SEC Stock Exchanges: Same Old Form, No Thrills
Published Date: 1/9/2026
Notice
Summary
The SEC is asking self-regulatory organizations (like stock exchanges and clearing agencies) to keep filing their rule changes using Form 19b-4. This helps the SEC review and decide if these changes are safe and fair. No big changes or extra costs are planned, but the SEC wants your comments before extending this paperwork process.
Analyzed Economic Effects
6 provisions identified: 0 benefits, 6 costs, 0 mixed.
SEC extends mandatory Rule 19b-4 filings
The SEC is proposing to extend the paperwork collection under Rule 19b-4 and Form 19b-4, and compliance is mandatory. The agency estimates the total annual burden for all respondents is 92,876 hours and the total estimated external cost burden is $1,270,500.
Ongoing filing, posting, rulebook update burdens
Each SRO filed about 41 proposed rule changes on average in 2024; each filing takes about 41 hours. The SEC estimates the annual burden for filing proposed rule changes is 75,645 hours, posting proposals to SRO websites is 7,380 hours, updating online rulebooks is 4,496 hours, and preparing notices when postings are late is 17 hours.
Security-based swap submission costs for clearing agencies
Two security-based swap clearing agencies are estimated to submit 13 Security-Based Swap Submissions each year, with each submission taking about 140 hours, for a total of 3,640 hours. The SEC estimates outside legal costs for these submissions will total $720,720 annually. Two clearing agencies also may incur a one-time 30-hour website update (10 hours annualized).
Advance Notice burdens for clearing agencies
Designated clearing agencies must file Advance Notices of material rule or operations changes; the SEC estimates each designated clearing agency will file two Advance Notices per year, each taking about 90 hours, for a total of 720 hours across four designated clearing agencies. The Commission estimates outside legal work for those filings will total $147,840 annually.
Time and legal costs for stays of clearing requirements
Under Rule 3Ca-1, clearing agencies are estimated to submit four applications for stays of a mandatory clearing requirement per year, taking about 18 hours each (144 hours total for two clearing agencies). The SEC estimates outside legal costs for the two clearing agencies at $32,340 annually and that counterparties will incur outside legal costs totaling $369,600 annually.
EFFS training and internal policy drafting burdens
Respondents must train staff to use the Electronic Form 19b-4 Filing System (EFFS) and draft internal policies. The SEC estimates two anticipated national exchanges will spend about 60 hours training (20 hours annualized) and 260 hours drafting policies (87 hours annualized), and that all 45 respondents will spend 10 hours each year training staff (450 hours total).
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