Regulator Keynote: New Developments in US Market Structure – Update from the SEC: Session Recap: Key Takeaways from Commissioner Hester M. Peirce at Equities Leaders Summit 2026

2026, Equity Leaders Summit. Regulator Keynote: New Developments in US Market Structure – Update from the SEC

Announcer: Jesse, I'm gonna let you come in place. Do the intro. How are you? Nice to see. How are you? Nice to you. Very well. Very well. Good morning. Wonderful to see you in person. Thank you for joining us in person this year. Thank you.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Right,

Jesse, I'm gonna hand it over to you ladies. Gentleman, please if you are and then take it away.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Sure. Would you like

Speaker 3: how

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): close

Announcer: are you today? Here?

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Yeah,

Speaker 3: hi, everyone, please take your seats. Our next session is about to begin. We have a wonderful keynote with the commissioner from the SEC. Please take your seats, everyone.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): That's funny. So Chris,

Announcer: last night, excuse me, told, sorry. Ladies and gentlemen, please, you are front and center, like you said, asked.

Thank you. Take your seats. We have a very honored guest with us this morning.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): No imposter syndrome today.

They are a roussy crowd this morning. I wonder why. It must be the travel. It must be the travel. We

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): got the rock star here.

Snow crazy.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Alright, everybody be quiet. Shut up everybody. Thank you.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: All

done.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Thank you. Good morning everybody. Welcome to day two. Hi. We're starting. Everybody ready in the back. Thank you. Good morning. Oh, a couple more people are trickling in here. Hi, Dave. Dave wanted a shout out to us. Everybody wants pictures with you. By the way, has anybody ever seen an SEC commissioner?

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Surrounded by people who wanna take selfies. That's happened this morning. I told you when you came down here. We are so happy you were here. Somebody last night at cocktail hour. It wasn't Chris, but I was with Chris when somebody said it was the happiest regulatory regime ever. If it was you, raise your hand please.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): 'cause I really forgot who said it, but I sent myself an email from the bar last night. Oh, I'm with you. With this morning with Commissioner Hester Purse. Everybody knows right? If you do not know who she is, you are at the wrong conference last year. When you were here virtually with us, I'm super excited that you're here in person.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): You had just kicked off the crypto task force. Alright, here are here we are. A year later. You're here with us in person. Now the SEC is clearly moving full steam ahead with this agenda. This is a conference of equity leaders, asset managers, broker dealers, fintechs in here. Why should they be on board?

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): What benefits are they gonna see? In short what's in it for them.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Sure. Jesse, thank you. And it's a delight to be here with you all. I'm glad that people were able to make it despite the snows and other parts of the country. So I do have to start with my disclaimer, which is that my views are, my own views as a commissioner are not necessarily those of the SEC or my fellow commissioners.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: My fellow commissioners now are more aligned with me. I will say probably than, than has been the case in the past which I think is really wonderful. Chairman Atkins mark Uda and I all worked together before when he was last at the SEC, so it's nice to have the band back together in terms of crypto, it is obviously a very small market compared to what you all deal with on a day-to-day basis, and so I think it's a fair question to ask.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Okay, why why is it relevant? But so the, a couple things. One is just a procedural thing. The way we approached crypto in the past at the SEC was procedurally really bad. We were writing rules through enforcement actions. We were strategically ambiguous is how someone has described what we did using regulatory ambiguity to try to chill.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Development in crypto, that is not a good thing for a regulatory agency to do. And it does not set a good precedent for how we might act in other areas. So I think part of what we needed to do is roll that back, say we're having a fresh start here. We're gonna try to work through some of these difficult legal policy, technical issues by inviting people to come and talk to us.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Having those conversations, hearing from people many of whom are not happy with with the direction the SEC might go. But having this mix of voices so that we can get to the right place. And I think that will set a good precedent for us moving forward in other areas as well, to make sure that we're talking with people as we write regulations.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: So second is one of the big areas of interest. Has been tokenized equities and that surprised me a little bit. Not I knew there was a lot of interest in it, but the level of interest in tokenizing equities has been much higher than I anticipated. And so I think tokenization is coming to your markets.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: It's gonna start slowly. Of course there are some small scale experiments going, but, I think that it probably is coming and it will raise some interesting questions, some of which I'm sure Jesse's gonna ask me.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Yeah, I had three more just from that alone. Okay, so let's dive into tokenization, what exactly from a regulatory perspective does the SECD to accomplish this year? People wanna trade tokenized securities in 2026, right? What for wide, for people to be, for the market participants in this room and others to be comfortable with a widespread adoption. Like what exactly do you need to do?

