On October 31, 2025, the Securities and Exchange Commission (SEC) issued an order providing temporary exemptive relief from specific compliance dates outlined in Regulation NMS (National Market System). This relief pertains to recently adopted amendments concerning minimum pricing increments, access fee caps, and transparency mandates for superior-priced orders. 

Delayed Compliance Dates: 

The SEC has extended the compliance deadlines for the following rules: 

• Rules 600(b)(89)(i)(F) and 612 (Minimum Pricing Increments): Compliance is now required by the first business day of November 2026. 

• Rule 610(c) (Access Fee Caps): Compliance is now required by the first business day of November 2026. 

• Rule 610(d) (Determinability of Exchange Fees at Execution): Compliance is now required by the first business day of February 2026. 

Furthermore, the SEC has granted temporary exemptive relief to national securities exchanges from the obligation to file proposed rule changes to update exchange rules reflecting the revised round lot definition under Rule 600(b)(93). This relief will remain effective until 30 calendar days after the end of the lapse in appropriations. 

Impact on Investment Advisers and Broker-Dealers: 

This exemptive relief directly impacts broker-dealers and exchanges, as it postpones the implementation of critical market structure changes related to pricing, fees, and order transparency. 

While Regulation NMS does not directly impose compliance obligations on investment advisers, it is important for advisers to stay informed about these changes. Understanding these developments from a best-execution and market-structure standpoint is crucial, as they can influence trading conditions and execution outcomes through broker-dealer counterparties. Investment advisors should engage with their broker-dealer counterparties to understand how these delays will affect their trading strategies and execution quality.