On August 15, the Securities and Exchange Commission released an order “temporarily exempting the floor broker operations of broker-dealers with market access that handle orders on a manual basis” (the Floor Brokers) from the automated controls requirement of Rules 15c3-5(c)(1)(ii) and (c)(2) of the Securities Exchange Act of 1934 (the Automated Controls Rule). The Automated Controls Rule applies to each broker-dealer with market access to an exchange or automated trading system and requires, among other things, that each such broker-dealer implement a risk management control system and supervisory procedures reasonably designed to...