Rialto Markets and the Evolving Discussion Around Exchanges and ATSs
In her December 17, 2025 statement, SEC Commissioner Hester Peirce outlined a request for information focused on the regulatory treatment of national securities exchanges and alternative trading systems, including questions related to crypto asset securities and trading pairs. The statement reflects ongoing consideration of how existing market structure rules apply to evolving trading models, while maintaining investor protection and orderly markets.
Rialto Markets operates as a FINRA-member broker-dealer, runs an SEC-registered digital Alternative Trading System (ATS), and maintains an affiliated digital transfer agent. These registrations reflect an operating model that functions within the current regulatory framework applicable to broker-dealers, ATSs, and securities recordkeeping.
Rialto’s ATS is approved to support secondary trading and matching of securities, including digital and tokenized securities, in accordance with Regulation ATS and applicable SEC guidance. The broker-dealer registration permits participation in private market transactions subject to FINRA oversight and other applicable rules. The affiliated transfer agent supports issuer and shareholder recordkeeping functions and is structured to accommodate securities represented in both traditional and digital formats, including tokenized representations recorded on distributed ledger technology.
Taken together, this construct is consistent with the market structure considerations referenced in the SEC’s recent request for information, including the operation of regulated trading venues, the interaction between different types of market participants, and the treatment of securities in evolving asset classes, such as crypto asset securities and trading pairs involving non-security assets (including stablecoins). Rialto has operated with this structure prior to the current regulatory dialogue and continues to engage within the existing framework as these discussions develop.
As regulatory agencies evaluate potential changes or clarifications to exchange and ATS rules, Rialto’s experience operating across broker-dealer, digital ATS, and transfer agent functions provides practical context for how trading, settlement, and ownership recordkeeping can be implemented within existing regulatory requirements in private and digital securities markets.
Digital market participants operate under a range of regulatory models and licensing structures, depending on their activities and jurisdictions. Rialto Markets operates as a FINRA-member broker-dealer, SEC-registered Alternative Trading System (ATS), and maintains an affiliated transfer agent, each subject to applicable regulatory oversight.
As the SEC seeks feedback and evaluates potential changes or clarifications to its approach, including questions related to ATSs and crypto assets, institutions and advisors are focused on understanding existing regulatory frameworks. Rialto Markets’ experience operating within regulatory framework applicable to broker-dealers, ATSs, and transfer agents illustrates how digital securities may be supported within regulated capital markets.
This material is provided for informational and educational purposes only and does not constitute an offer, solicitation, or recommendation to buy or sell any security or to engage any particular service. References to regulatory frameworks, market structure, or digital securities reflect current discussions and are subject to change based on future regulatory developments. Rialto Markets, LLC is a FINRA-member broker-dealer and operates subject to applicable federal securities laws and regulations.