Davis Polk partner Zach Zweihorn was quoted in Risk.net discussing potential roadblocks delaying the implementation of 24-hour trading in the U.S.

The article noted that four exchanges (24X, the New York Stock Exchange, Nasdaq and Cboe) and Securities Information Processors (Sips) – which collect and consolidate the data required to calculated national best bid/offer quotes from U.S. exchange trades – are subject to Regulation Systems Compliance and Integrity that requires certain critical market infrastructure be robust and well tested.

“I think they are going to want to make sure they do adequate testing and to make sure these things all are working together well to not have operational challenges when they go live,” Zach said.

The article also suggested that reduced SEC headcount could further contribute to delayed timelines as the exchanges are required to have regulatory reviews to move forward. “Certain people who used to be at the SEC who would have been involved in this [are no longer there],” Zach said.

“There were some pretty senior as well as down-the-line staff that look like they took the buyout offers and left,” he added. “[Amending exchange rules] takes time because they need to file those amendments with the SEC and get the SEC to approve. [That process] can be dragged out as far as 240 days if the SEC uses every extension that it has available to it.”

However, Zach noted, “There’s a statutory timeline the SEC has to work to on rule filings regardless of staffing levels. It may be tougher, but they’ll get it done.”

“Is 2027 the new 24-hour trading target?, Risk.net (September 2, 2025) (subscription required)

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