Davis Polk counsel William Tong discussed the new share trading platform Private Intermittent Securities and Capital Exchange System (PISCES) and its potential with International Financial Law Review (IFLR).

William notes that with PISCES, “The opportunity here is to get a first-mover advantage by being one of the first law firms to advise companies and investors participating in the process.”

Discussing how companies will control when the intermittent trading windows in their shares will be open and who can buy and sell within those windows, William explained, “We have highlighted to certain investor clients that the existing shareholders’ agreements relating to their investments are unlikely to contemplate PISCES as an option for exit. They will need to consider how to initiate this process contractually because they don’t have that right under the PISCES rules and in these agreements. Investors consider PISCES to be a helpful option for the sell-down of their stake but are surprised that this is company led.”

Additionally, William addressed the future outlook for PISCES, mentioning that investors of various kinds will be watching to see if it is for them. “We have mature fintech companies looking to IPO in the next couple of years in the US or in the UK. We’ve been assisting them with pre-IPO funding rounds, and often as part of this process, there is sometimes the flexibility for founders and employees to start selling down to institutional investors looking to benefit from the IPO when it happens. These clients will be very interested in seeing how PISCES could be used and what advantages it offers in comparison to what they currently do, which is to do so on a contractual basis, rather than through a marketplace,” he said.

“Greenlight for PISCES brings potential for more private company work,” IFLR (October 28, 2025) (subscription required) 

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