SIPs Submit Exemption Request Related to Dissemination of Odd-Lot Depth of Book

The Securities Information Processors Are Moving Ahead with Adding Odd-Lot Data to the Tapes, but Request a Two-Year Delay for Adding Depth of Book

NEW YORK, Aug. 14, 2025 /PRNewswire/ -- The CTA/CQ and UTP Operating Committees ("Committees") today announced that they have submitted to the SEC a request for a temporary exemption from certain requirements set forth in amendments to Regulation NMS adopted by the SEC in Release No. 34-101070 ("SEC Amendments").

In the SEC Amendments, the Commission directed the SIPs ("Securities Information Processors") to collect and disseminate certain odd-lot quote information, including odd-lot bids and offers that are priced at or better than the National Best Bid and Offer ("NBBO"). The Committees are requesting a temporary two-year exemption (to May 2028) from the requirement to disseminate odd-lot quotes beyond each Participant's best odd-lot bid or offer quotation for each NMS security.

Pursuant to this approach, beginning by May of 2026, the SIPs would disseminate top-of-book odd-lot quotations priced at or better than the NBBO, including:

(1) the best odd-lot bid and offer across all Participants ("BOLO"); and
(2) the best odd lot bid and offer from each Participant.

The requested delay is in response to the aggressive implementation timeline: The SIPs, exchanges, and market participants all need to develop, test, and implement a number of complex changes (see list below) and adding depth-of-book odd-lot quotations would increase both complexity and associated risks.

Requiring the dissemination of odd-lot depth-of-book quotations also carries considerable economic implications for market participants. For instance, market participants that consume SIP data will incur development expenses related to the integration of depth-of-book odd-lot quotations. In addition, there will be ongoing technology costs associated with handling increased message traffic. These costs will be borne by all SIP subscribers regardless of whether they want or need this data.

Additionally, the initiatives described above will require significant involvement from the data recipient community.  Specifically, data recipients are faced with back-to-back changes from the SIP, including . . .

• The incorporation of fractional share trading data.
• Implementation of the amended "round lot" definition on or before November 3, 2025.
• The potential transition toward 24-hour SIP operations.
• The need to potentially accommodate a transition to half-cent tick sizes for many stocks, as adopted by the Commission last year as part of the NMS Amendments.
• Infrastructure expansion to handle growing market data traffic.

The regulatory landscape governing the U.S. equities market is undergoing profound changes, with the SIPs facing an unprecedented number of concurrent obligations and enhancements to the operation of the SIPs.  The Operating Committees believe that simplifying the odd-lot release in accordance with the exemption request will reduce the burden on the data recipient community as it prepares for these various initiatives.

Since the Operating Committees do not know if the SEC will grant exemptive relief—or when that determination will be made—they have instructed the Processors to continue with the Odd Lots project assuming that depth of book data will be required day one.  Industry participants are encouraged to do the same.

The full exemption request can be found here, on the CTA/CQ website.

About the SIPs

The "SIPs" (Securities Information Processors) link the U.S. markets by processing and consolidating all protected equities bid/ask quotes and trades from every registered exchange and FINRA's Alternative Display Facility (ADF) into a single, easily consumable data feed. The SIPs are an asset unique to U.S. market structure and play a critical role in making the U.S. equities markets transparent and accessible to investors worldwide.

Although often referred to in the singular, there are actually two SIPs: the combined CTA (Consolidated Tape Association) and CQ (Consolidated Quotation System) SIP, and the UTP (Unlisted Trading Privileges) SIP. The CTA/CQ SIP is responsible for the dissemination of real‐time quote and trade information in New York Stock Exchange listed securities (sometimes called "Network A" or "Tape A" securities) and Cboe, NYSE Arca, NYSE American, and other regional exchange listed securities (sometimes called "Network B" or "Tape B" securities). The UTP SIP handles Nasdaq-listed securities (sometimes called "Network C" or "Tape C" securities). This structure has been in place since the late 1970s, when the Securities and Exchange Commission ("SEC") mandated that all registered exchanges that trade Network A, B, or C securities send their trades and quotes to the SIPs for consolidated worldwide distribution.

Each SIP is governed by a Plan and run by an Operating Committee ("OC") comprised of its Plan Participants. The OCs are counseled by an Advisory Committee made up of individuals representing firms from across the industry and representing the diverse viewpoints of the market. Among other duties, the OCs set their individual Plan policies, select a Processor that is responsible for providing the technology to power it, and review the performance of both the Processor and the network administrators, which are responsible for the administrative functions for each SIP, such as contracting, billing, auditing, policy development, and vendor relations. The New York Stock Exchange serves as the Administrator for the CTA/CQ SIP Plans and the Securities Industry Automation Corporation is the Processor. Nasdaq business units serve as the Administrator and Processor for the UTP SIP.

One of the primary objectives of both SIPs is transparency. Both the CTA/CQ Operating Committee and UTP Operating Committee meet quarterly, and the summary of the General Sessions of those meetings are posted to their respective websites: www.ctaplan.com and www.utpplan.com. Also provided on those websites are their Plans' announcements, policies, quarterly and monthly performance metrics, the pricing schedules, technical specifications, and more. 

Media Contact
Rafi Reguer
Forefront Communications for the SIP Operating Committees
+1 (718) 781-4946
[email protected]

SOURCE SIP Operating Committees