MFA supports the measured transition toward 23/5 trading, but the Commissions should treat any further move to 24/7 trading as a separate and significantly more consequential policy decision. In particular:
- 23/5 trading is a reasonable next step. The developing market-data, trade-reporting, clearing, volatility-control, surveillance, and operational framework is designed to support a phased expansion while preserving a defined maintenance window, but its performance has not yet been demonstrated under live, market-wide overnight conditions. The Commissions should allow that framework to operate and mature before considering continuous trading.
- 24/7 trading presents different and more significant risks. Further expansion should depend on demonstrated liquidity and market quality.
- The full market ecosystem must be ready. Trading venues cannot move to continuous operation in isolation.
- The Commissions should proceed incrementally and in coordination. The agencies should monitor the 23/5 rollout, establish objective measures of performance, address identified gaps, and undertake a separate, data-driven evaluation before permitting a move to 24/7 trading.
- Participation should remain voluntary.
