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MMI Comment Letter to the CFTC Regarding Supplemental Notice of Proposed Rulemaking for Regulation AT

This Proposed Rule threatens to erode confidence in our country’s resolve to uphold the regulatory standards that protect the innovation that drives much of our economy. Despite the changes in the proposed rule as listed in the Supplemental, it still grants a government agency the ability to bypass due process to access confidential and highly […]

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ValueWalk: Why Did Regulator Have Computer Trading Code On Personal PC?

Mark Melin writes that a 2016 SEC Office of Inspector General (OIG) report contains a little-noticed reprimand of an SEC quantitative analyst charged with improperly requesting and downloading confidential computer code to his personal computer.  This as measures in the CFTC’s pending Reg AT call for regulators to have subpoena-less access to source code used by […]

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WSJ: Multiple Buyers, Not One, Influenced Most Active E-Mini Move of 2016

Alexander Osipovich reports that a sharp move in stock-market futures that fueled the Dec. 7 buying in U.S. equities likely reflected trading by multiple buyers.  MayStreet LLC, said its initial analysis was that the move was a single trade.  The firm changed its view after being contacted by the Modern Markets Initiative, which carried out its own […]

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MMI Comment Letter to the SEC Regarding Regulation National Market System

We propose a review of the Reg NMS in light of technology and efficiencies that have made some measures unnecessary or contributed to market inefficiency.  In our letter, we propose a review of the effectiveness of The Order Protection Rule, the prohibition on locking or crossing quotations and consideration of a competing consolidators model for […]

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The Buy Side Isn’t Buying It

If you’ve listened to the market structure debate over the past few years, you’d think large, institutional investors — the “buy side” — desperately need ‘speed bumps’ and other barriers to protect them from high frequency trading (HFT). The discussion has been more about demonizing than data, except that it ultimately led to a well-publicized […]

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Financial News: Possible Consequences of the Pending Trump Presidency on Reg AT

Tim Cave reports Bill Harts, chief executive of New York-based HFT advocacy group Modern Markets Initiative, said that as a result of the election of Trump, the 2005 equity trading regulation Regulation NMS may be reviewed.  He also pointed out that Regulation AT – the CFTC’s new rules overseeing algorithmic trading which include a controversial provision […]

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Washington Post: Possible Consequences of the Pending Trump Presidency on a FTT

Renae Merle reports Wall Street insiders had been preparing for a Clinton administration that would institute a financial transaction tax on trading. That now appears to be off the table.  “We have no reason to believe President-elect Trump is in favor of anything but the cost-effective, efficient markets we have in America today. We don’t need […]

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Dissent by Commissioner J. Christopher Giancarlo Regarding Reg AT Source Code Provision

The subpoena process provides property owners with due process of law before the government can seize their property. It protects owners of property – not the government that already has abundant power. It allows property owners an opportunity to challenge the scope, timing and manner of discovery and whether any legal privileges apply to the […]

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ValueWalk: CFTC One Step Closer To Reg AT, Requiring Access to Algos

Mark Melin reports the CFTC proposed rulemaking changes to issue a “special call” notice to registered participant as opposed to a legal subpoena, when seeking access to the source code of automated traders. CFTC Chairman Tim Massad said engaging in market manipulation “should not be able to hide behind machines.” Modern Markets Initiative CEO Bill […]

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Financial Times: CFTC set to tweak rules for automated trading

Gregory Meyer and Joe Rennison report the Commodity Futures Trading Commission’s proposal, known as Regulation AT, seeks subpoena-less access to source code as part of its oversight of markets. Bill Harts, chief executive of Modern Markets Initiative, a trading industry group, said: “It would not remediate the problems. We are still frankly in the dark. […]

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“High-frequency traders provide a vital service to all market participants…HFT helps to create efficient markets by facilitating price formation, lowering the cost of trading and improving the linkage between markets."

BlackRock Viewpoint, June 2011

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