SITREP #010 · WEEKLY SITUATION REPORT · 14–20 SEP 2026

The Busiest Hour Has No Tape

The FOMC hiked 25 bp to 3.75–4.00% on a 12–0 vote, the first increase since 2023, and used the September SEP to erase the 2027 easing path that June still showed. The SEC roundtable confirmed that 21 percent of overnight volume trades in the 8-to-9 PM hour, which stays ATS-only and off the consolidated tape after December 6. The same day, the Commission issued a five-year conditional Innovation Exemption for tokenized NMS stock. Three venues ran $19.4B for the week, up 20 percent.

Sapinover Intelligence · Sunday, September 20, 2026 · Overnight figures computed from the three-venue pipeline; FOMC statement and SEP from the Federal Reserve; roundtable from SEC transcripts and the OAR staff memo; market closes from Yahoo Finance; filings read at source on SEC EDGAR.

00BLUF

//The Stack

Five layers of market plumbing, and where each one stands this week. Click any layer for the detail.

01The Tape

Five sessions, Sunday through Thursday. Sunday's trade date is September 14 and ran heavy at $6.20B across three venues, consistent with every post-weekend Sunday session this year. The four weeknight sessions averaged $3.31B.

Notional in millions. Moon reported zero on Sunday (expected for a Sunday session) but reported every weeknight. BlueOcean ran $15.40B for the week; the total three-venue figure was $19.4B against $16.2B the week before, +19.8%.

The semis basket

Semis share rose slightly from last week's 43.0% to 45.8%, ranging 37.0% to 51.6% across the five nights. Memory eased from 25.0% to 16.9%. This is the first full week with SOXL back. The basket pinned in #005 is unchanged.

The names underneath

SOXL led the tape at $1.87B, its first full week back after the fair access halts ended September 10. MU ($1.33B) and SNDK ($1.10B) held the next two spots. The top ten is semis and index wrappers, the same pattern as every week since #005. KORU and TQQQ tied at $465M.

02The Busiest Hour

The SEC held a roundtable on 24-hour trading preparations on Wednesday, September 17. Commissioner Peirce titled her remarks “Stock Around the Clock.” Chair Atkins, Commissioner Uyeda, and Trading & Markets Director Jamie Selway also spoke. Selway noted Peirce is winding down her tenure.

The finding that most changes the published overnight work: the 8:00 to 9:00 PM ET hour is the single busiest hour of the overnight session, and it is exactly the hour with no consolidated tape. Dan Matheson of the Office of Analytics and Research, presenting the staff memo data: volume is heavily front-weighted, the first ten minutes is the largest bucket, the first hour carries 21 percent of overnight volume, and “8 PM to 9 PM is their biggest hour by far.” After December 6, the SIP runs 9 PM to 8 PM. That hour stays ATS-only and off the public tape.

What else came out

• LULD reference price moved 7:45 PM to 7:30 PM. The Operating Committee amended it days before the roundtable so ATSs trading 8 to 9 PM can apply the same 20% band. Reference is the official close combined with the 7:30 consolidated last sale.
• Exchanges intend to route to ATSs during the 8-to-9 window and outside SIP hours. 24X: “three out of four looks like they're gonna allow us to route to them.” ATSs do not route to each other.
• Citi is not going live December 6. Wait-and-see into 2027, citing code freezes and that tech budgets were set before a SIP date existed. Counterweight to the “green lights everywhere” framing.
• Bruce confirmed our figures. Across BlueOcean, Bruce and Moon, August 2025 was 22.2M shares and $1.2B a session; August 2026 is ~108M shares and ~$5B a session. Our tape gives 108.0M shares and $4.99B over 21 dates. Independent validation.
• Citadel Securities on overnight market quality: spreads 2 to 3x regular session; median depth $15,000 on the contra side against a median order of $800; two thirds of executing orders arrive non-marketable, against ~25% in the regular session.
• Robinhood: 1,300+ eligible symbols, cumulative $289B notional and 41M trades since July 2023.
• DTCC: ~25% of members participate overnight; more than $15B and 200M shares cleared since real-time submission began mid-July.

