In this special edition of The Monitor, we’re giving trading teams and compliance leads a focused set of tools and insights to navigate what’s shaping up to be a pivotal moment for best execution.
Inside, you’ll find key considerations surrounding the SEC’s proposed updates to Rules 605, a checklist to benchmark your firm’s readiness, and a first look at our next-generation, best execution analytics engine.
June marks a critical turning point for trading desks and compliance leads as the December 15th deadline to comply with the SEC’s amended Rule 605 is fast approaching. These changes significantly expand execution quality disclosure requirements, which makes it even more essential for firms to provide transparent, data-backed reporting on how their orders are handled. With just six months remaining, firms must urgently lock in analytics vendors, finalize internal workflows, and prepare for compliance.
Beyond meeting regulatory demands, we’re seeing a shift in how firms are approaching best execution operationally to meet increasing expectations around speed, transparency, and scale. Today’s firms are leveraging technology to surface insights faster, reduce prep work, and support smarter decision-making across increasingly complex trading environments.
In speaking with best execution committees and trading teams, one theme was clear: legacy systems aren’t keeping pace with the way teams work today.
It’s why we’ve re-engineered our best execution analytics engine to enable trading teams to drive growth with their trade data and unlock measurable ROI.
We’re excited to share what we’ve learned and as this new standard for execution and transparency emerges, we hope this issue helps you navigate what’s next.
– Lisa Balter Saacks, President at Trillium Surveyor
Trading Newsbeat
With Rules 605 and 606 in mind, here are some considerations we’re seeing across the industry, especially as firms rethink best execution in light of new transparency and performance expectations.
Reframing Execution Quality
Previous iterations of Rule 605 categorized trades into “size buckets” based on the number of shares or contracts traded. However, this approach can impact how firms and regulators evaluate execution quality, especially for low-volume and high-value stocks. It also can make it difficult to compare execution quality across different asset classes.
The December 2025 amendments to Rule 605 are due to recategorize trades based on their total monetary value instead. This will, in theory, make the impact of trades easier to evaluate.
From a best execution perspective, this could offer broker dealers a more granular view of how well they are achieving execution quality across different value thresholds and a broader range of order sizes and asset classes.
Yet, this also raises the bar for firms’ internal processes. Many will need to revisit how they analyze trade data and adapt their review procedures to align. As the deadline approaches, firms should begin evaluating analytics tools that are evolving to support this change.
Industry Eyes Public Access to Execution Performance
We’ve observed growing trend that is beginning to take shape across the industry, one where firms may start leveraging their execution performance data as a strategic competitive advantage. (Source)
As regulators push for greater market transparency, new proposals aim to make execution data more accessible. One major development is FINRA’s March 2025 proposal to adopt Rule 6152, which would require broker-dealers subject to SEC Rule 605 to submit monthly execution reports for centralized publication on FINRA’s website, free of charge and open to all.
The goal is to enhance regulatory oversight and make execution quality data easily accessible to investors, academics, and firms seeking to compare performance across the industry.
This transparency could fuel a new kind of “performance war.” Firms might begin marketing metrics like average price improvement or cost savings per share to highlight their execution edge, for example, touting $0.003 per share in price improvement versus peers or saving clients $0.015 per share on average.
While this may initially benefit large market makers, it also opens the door for niche or specialized firms to stand out, especially if they can demonstrate clear execution advantages in specific asset classes.
As execution data becomes publicly visible, performance could become a core part of how firms differentiate and build trust with clients.
Rule 605 Checklist
With Rule 605 changes fast approaching, there should be one question on your mind: How prepared is my firm? If you’re unsure, we’ve created a handy checklist for you to assess how prepared your organization is for December:
Have you tested your historical trade data through the new lens?
Are you prepared for fractional orders, overnight trading, and other nuances under amended rules?
Do you have a compliance technology partner with tools supporting these transitions?
Products and Services: Surveyor Reinvents Best Execution Analytics Engine
Surveyor’s best execution analytics engine is built for teams that want faster insights, smarter decisions, and real performance gains. This isn’t just an update. It’s a complete reinvention. So, if you know Surveyor for its best-in-class trade surveillance, we invite you to take another look.
Empowering trading teams with performance-driven technology for:
- Daily (not quarterly) monitoring of best execution performance
- Fast identification of trends by order type, venue, and more
- Clear visualizations to reduce slippage and improve routing
- One-click access to performance insights, no manual data prep
- A shared view that eliminates silos between traders and compliance team
Our Social Calendar
Let’s look back at some of the recent events that the Surveyor team attended in June.
We had a fantastic time hosting members of our community at a Chicago Cubs game! It was a perfect day for baseball and connecting with our clients, we even got to sport our favorite hats.
On June 11, we were delighted to attend the Women in Digital Assets Forum where prominent women shaping the digital asset space led thought-provoking conversations on market trends, regulatory clarity, and the future of trading and compliance.
Some key takeaways:
- The debate about institutional adoption of crypto is over; institutions are here and are increasing their participation.
- Regulatory clarity is advancing. The Genius Act (short for Guiding Uniform and Innovative National Standards for Digital Assets) is a bipartisan bill aimed at establishing clear regulatory definitions and frameworks for digital assets in the U.S. It seeks to clarify the roles of the SEC and CFTC, provide consumer protections, and support responsible innovation.
- TradFi vs DeFi remains complex. Interoperability between traditional finance and decentralized systems is still a work in progress.
- The secondary market is still forming. It’s an essential part of the value chain, but it remains underdeveloped. As it matures, there’s an opportunity to borrow best practices from traditional finance to strengthen investor protection and compliance frameworks.
ICYMI: Watch for Insights into 24/5 Trade Surveillance Risks
Why is 24/5 trading gaining momentum, and what risks come with it?
In an episode of At the Forefront, Surveyor and Blue Ocean Technologies break down their recent strategic partnership, the rising demand for extended-hours trading, key compliance concerns, and how firms are preparing for the future of round-the-clock markets.