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: I think part of it is just letting people do experiments and so we saw DTCC came in and got a no action letter so that people can trade tokenized security entitlements, basically. Others are interested. Other exchanges, NASDAQ NAS are interested in tokenized. Securities. So part of it is just working with people who are trying to figure out how to do this.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: What does it look like? Where do they need exemptive relief? We're also working with Native, I would characterize them as crypto natives who are thinking about how they can facilitate trading of equities and including in defi, which raises some very interesting and difficult questions. There is tokenized.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Equity trading going on, some of it is happening outside the us and is specifically geoblocking us investors. And there's a reason for that. I think part two of what we need to do is explain. Or make sure that people are explaining to the people that are selling these tokenized equities to what exactly they're getting.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Because there are different models for doing this and. Some models give you just the same rights that you would have if you were any other kind of equity holder. Others are you're buying something but you're not actually buying the underlying equity. And so I think part of what we're trying to do too is make sure that's clear and that people have thought that out and that we understand how.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: What will happen if there's an insolvency? What will happen if, you know who gets to vote? How does that work? So I think there, there are issues like that, that we're working through.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Alright. And I guess we wanna avoid some sort of bifurcated market, right?

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: So that's a big issue that people have raised.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Markets are really great at arbitraging, so even if you have separate. Pools of liquidity. There are people who can figure out how to merge those two together. But you don't wanna be in a situation where a tokenized equity is trading very differently from the normal equity.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: And one of the reasons that could be is if you have counterparty risk that's unique to the tokenized equity, there might be a real reason to have the price differential. But I think that we hope to get to the place where that is one pool of liquidity.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): So for that we're also have to presume some fungibility

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Yes.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Then too. That makes sense. Awesome. You probably could have predicted the next topic, dad joke. So on Friday coalition Greenwich is gonna be publishing our first study on prediction markets. Where we went out to 50 market participants, many people in this room, buy side, sell side and fintechs.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): And we asked a couple of questions, Hey, what do you think of them? Favorable, unfavorable. So we had about 40% to kill the lead. To kill the surprise. About 43% said favorable. About 38% said neutral, just under 20% negative and only 2% undecided. So it seems like there's some strong nobody doesn't have a view.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): And there's an overall favorable view. So I guess from the, from the outset though, prediction markets tend, at least in theory to rely on a bit of inside information or participants who feel they have an inside edge. Like how do you reconcile that with the SEC's mandate of fair and orderly markets?

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Is that a concern?

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Yeah, I think prediction markets are really interesting and I, mention them, I think first in a, in my, a descent on the climate rule because I think that prediction markets can help us get all kinds of information. And so if you're imposing a climate disclosure mandate, actually you might need to rely on prediction markets for some information.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: So I think at a base level, they can be really good ways of drawing people's knowledge in and. Putting it in a place, in a form that the rest of us can rely on that knowledge. So that leads to the issue that you're raising, which is maybe people are taking knowledge that they're not supposed to be making public through their prediction market bets. And maybe they're putting that into the marketplace. I think fundamentally that's an issue that goes to a person's relationship with her employer if that's where she's getting the information from. Employers should have rules saying you can't.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: If that's what they feel they should have rules saying you can't trade on prediction markets. Certainly for government officials, I think we don't really want government officials getting wealthy by, by trading on prediction markets. So you could have rules there as well, but I'm not sure that issue is really a predictions market issue as much as an employment issue.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: I have the same reaction often in these insider trading cases that we bring. The employer has a policy that says you can't trade on inside information. And that first and foremost, when someone engages in insider trading, that is a violation of the relationship with the employer. Or if it's, someone stealing his wife's information it's a violation of their marital agreement.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: But so I feel like. When we focus on prediction markets and say, this is terrible that this information is getting out there. We're really focusing on the wrong thing,

