THE ETHICS REPORTER

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Regulatory

All the PFOF Reform Proposals That Have Failed: A Complete Record

A comprehensive record of PFOF reform proposals, their status, and why they failed to become effective policy.

SEC Proposals

SEC Chair Gensler 2022-2024 market structure reforms: Order Competition Rule (never finalized), tick size reforms (partially adopted), access fee reforms (modified). None addressed structural PFOF conflict.

Congressional Proposals

Multiple bills have been introduced to restrict or ban PFOF since 2021. None have passed committee. Key opponents received Griffin political contributions.

State Actions

Massachusetts: $7.5M Robinhood settlement (2020). Other states: minimal specific PFOF enforcement actions. Federal inaction continues to leave state action as the only viable path.

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