Comment Letters addressing regulation stemming from the May 6, "flash crash," specifically, letters pertaining to automated and high frequency trading systems. The letters on top are from the CFTC 's proposed rule from December , Regulation Automated Trading Reg AT.

For comment letters on the SEC Regulation SCI, Systems Compliance and Integrity, click HERE. MMI supports the vast majority of definitions and designations proposed by the Commission and its specific efforts to ensure all market participants: The cumulative impact of these proposals should propel a virtuous cycle of increased confidence in the futures markets begetting greater liquidity, producing improved pricing, which in turn, will further increased market confidence.

A more detailed explanation of our concerns is contained later in this letter. While we generally favor principles-based requirements to ensure that any risk controls are reasonably designed and appropriately implemented and monitored, we do support the specific requirements proposed by the Commission regarding messaging and price limitations.

CFTC Concept Release on Risk Controls and System Safeguards for Automated Trading Environments December 11, The response describes the many risk controls and system safeguards that are currently in use in the futures industry, and outlines several principles for the CFTC to consider as it examines ways to further strengthen those controls and safeguards.

The response also contains detailed responses to specific questions posed by the CFTC in its concept release, and draws on the collective expertise of nearly individuals from members of FIA and the FIA Principal Traders Group. The letter includes an overview of the types of systems in use at exchanges, firms and FCMs, and answers to over questions posed by the CFTC in the concept release.

Steptoe & Johnson LLP

CFTC Concept Release on Risk Controls and System Safeguards for Automated Trading Environments October 31, We are concerned that the concept release, as structured, is overly broad and has numerous potential and unintended consequences. Many of the questions, definitions and potential safeguard areas contain numerous absolute determinations that would trigger compliance requirements.

Federal Register :: Concept Release on Risk Controls and System Safeguards for Automated Trading Environments

CFTC Concept Release on Risk Controls and System Safeguards for Automated Trading Environments December 17, While some critics have claimed otherwise, we urge the Commission to make its own assessment of the relevant literature. We hope the attached literature review is helpful in that regard. CFTC Concept Release on Risk Controls and System Safeguards for Automated Trading Environments February 14, In the discussion that follows, we illustrate some of the more damaging HFT practices and elucidate the following points:.

Automated Trading Regulation - Comment Letters From MarketsReformWiki.

Automated Trading Regulation - Comment Letters - MarketsReformWiki

Timeline, Automated Trading, CFTC Concept Release Date Proposed Rule in Federal Register Comment Deadline September 9, December 17, March 16, Timeline, Improving Systems Compliance and Integrity, SEC Proposal Date Comment Deadline Final Rule Issue Effective Date March 25, July 8, November 19, February 3, Dodd-Frank Timeline, Risk Management Controls for Brokers or Dealers with Market Access, SEC Final Rule Issue Effective Date Compliance Date November 15, June 30, November 30, Click Here To Explore Other Topics.

Regulation Automated Trading Regulation AT. Risk Controls and System Safeguards for Automated Trading.

Risk Management Controls for Brokers or Dealers with Market Access. Joint CFTC-SEC Advisory Committee on Emerging Regulatory Issues.

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