Rulemaking at the U.S. Securities and Exchange Commission is a public process. Proposed rules and roundtables are opened for comment, and every letter the Commission receives becomes part of its permanent public file. Andy Altahawi takes part in that process on regulations now under discussion in the public discourse.
His comment letters are collected below. Each entry summarizes the position the letter takes and what it recommends, and each links to the full letter exactly as filed with the Commission, as a PDF on sec.gov that anyone can open and read.
The Trade-Through Rule and Locked and Crossed Markets Provisions of Regulation NMS
The rulemaking. The Commission has proposed rescinding two pillars of Regulation NMS: Rule 611, the Order Protection Rule, which bars trading centers from executing trades at prices inferior to protected quotations displayed on other markets, and Rule 610(e), which restricts locked and crossed markets.
The letter. Mr. Altahawi opposes the rescission and asks the Commission to withdraw the proposal, or at a minimum to defer it until an enforceable replacement for intermarket price protection has been adopted and tested. Writing from his experience as a former market maker and broker-dealer principal, he argues that quote protection is what makes displayed liquidity worth providing; that the proposing release itself acknowledges retail investors could receive worse prices while wholesalers gain; that best-execution duties are a supervisory standard rather than an order-by-order price guarantee; and that unpoliced locked and crossed markets would degrade the reference price on which new listings and thinly traded securities depend.
If the Commission proceeds anyway, the letter asks it to:
- adopt an objective, enforceable best-execution standard for retail-sized orders before any rescission takes effect;
- preserve trade-through protection for displayed retail-sized limit orders;
- phase implementation and publish data on execution quality, displayed liquidity, and locked and crossed conditions; and
- stand ready to reintroduce targeted protections if displayed liquidity or retail execution quality deteriorates.
Roundtable on Preparations for 24-Hour Trading
The roundtable. Ahead of its September 17, 2026 roundtable, the Commission invited public statements on what moving U.S. equities toward round-the-clock trading would require of the national market system.
The letter. Mr. Altahawi’s written statement strongly supports 24-hour trading and urges the Commission to treat the roundtable as the start of a rulemaking rather than the end of a discussion. He argues that the 9:30-to-4:00 session is an operational artifact of an earlier market; that foreign exchange, equity index futures, and crypto markets already trade around the clock; that automated quoting, continuous risk monitoring, and machine-learning surveillance have removed the staffing constraints that once justified limited hours; and that investors in the Gulf, Asia, and Europe are effectively shut out of the U.S. trading day. Continuous trading is already arriving at the edges of the market, he writes; the question is whether it arrives inside the regulated national market system or outside it.
The letter asks the roundtable to settle, at a minimum:
- a single authoritative closing price and reference-price convention;
- overnight volatility safeguards equivalent to Limit Up-Limit Down;
- liquidity and quoting standards for overnight sessions;
- disclosure conventions for news and earnings releases in a market with no overnight pause;
- resiliency requirements and consolidated market data for every operating hour; and
- a phased rollout beginning with the most liquid securities.
Electronic Delivery of Information Under the Federal Securities Laws
The rulemaking. Proposed Regulation E-Delivery would make electronic delivery the default for disclosure under the federal securities laws, while preserving every investor’s right to receive paper on request, at no cost.
The letter. Mr. Altahawi strongly supports adoption. Drawing on the years his multi-office broker-dealer spent printing and mailing prospectuses, trade confirmations, and proxy materials, he argues that the paper default is a leftover of a pre-internet market that costs issuers and investors without protecting anyone; that electronic documents are better disclosure, not merely cheaper, because they can be searched, enlarged, translated, and analyzed with AI tools; that the proposal’s free, permanent opt-out answers the concerns of investors who prefer paper; and that paper delivery is a recurring cost of being a U.S. public company, especially for foreign issuers.
To strengthen the rule, the letter recommends that the Commission:
- adopt the opt-out default as proposed, without document-by-document carve-outs;
- require that a failed electronic delivery trigger prompt fallback to paper;
- keep the opt-out one step, free, and permanent until changed;
- pair electronic delivery with machine-readable formatting requirements; and
- treat the rule as a bridge to an “access equals delivery” framework for EDGAR-filed documents.
Regulation Crypto Assets
The rulemaking. Proposed Regulation Crypto Assets would give crypto asset offerings a framework written for them under the federal securities laws: a startup exemption, a Regulation A-style fundraising exemption, an investment contract safe harbor with a public exit filing on Form TR, and qualified-purchaser preemption for covered instruments.
The letter. Mr. Altahawi supports prompt adoption, with one substantial reservation: the proposal would limit the fundraising exemption to issuers organized and principally run in the United States. Drawing on his cross-border work structuring foreign issuers for U.S. markets, he argues that the restriction would not bring crypto projects home; it would leave U.S. investors buying the same assets with no Commission-filed disclosure at all. He recommends admitting foreign issuers on conditions built from the Commission’s existing foreign-issuer framework: filing on EDGAR in English, appointing a U.S. agent for service of process, presenting U.S. GAAP or IFRS financial statements with Tier 2 audits by a PCAOB-registered firm, bad-actor disqualification that also reaches home-country sanctions, and an identified person responsible for the filings.
The letter also recommends:
- keeping the startup exemption open to issuers worldwide, conditioned on a U.S. agent for service of process, and allowing it to reach $10 million where reviewed financial statements are filed;
- confirming that registered broker-dealers may sell and deal in covered investment contracts, and publishing an EDGAR status record for each subject crypto asset;
- defining “essential managerial efforts” in rule text, separating completion filings from cessation filings on Form TR, requiring disclosure of related-person holdings and lock-ups at exit, and adding a thirty-day effectiveness period; and
- addressing Regulation S offerings and integration expressly.
About these letters
The Commission publishes every comment letter as received, and each remains permanently available in the public file for its rulemaking on sec.gov. The letters express Mr. Altahawi’s personal views on proposed rules and Commission initiatives.