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): isn't she great? So then, all right, so let's take it one step further though. All right. Let's just pull on this thread for a minute.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): So forget about the prediction market itself, right? The data generated from these prediction markets. If then you have investors pulling from this data, and then let's say trading equities or futures using. Data, underlying data from a prediction market, which maybe we could agree is predicated on a bit of an inside view.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Is that a concern? Not so much trading the market, but then taking data

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: from Yeah, I guess you could spin up a theory an insider trading theory that was based on that. But once it's in the prediction markets, it's out in the public. So I think that's a little bit hard to make that case. I, first of all, I will say we're not trying to regulate the prediction markets generally, although there may be pieces of prediction markets that do fall within the SEC's jurisdiction. Most of the actions so far has been at the CFTC and state reg, state gaming regulators saying, Hey, we might have a piece of this and maybe it should be in the states.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: So that needs to get sorted out in the court. There again, when it relates to issuers there may be a case for us to regulate them. And that might be an interesting part of the SEC's agenda going forward.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Thank you. I just realized, and they only gave us 20 minutes, and we're down to eight, so we gotta move along here.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Can we talk about the OPR round table?

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Yeah.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): So we had some questions around there. Is it repealing or modifying gonna be more difficult? And people think, or is there some irrational exuberance around this to use a

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: I think there's never too much exuberance over repealing OPR

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): yes,

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: but

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): you guys heard her say that.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Right?

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: But that said, my, my mind is still open. We haven't, we're, we haven't even gotten to the proposal stage. I think these round tables have been very helpful in laying the groundwork for potentially. Modifying or repealing OPR and I've actually been surprised at how open people are to the idea that, yeah, even if they thought the OPR was necessary at some point, they don't think it is needed now.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: And I've been encouraged that while there are some difficult questions people seem to think that it can be done. You just need to take into account. Are there other changes that we have to make, sort of companion changes that we have to make? I actually think the round table showed us that people are willing to engage.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: People are ready to engage on it and it's not it impossible a task as maybe it had seemed to be before.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): And, everybody is ready and willing and eager to engage.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Everyone's trying to figure out a new way to make money, I assume.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): No, they have an SEC that listens to them.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: I think there's also some of people are figuring how can I be better off if we do this now? It is good that we have an SEC that listens. I think that's really important. It goes back to that first question about process, right? And we had some pretty sweeping equity market structure.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Reforms proposed under Chairman Gensler and there was, I think, a little bit of an abdication of the responsibility of doing this kind of engagement. And the industry itself was putting on round tables. I really am happy that now we're in the mode of really wanting that input. And so with that, my door is open.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: I'm not prejudging the issue. If some of you have concerns about repealing OPR, you should come talk to us. Come talk to me. I'm all ears.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Yeah. I think after the chairman's, I'll just say it, after his disastrous appearance at the Bloomberg conference, I don't think anybody wants to see that guy up on stage ever again.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): That was just, he was just so rude. So anyway, going back to that fungibility thing, I'm not the only one who feels that way, right? Was anybody here? He was such a. No. Anyway, he was a, I'm not gonna say it 'cause you're here.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: No swearing please.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): No swearing. No, I'm not gonna swear in front of you. Yesterday there was some swearing going on.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): I was very nervous about this. I was telling the people yesterday, anybody who was in the buy-side day yesterday, I was telling 'em I had raging case of anxiety and imposter syndrome about being up here with you today.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Find out. As it turns, find out. As it turns out that you're doing fine.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Thank you.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: And you, I

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): wrote that down here again too. You're doing fine, Jesse. That's what this says. See that? She said I'm doing fine. All right.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: And as it turns out, you didn't even swear, so that's, I didn't even swear, but I go to crypto conferences so I've heard all the words.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): We have some new ones in our lingo, but anyway, so going back to this point, we got a couple more minutes. All right. Real quick, this was actually a specific question from somebody who. I better be in the room 'cause I'm asking this question. Going back to that fungibility, right? How do we reconcile then trading, let's say like apple off exchange, token tokenized when trading the traditional within the NBBO, right?