The OAR staff memo (File 4-913, September 10) is the data underpinning all of this. August 2026: 0.9% of total NMS share volume, 144.6M shares per day, 4,208 names trading daily on average, top ten names are 43.4% of overnight share volume. Foreign accounts: 37% of overnight share volume. And in footnote 2: Sunday-evening ATS trades are TRF-reported but SIP-suppressed. Our three-venue tape can see Sunday because we take venue data directly.

Who trades overnight (CAT, Q2 2026)

Table 5 of the OAR memo breaks volume by account holder type. Each trade is attributed to both buyer and seller, so the row sums exceed 100%. The first column pair is shares; the second is dollars.

Overnight is structurally different. Foreign accounts are the largest share-volume participant at 37%, three times their regular-session share. Market-makers lead in dollar terms at 29%. Institutional accounts, which dominate regular hours at 30%/35%, are the smallest overnight category at 7%/14%. The gap between share and dollar shares tells you that foreign flow skews toward lower-priced names (37% of shares but 24% of dollars), while market-maker flow concentrates in higher-priced names (19% of shares, 29% of dollars).

Only 118 executing broker-dealers participate overnight, versus 1,104 in the regular session. 67 introducing firms. That is 10.7% of the regular-session executing universe. The overnight session is a small-firm, concentrated market running on a handful of participants.

03The Fed Restarted

Meeting September 15–16; statement and SEP at 2:00 PM ET September 16. Target range raised 25 bp to 3¾–4 percent. Vote 12–0. IORB set at 3.90% effective September 17. Chair is Kevin Warsh; he did not submit a dot. This is the first rate increase since July 2023.

Statement tone. Short and blunt. Activity “expanding at a solid pace,” domestic spending “resilient,” labor “kept pace,” unemployment “changed little.” Inflation is simply “elevated.” The Committee dropped earlier language that had attributed elevated inflation in part to supply shocks, a shift from “this is a shock we wait out” to “this is a policy problem.”

September SEP vs June (medians)

Source: official September 16 SEP tables.

The 2027 revision is the hawkish core. June still had 50 bp of net easing next year. September has no net easing through 2027. That is not a “one and done” plot.

Dot distribution (18 submitters). 2026 year-end: 12 dots at 4.125% (one more hike), 4 at 4.375% (two more), 2 at 3.875% (stop here). 16 of 18 want at least one additional 25 bp this year. 2027 median still 4.1%; about eight participants at 4.375%. Longer-run nudged to 3.2%.

How to read it. The hike itself was fully priced. The information was: unanimity after a split at July, deletion of the supply-shock alibi, a 2027 median that no longer embeds cuts, and Warsh's “timelier return” framing. Street takes split between “one more in December, then hold” and “this is the start of a short recalibration, not a 2022-style cycle.”

Political overlay, not the reaction function. Reuters and others note Trump continues to argue for lower rates. The Committee hiked anyway, unanimously, under a Warsh chair. That is the relevant institutional fact for the next two meetings (October 27–28, no SEP; December with SEP). October is one week before the midterms; several desks already assume a hold then and a live debate in December.

04Markets

Week ending Friday, September 18 (triple witching).

Only two of eleven S&P sectors finished green: Health Care ~+1.83% and Technology ~+1.03%. Utilities were the worst (~−3.0%), then Financials (~−2.4%), Real Estate (~−2.1%). Rate-sensitive cyclicals and balance-sheet names ate the hike; a handful of large tech and healthcare names carried the cap-weighted index.

Breadth on Friday. Advance/decline was 1,658 up / 2,807 down, about 1,150 more decliners than advancers while the S&P closed green. Volume exceeded 26 billion shares, ~40% above the 12-month average. That is expiry mechanics plus a weak tape underneath a firm index.

Triple witching (Friday, September 18). About $7 trillion of U.S. options notional expired, second-largest on record (Citadel Securities). Index options, single-stock options and index futures rolled off two sessions after the Fed. Treat Friday's +0.17% as low-information.

