SEC Proposes Rescission of Regulation NMS Rules 611 and 610(e); Firms Should Monitor Market-Structure Implications

- What the source says:

According to the SEC press release description, the Commission proposed amendments to rescind Rules 611 and 610(e) of Regulation NMS and commented that Rule 611 has had unintended consequences that warrant review. The statement in the source frames the action as a regulatory proposal to remove those specific rules from Regulation NMS.

- Why this matters to CPA firms:

Changes to market-structure rules can ripple into areas that CPA firms audit, advise, or use for valuation and reporting. Firms auditing broker-dealers, investment advisers, or clients whose valuations and liquidity depend on trading venue behavior should flag the proposal because altered execution, routing, or quoting dynamics could affect market data, fair-value measurements, and assumptions used in financial statements.

- Operational and labor implications:

If the rescission moves forward, firms may need to reassess audit procedures that rely on market-data stability, including the selection of price sources, testing of fair-value models, and confirmation procedures. Preparing for potential change requires monitoring rulemaking, scenario planning, and possibly reallocating technical staff to evaluate impacts on audit evidence and client disclosures.

- Risk, judgment, and economics:

The proposal raises forward-looking regulatory risk: uncertainty about future trading behaviors can affect clients' liquidity management and pricing models, increasing professional-judgment demands on auditors and advisors. Practice leaders should brief teams and clients, consider contingency plans for affected engagements, and evaluate whether additional training or external expertise will be needed to address new market-structure realities.