FINRA)
- CFTC Proposes Clarifying Event Contracts as Swaps: On October 9, the CFTC proposed explicitly including event contracts tied to sports, politics, culture, and weather in the definition of “swap.” A companion interim final rule excludes traditional casino-style gambling and sportsbook wagers from that definition. Together, the actions aim to clarify the regulatory distinction between federally regulated event contracts and gambling products overseen by state and tribal authorities. (Source: CFTC)
Market Structure and Compliance Trends
Featured Perspective | Check the Accuracy of Your 606 Report
Rule 606 reporting has been a longstanding requirement, but accuracy deserves a closer look. Common mistakes, from misclassified execution venues and order types to incomplete order populations, can raise questions about the reliability of a firm’s disclosures.
In our latest Perspective, we explore five common reporting mistakes and practical steps firms can take to strengthen their review and verification processes.
Read the Perspective: Check the Accuracy of Your 606 Report →
NSCP 2026: Key Compliance Topics and Our Perspective
The NSCP National Conference agenda addressed a range of challenges facing compliance teams, from emerging technologies to changing market structure. Here are three topics that stood out to our team and our take on each.
1. Trade Surveillance Modernization
The topic: How firms can evaluate the effectiveness of their surveillance programs, manage regulatory change, and adapt their oversight as markets evolve.
Our perspective: Context is critical to effective trade surveillance. A change in trading behavior doesn’t necessarily indicate suspicious activity. Understanding what’s normal for a participant, considering the market conditions at the time, and incorporating lessons from previous investigations can help compliance teams better distinguish activity that warrants further review from activity that can be reasonably explained.
2. AI & Compliance Technology
The topic: How AI and GenAI can improve compliance efficiency, alongside considerations around governance, validation, and human oversight.
Our perspective: Focus on practical applications of AI in compliance. We’re particularly interested in how AI can make it easier for teams to access and analyze their data. For example, AI-powered querying could allow compliance professionals to ask questions directly of their data rather than navigate multiple filters and reports. As firms explore these applications, explainability, validation, and human oversight remain important considerations.
3. Prediction Markets & Market Integrity
The topic: How firms should approach potentially non-public information, compliance risks, and market integrity as prediction markets expand.
Our perspective: Understanding trading behavior is especially important in prediction markets. Event timing, information availability, and activity across related contracts can all provide important context when evaluating potentially unusual trading. Looking at a participant’s historical win rate alongside trade timing and size, and considering activity across related markets and products, can help compliance teams identify patterns that warrant further investigation.
FINRA Small Firm Conference: Practical Oversight for Smaller Teams
The FINRA Small Firm Conference focused on the regulatory and compliance challenges facing smaller broker-dealers, where teams often manage multiple responsibilities with limited resources.
Our perspective: Effective oversight needs to be manageable for smaller compliance teams. As trading hours expand and market conditions change, firms need to ensure their surveillance and best execution reviews remain effective. Prioritizing activity that warrants attention, reducing unnecessary manual work, and maintaining clear investigation records can help smaller teams manage oversight without adding operational complexity.
Poll
What’s your firm’s biggest challenge when it comes to best execution oversight?
- Manual data preparation
- Evaluating execution quality
- Rule 605/606 reporting accuracy
- Keeping up with regulatory changes
Participate in the community poll here.
Our Social Calendar
Recent Highlights | PREDICT 2026
It was great to be part of PREDICT in New York! Our President, Lisa Balter Saacks, joined industry leaders for a panel on market integrity, surveillance, and trust in prediction markets. The discussion explored the importance of behavioral context and industry collaboration as these markets continue to grow.
Where to Find Us Next
New York City
- FIX Americas Trading Conference | October 29
- TabbFORUM Best Execution Symposium | November 2
Heading to one of these events? Reach out to set up time with the Surveyor team in person.
In the News
TradingTech Insight | The Surveillance Challenge Behind an Increasingly Continuous Market
Our Director of Markets & Operations Strategy, Rob Cope, spoke with TradingTech Insight about the surveillance challenges emerging as markets move toward 24/5 trading, prediction markets expand, and AI takes on a greater role in compliance.
Prediction News Network | Lisa Balter Saacks
Lisa joined Prediction News Network for a conversation about prediction markets and market integrity.
Let’s Connect!
As your markets and oversight needs evolve, let’s talk about how Surveyor can support your surveillance and best execution program. Connect with our team →