OTC Link amends MOON ATS overnight rules for SIP data, LULD and Rule 201

OTC Link LLC, the New York broker-dealer that operates MOON ATS, filed a material amendment to its Form ATS-N with the SEC on 9 Nov (accession 0001491895-26-000021, file number 013-00200). The cover statement says the changes “impact all subscribers and are applicable to OTC Link as ATS operator”. It does not name an implementation date.

MOON already runs an overnight book in NMS stocks. The current Form ATS-N, last updated on 29 Jul, says operating hours are “from 7:30 P.M. to 4:00 A.M. E.T.: Sunday to Thursday (ending Friday at 4 A.M. E.T.)”, with orders “only executable from 8:00 P.M. to 4:00 A.M. E.T.”.

What the amendment would change

The cover statement lists six changes:

• Live SIP data overnight. Part II, Item 6(b) would add “a third-party service provider that will supply Securities Information Processor (SIP) data during MOON’s overnight trading session”. The statement does not name the provider.
• LULD-style reference bands. Part III, Items 11(c) and 23(a) would be updated so that “the ATS’ reference price bands will be updated to mirror the limit up-limit down band methodology used in the NMS Plan”.
• Enforcement while the SIP is open. The ATS “will enforce Limit Up-Limit Down (LULD) reference prices published by the SIP during the overnight hours the SIP is operating between 9:00 P.M. E.T. and 4:00 A.M.”
• Rule 201 short-sale rejections. The ATS “will reject short sale orders in an NMS Stock that triggered a short sale circuit breaker pursuant to Rule 201 of Regulation SHO”.
• Faster trade reporting. Trades “occurring between 8:00 P.M. and 9:00 P.M. ET” would be reported “by 9:15 P.M. ET”, and trades “occurring between 9:00 P.M. ET and 4:00 AM ET” would be reported “within 10 seconds of execution”.
• SIP regulatory messages. The ATS “will utilize certain regulatory information provided by the SIPs in connection with its operation (e.g., limit up-limit down bands, short sale circuit breaks and trading halts)”.

How that differs from the current Form ATS-N

The 29 Jul form still describes a venue that works off prior-day SIP last-sale prices and reports in a batch once FINRA’s trade reporting facility opens in the morning.

On price bands, MOON “institutes a risk control that rejects buy orders priced more than twenty percent (20%) above the reference price and sell orders priced more than 20% below the reference price”. That reference price “is the last sale price of the security from the prior Regular Day’s session as reported by the SIP feeds (CTA and UTP) and is used solely for risk control purposes”. The broker-dealer operator uses OneMarketData, LLC to supply that SIP last-sale data. The 9 Nov cover statement does not say whether OneMarketData, or another vendor, would be the new overnight SIP provider.

On short sales, the current rule is the opposite of the amendment. The July form says: “In the event a short sale circuit breaker pursuant to Rule 201 of Regulation SHO is triggered during regular trading hours, MOON still accepts and processes short sales because the NBBO is not available during MOON operating hours.”

On reporting, trades are still sent to the Nasdaq TRF “after the TRF accepts trade reports beginning at 4:00 A.M. E.T. on the next trading day” and “must be reported by 4:15 A.M. E.T. following the opening of the TRF”.

The 23x5 context

The amendment lines up with the market-wide move to 23-hour trading, under which the SIPs are due to operate from 9:00pm ET on Sunday to 8:00pm ET on Friday, with a one-hour pause from 8:00pm ET Monday to Thursday, and overnight LULD bands are due to apply from 9:00pm to 4:00am ET (our report, LULD overnight bands). Both timetables are aimed at 6 Dec, subject to remaining approvals and SIP readiness.

The new reporting split matches that clock. From 9:00pm to 4:00am ET, when the SIPs and the TRFs are expected to be open, MOON would report within 10 seconds. Between 8:00pm and 9:00pm ET, when MOON is already open and the SIPs and TRFs are due to be in their nightly pause, prints would wait until 9:15pm ET.

Rule 304 of Regulation ATS requires a material amendment to be filed “at least 30 calendar days” prior to the date of implementation. The Commission may also declare a Form ATS-N amendment ineffective no later than 30 calendar days from filing. The cover statement does not give a start date, so the rule’s 30-day notice period is the only timing on the public record. Counted from 9 Nov, that period runs to 9 Dec, after the 6 Dec target for the SIPs and the exchange overnight sessions.

Why it matters

Analysis. MOON is already in the overnight NMS-stock market, and it starts an hour before the exchanges’ planned 9:00pm ET session. The amendment would bring its overnight controls into line with the new SIP and LULD regime rather than leaving it on prior-day last-sale bands and a 4:15am reporting cut-off.

Two changes will be felt on the desk once the amendment is in force. First, short-sale handling reverses: a stock that has triggered a Rule 201 circuit breaker would see short-sale orders rejected, instead of being accepted because there is no overnight NBBO. Second, trade reporting moves from a next-morning batch to 10-second prints once the SIP is open, with a 9:15pm ET backstop for the 8:00pm–9:00pm hour. Subscribers, vendors and clearing firms will need FIX, market-data and TRF workflows that can consume live SIP LULD bands and short-sale messages, and that can report in real time rather than at 4:00am.

The filing date also matters. Because this is a material amendment, OTC Link cannot implement the changes until at least 30 calendar days after 9 Nov, unless a later filing changes that timetable. If the SIP overnight feeds and the exchange sessions start on 6 Dec as planned, there could be a short period in which those systems are live but MOON is still operating under the July form.

What we are watching

• Whether the Commission declares the amendment ineffective, and when OTC Link states an implementation date.
• The identity of the third-party firm that will supply SIP data during the overnight session, once the full Form ATS-N text is public.
• How MOON handles the 8:00pm–9:00pm ET hour, when it is open and the SIP is not.

Sources

• Form ATS-N/MA, accession 0001491895-26-000021, OTC Link LLC, 9 Nov 2026
• Form ATS-N/UA, accession 0001491895-26-000016, OTC Link LLC, 29 Jul 2026
• 17 CFR 242.304(a)(2)(i)(A), Form ATS-N material amendments