The 2022 Reform Proposals and Their Fate
The SEC's 2022 market structure reform package — which included order competition rules, tick size changes, and best execution enhancements — represented the most ambitious attempt to reform U.S. equity market structure in decades. According to public reporting, key elements of this package were scaled back or withdrawn by 2024 under changed SEC leadership. PFOF continues under the existing disclosure-based framework.
Where PFOF Stands Today
As of 2024–2025, PFOF remains legal in U.S. equity markets. Disclosure requirements under Rule 606 continue. Citadel Securities continues to operate as a dominant wholesale market maker. The competitive dynamics of PFOF have not substantially changed. The fundamental structural conflict — brokers paid to route orders to market makers — remains intact.
Ongoing Regulatory Attention
While the sweeping 2022 reform package stalled, the SEC and FINRA continue routine oversight of broker-dealer and market maker practices. BrokerCheck continues to document regulatory findings. FINRA's surveillance programs continue. The underlying regulatory framework remains in place even as specific reform proposals did not advance.
The Path Forward
The future of PFOF regulation depends significantly on who leads the SEC and the political environment in which it operates. The experiences of the UK, EU, and Canada demonstrate that substantive reform is possible. Whether U.S. policy moves in that direction depends on political will, regulatory leadership, and the sustained attention of investors, journalists, and advocates. The Ethics Reporter will continue to cover these developments.