Rates. The 10-year tested 5% on Monday, printed as high as ~5.04% Tuesday, the highest since 2007. Path around the Fed: Sep 15 close ~5.00%, Sep 16 ~5.01%, Sep 17 4.94% (−7 bp as oil eased), Sep 18 back to ~5.00–5.01%. The 2-year rose +13 bp on the week to ~4.76%. Bear-flattener: front end did more of the work. Next test: ~$183 billion in 2s/5s/7s auctions this coming week.

Oil. WTI: Sep 15 close $105.83 (week high $106.75), then three down sessions to Friday $100.30, −1.58%. Still ~$100 on Middle East supply risk. Softening late-week oil is what let the 10-year slip to 4.94% Thursday; Friday's rebound in yields came as crude stayed three-digit.

VIX. 17.71 Wednesday (FOMC) to 15.44 Thursday to 14.81 Friday. Implied vol faded as fast as the statement was digested. VIX 14.8 after the first hike in three years and a 5% 10-year is a statement that the market thinks the Committee is predictable. That is only true until the next CPI/PCE or an oil spike.

Cross-asset. Dollar index ~100.2, +~1.1% on the week. Gold held the mid-$4,300s. Bitcoin cleared $80k–$81k into the Innovation Exemption. BOJ hiked to 1.25% (31-year high) on the same calendar.

05Innovation Exemption

On the same day as the roundtable, the Commission issued a temporary, conditional exemptive relief order under Exchange Act §36(a)(1):

• Tokenized Securities Venues (TSVs) are exempt from the “exchange” definition when they operate permissioned AMM liquidity pools in tokenized NMS stock.
• Certain liquidity providers (“Covered Firms”) are exempt from the “dealer” definition when they supply those pools.

Conditions flagged in the Chair's statement and the press release: TSV must be a U.S. person, OFAC/sanctions compliance, gated access, no synthetics, tokenized shares carry the same rights as the listed stock, issuer opt-out, notice/transparency/books-and-records/ tech-safeguard conditions, symbol and volume caps tied to LULD tiers. Relief is time-limited (five years from publication) and paired with a request for comment.

Atkins framed it as a workaround after the Senate failed to advance the CLARITY Act this week, and as a step in “Project Crypto.” Peirce: observe how on-chain and traditional markets interact before durable rulemaking; DeFi/permissionless peer-to-peer is outside this order.

06Disclosure

No new cover-page-only ATS-N filings this week. The seven outstanding from last week remain. No venue filed a restated form to absorb any of them.

IntelligentCross still has three material amendments outstanding against its July 24 restated form: SOR pass-through (Aug 17), overnight trading session (Aug 31) and random match priority Hosted Pool (Sep 9).

07Forward Calendar

• This week. ~$183B in Treasury coupon auctions (2s/5s/7s). A tail at 5%+ on the 10-year would confirm the level; a stop-out well through the when-issued would ease the equity duration hit.
• Oil path around $100. A close back through the midweek $105–107 area reopens the “more than one more hike” tail in the dots.
• Sep 30. Amended Rule 605 wave one. First monthly execution-quality reports. Amended 605 still excludes not-held orders.
• Sep 30. August PCE, the first full inflation print after the hike.
• Oct 2. SIP UAT weekends begin. Six weekends through December 4 over production multicast channels.
• Oct 27–28. FOMC (no SEP). One week before midterms. Pricing mid-50s for another hike; most desks expect a hold. Statement language on inflation will matter more than the decision.
• Innovation Exemption. Watch which issuers opt out and whether volume caps bind.
• Dec 6. SIP 23x5 production launch. The overnight data gap closes.

The rail

08Get SITREP

##Sources

SITREP is a weekly situation report on market structure. Overnight notional figures reflect Sapinover's overnight pipeline and are not comparable to full-market consolidated volume. This analysis is for information only and is not investment advice, a recommendation, or a solicitation. For methodology see the support page.