The Texas Stock Exchange (TXSE) commenced trading last week, showcasing the operations of a new national securities exchange seeking to compete with Nasdaq and the New York Stock Exchange. As this story from Houston Public Media notes, the TXSE initiated a phased rollout that will take place over the course of July. During this initial testing phase and going forward, equity securities of companies that are listed on other exchanges will be traded on the TXSE under the concept of “unlisted trading privileges.” This Goodwin Public Company Advisory Blog entry notes:

The Texas Stock Exchange (TXSE) commenced quoting and trading securities pursuant to unlisted trading privileges on July 6, 2026, and the new national securities exchange intends to commence trading of other securities on the exchange in the coming weeks. The TXSE published a trading launch schedule identifying securities that will begin trading on the exchange in the coming weeks.

A security may begin trading on the TXSE pursuant to unlisted trading privileges without any action by the issuer. Under Exchange Act Section 12(f), a national securities exchange may trade a security that is listed on another exchange on an unlisted trading privileges basis. The SEC has provided guidance confirming that a national securities exchange may generally extend UTP immediately to any exchange-listed security, subject to a limited IPO timing exception set forth in Exchange Act Rule 12f-2. Under unlisted trading privileges, a security can trade on an exchange while retaining its primary listing on the exchange where that security is listed. The commencement of trading on the TXSE pursuant to unlisted trading privileges does not change an issuer’s primary listing, transfer its listing to the TXSE, or alter its ongoing obligations to its primary listing exchange.

Why it matters

The commencement of trading on another national securities exchange may cause some concern, because companies have taken no action to facilitate such trading. In this regard, it should be noted that trading pursuant to unlisted trading privileges occurs without any action on the part of the issuer of the securities, and the issuer of the securities generally cannot object to the trading on the exchange. This contrasts with the process of listing on an exchange, in which case the issuer of the securities would file a registration statement with the SEC and a listing application with the exchange.

Practical takeaway

For investor relations and other purposes, public companies will typically monitor their trading activity across markets and exchanges. Companies included in the TXSE trading launch schedule may wish to notify their investor relations and communications teams in advance and consider whether to develop an investor relations and/or public relations response when trading commences on the TXSE. Companies should be prepared to respond to investor, analyst, or media inquiries regarding the commencement of trading and recognize that such trading does not reflect a decision by the issuer to list its securities on the TXSE.

It will be interesting to see what listings the TXSE will attract now that it is operational. In addition to initial listings, the TXSE also contemplates dual-listed securities, where a company’s stock would be listed on the TXSE in addition to the New York Stock Exchange or Nasdaq. It should also be noted that Nasdaq Texas and NYSE Texas recently launched their exchanges and companies can dual-list their securities on those exchanges, as Meredith noted in her blog post back in March.

– Dave Lynn