FIA PTG submitted comments to the SEC opposing the delay mechanism proposed by NYSE MKT. The NYSE MKT speedbump introduces an intentional delay in protected quotes which creates undue complexity in markets and amplifies the risk of market disruptions during periods of high volatility.
CONTINUE READINGFIA PTG submitted a second round of comments to the SEC in response to the Nasdaq Extended Life Priority Order Attribute (ELO).
CONTINUE READINGFIA PTG sent a letter to the SEC today recommending a comprehensive reform of equity market structure and a repeal of Reg NMS Rule 610.d (the Access Rule) and Rule 611 (the Order Protection Rule). For the past few years, FIA PTG has been advocating for comprehensive reform of equity market structure and calling for a review of the Access Rule and Order Protection Rule.
CONTINUE READINGThe FIA Operations Americas Division is pleased to announce that the 2017-2018 Scholarship Application is now available. New for 2017, the application process will be supported on-line. Once again, we are proud to confirm that the division will be awarding ten scholarships with each valued at $2,500.
CONTINUE READINGFIA PTG filed a letter with the SEC today in support of a proposed rule change by CBOE regarding the responsibility for ensuring compliance with open outcry priority and allocation requirements and trade-through prohibitions. Although the SEC expressed concern that the proposal may diminish the Exchange’s ability to ensure compliance with CBOE’s Book Priority and Trade-Through Rules, the rule change, in fact, advances many principles of the Exchange Act. CBOE's proposed changes would promote just and equitable principles of trade, remove impediments to and perfect the mechanism of a free and open market and a national market system, and not impose any unnecessary or inappropriate burdens on competition.
CONTINUE READINGAt an April 25 meeting of the CFTC's Market Risk Advisory Committee, CFTC staff and industry representatives discussed ways to enhance the process used by clearinghouses for managing the default of a clearing member. The discussion centered on a set of recommendations that were developed last year by a subgroup of the advisory committee under the leadership of Susan O'Flynn of Morgan Stanley.
CONTINUE READINGOn 4 May the European Commission published a legislative text proposing changes to the current EMIR framework. Vice-President Valdis Dombrovskis, who presented the proposal, emphasised that the majority of the changes come as a result of the Commission’s call for evidence exercise which sought views from industry on where post-crisis legislation could be amended to streamline existing provisions and reduce effects of any unintended consequences. Below is an outline of the proposed Commission changes.
CONTINUE READINGFIA PTG submitted comments to the CFTC today regarding proposed capital requirements for swap dealers and major swap participants. FIA PTG argued that the proposed rules would present a significant and unnecessary barrier to entry that would likely render it too costly for many existing and aspiring swap dealers to continue providing this service. Each FIA PTG member firm’s decision to participate in the swaps markets, and to what extent, is dependent upon a number of factors, not the least of which are the costs associated with compliance with the applicable regulations.
CONTINUE READINGThe number of broker dealers and FCMs registered in the United States continues to decline as industry consolidation gathers pace. This fact is somewhat surprising given that trading volumes, in both cash and derivatives, remains robust. According to Bank for International Settlements (BIS), exchange traded futures and options volumes, measured in notional principal, rose over 12% between 2015 and 2016. Meanwhile, the global OTC derivatives market rose by 10.5% during the same period. So, what is going on here? Of course, downward pressure on fees and commissions, combined with low interest rates, have punished operating margins at traditional firms. In other words, many dealers and FCMs are not able to earn economic profits, net of capital costs.
CONTINUE READINGFIA PTG filed comments with the SEC today opposing the CHX Liquidity Enhancing Access Delay (LEAD). The comments reiterate the concerns raised in FIA PTG's October 2016 and January 2017 comments on the CHX Liquidity Taking Access Delay (LTAD, now withdrawn) and March 2017 comments on LEAD.
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