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Do we need an NBBO or do we have an NBBO without six 11? Do we need six 10?

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: So I think people have been raising that issue. We've gotten a lot of letters coming into the SEC from some traditional players who are. Already very angry because they think that things are working fine and there's no need for tokenization.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: And tokenization does raise these kind of issues around NBBO. So I think as we craft experiments for people to try to trade and tokenized securities, we need to think about the fungibility. We need to think about the interaction of those markets, and we need to think about. How someone with a best execution responsibility is going to approach the fact that they're tokenized equities and that they're standard equities.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: And what does that look like? Now, there is data, good data that comes out. When something trades on chain. The data is there, people can see it, people can pull it off and analyze it, and so someone will be able to take the data and use it, and put it in a form that enables people to rely on it.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Whether that figures into the official NBBO, that's a question. And so I think we start out small. We're we start the experiment small and then figure out how that's working and then we can move on from there. I think the issue that people are pushing back on us on is they don't think anyone should get any exemptive relief.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: But as we know, when you're trying something new, the SEC's statutes envisioned that there would be exemptive relief. That's how we've gotten to different developments in our markets, and so I think that is a reasonable approach to take. We're going to be careful about how we do it though.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Awesome. Thank you.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): I think we have two minutes, so I have one more question then we'll get to a question or two if anybody's got you touched upon it. Earlier in your first response, something that people come to us come to me about and my team is what happens if all this stuff gets unwound.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Yeah.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): How are you laying the, I know you've spoken about this before, but can you just do a minute of reassurance?

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Yeah. I think we're trying to, we're trying to adopt rules in a durable manner. We're trying to do it, in a way that will last. And I think if we get to a good place and people see that the markets are working well, they won't change the rules.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: One we're living in an age of great division in this country, but. There is something that we all can agree that we care about, and that is we have really wonderful capital markets. Thanks to the work of people like you. Our markets function really well and they serve our country very well. And so let's not politicize those markets, let's let those markets be markets that can serve everyone.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: And I think if we can do that successfully. A new administration, regardless of the politics of that new administration, is going to say, we wanna keep those equity markets functioning well and they won't change it.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Thank you very much. I think we're just at it. Do we have any questions? Mr.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Kanar, please? Commissioner. Oh, Dan's getting a microphone. One sec. Just so everybody else can hear.

Audience: Where's the

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): question mark? Kepner right here. Third row.

Thank you. When it comes to tokenization, has there been any discussions with the underlying public companies? Have they had any input and what has that possibly been?

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: That's a great question and I and it's one that we're thinking about too. I, people are tokenizing now equities that without the issuers, and then there are other people who are doing it with the issuers. I think as we think about experiments, we're thinking about. Issuer permissioned experiments because it will, like the, for the reasons Jesse raised we do think about how those liquidity pools interact.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: It will affect the trading of the issuer's securities. So I think that's how we're thinking about starting out with issuer. Permissioned. You have ADRs and there isn't always issuer permission there, so that is a comparable thing to think about, but. We really, I, and I think there will be issuers who wanna see this.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: There already are, but I think there'll be more who wanna try tokenizing their equities.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Alright Ms. Streets runs a tight ship, so we are gonna, I know Mike, you to get off stage.

• Commissioner Hester M. Peirce, US Securities and Exchange Commission: Thank you all very much. Thank you Justin.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Thank you so much Commissioner. Big round of applause please for

Announcer: you.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): No, for you.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): Thank you so much.

Thank you very much indeed. So much. Thank you. I'm sorry to cut, I had to cut you short, so it's always my job.

• Jesse Forster, Head of Equity Research, Market Structure & Technology, Crisil Coalition Greenwich (moderator): I hope your

other

conferences.