A Tale of Two Issues: Zach Ziliak Breaks Down the HFT Debate
Keith Ross on HFT, Reg NMS and Dark Pools
Raj Mahajan, Allston Trading CEO, Talks HFT and the Business of Prop Trading
HFT Rules: Rules for the Algo Highway
HFT Rules: Three Part HFT Harmony
The first 10 years of the U.S. Securities and Exchange Commission's Rule 15c3-5, known as the market access rule, have been a textbook example of the principle of regulation by enforcement, resulting in an informal patchwork...more
Bass, Berry & Sims attorney Chris Lazarini commented on a case in which a court took the unusual step of remanding a case to the arbitration panel to explain the rationale behind its award. The Court made the decision because...more
Gretchen Morgenson and Fair Game have had a few days to reflect on the Bayer/Monsanto deal, and with that little bit of hindsight (and a lot of history), she’s not too sure that Bayer’s stockholders are going to be thrilled...more
On Monday, November 2, 2015, Andrew Ceresney, Director of the SEC’s Division of Enforcement, gave a speech at the SIFMA Compliance & Legal Society New York Regional Seminar in which he sought to address what he views as the...more
On October 20, 2015, SEC Chair Mary Jo White gave the keynote address at the “Evolving Structure of the U.S. Treasury Market” conference organized by the U.S. Department of Treasury and the Federal Reserve Bank of New York....more
SEC-Sanctioned Trader Began Alleged Spoofing After Complaining About Spoofing by Others to NYSE - Eric Oscher and Briargate Trading, LLC, a company 50 percent owned by Mr. Oscher, agreed to pay an aggregate fine of US...more
The Yates Memo, refocusing DOJ criminal and civil corporate investigations, continues to be the critical topic of discussion this week. The Memo, discussed here, directs that individuals be the focus of the inquiry from the...more
Reflecting increased regulatory willingness to discipline principals and supervisors, FINRA recently announced that it had imposed an industry bar on the former president of a defunct broker-dealer, along with five registered...more
Charles Schwab Fined US $2 Million by FINRA for Net Capital Deficiencies: Charles Schwab & Co. agreed to pay US $2 million to the Financial Industry Regulatory Authority to resolve allegations that it had net capital...more
The Securities and Exchange Commission (the “SEC”) recently proposed an amendment to Rule 15b9-1 under the Securities Exchange Act of 1934 (the “Exchange Act”). The proposed amendment (the “Proposed Amendment”) would require...more
Two Traders Subject of CME Summary Suspension for Alleged Spoofing Sued by CFTC Too - Last week, the Commodity Futures Trading Commission commenced a lawsuit in federal court in New York against Heet Khara and Nasim...more
Overview - On March 25, 2015, the Securities and Exchange Commission ("SEC" or "Commission") proposed an amendment to Rule 15b9-1 (the “Proposal”) under the Securities Exchange Act of 1934 ("Exchange Act") that, if...more
On March 25, 2015, the U.S. Securities and Exchange Commission (SEC) voted unanimously to issue a proposed rule amendment that would significantly narrow the existing exemption that permits many proprietary-trading...more
The Securities and Exchange Commission is proposing to amend Rule 15b9-1 under the Securities Exchange Act of 1934, as amended, to require broker-dealers that engage in off-exchange proprietary trading to become members of a...more
SEC Proposes FINRA Oversee Certain High-Frequency Trading Firms; FINRA and FIA Issue Best Practice Guidance - The Securities and Exchange Commission proposed changes to an existing rule that, if adopted, would require...more
On March 25, 2015, the SEC proposed an amendment to Rule 15b9-1 that would require high-frequency trading firms to register with FINRA. According to the SEC, the proposed amendment will better align the scope of Rule 15b9-1...more
In an effort to keep pace with rapidly accelerating market technology, the Securities & Exchange Commission (“SEC”) has taken steps to expand oversight over high-frequency trading. On March 25, 2015, the SEC unanimously...more
The Securities and Exchange Commission announced on March 25, 2015 a proposal to amend Rule 15b9-1 under the Exchange Act to require broker-dealers who trade in off-exchange venues to become members of a national securities...more
The Commission brought cases related to HFT this week, but not against those traders. One action involved the operations of one of the largest dark pools. A second involved two exchanges. Each action involved specific types...more
FINRA’s recently-released Regulatory and Examinations Priorities Letter for 2015 reflects substantial regulatory interest in high-frequency trading and other issues arising from trading technology. Regulatory concern over...more
The sheer number of enforcement actions brought against broker-dealers and investment advisers makes it challenging to keep up. In this alert, we divide this year’s most important cases against broker-dealers and investment...more
In this issue: - Delaware Court of Chancery Rejects Controlling Stockholder Claims and Applies Business Judgment Rule to Merger Suits - FINRA Remarks at the National Society of Compliance Professionals...more
Carlo DiFlorio, FINRA’s Chief Risk Officer and Head of Strategy, told the annual meeting of the National Society of Compliance Professionals Monday that FINRA is emphasizing efforts to mitigate market risks, even as it...more
In This Issue: - Regulation ..SEC Begins to Scrutinize Registrants’ Cybersecurity Practices ..SEC Staff Sets Boundaries for Adviser Testimonials in Social Media ..Chair White: SEC to Tackle High-Frequency...more
High speed trading, dark pools and similar market structure issues have become hotly debated topics. Former CFTC Commissioner Bart Chilton gave several speeches discussion the subjects and proposed that high speed traders be...more