Proposed CFTC Regulations on Automated Trading: What You Should Know in 2017
In response to the changing structure of financial markets lead by algorithmic trading, the Commodity Futures Trading Commission (CFTC is proposing Regulation of Automated Trading (Reg AT). The proposed rule is summarized as “a comprehensive approach to reducing risk and increasing transparency in automated trading.” Regulation AT would require proprietary trading firms’ CFTC registration and compliance to mandates such as those limiting the number of orders that can be placed at a given time. It would also give CFTC the access to secret computer source code – one of the controversial aspects of the rule.
While the industry is supportive of increasing transparency and reducing risks, it sees that the proposal’s approach is short of these goals. The industry is concerned with the cybersecurity danger an on-demand access to intellectual property might bring. Through a letter, a group of associations representing market players have encouraged the CFTC to limit its access to sensitive source code and to concentrate on risk control.
In this two-hour LIVE Webcast, a panel of distinguished professionals and thought leaders organized by The Knowledge Group will help the audience understand the fundamental aspects of this significant topic. They will provide an in-depth discussion of Reg AT as well as its implications to the financial markets. Speakers will also offer their insights on best compliance practices.
Key topics include:
- Regulation Automated Trading - Overview
- Reg AT Implications
- Industry Criticisms
- CFTC’s Proposed Computer Source Code Access
- Best Compliance Practices
- Regulatory Outlook
Skadden, Arps, Slate, Meagher & Flom LLP
Warshaw Burstein, LLP
- Is a new Federal Rule on algorithmic trading necessary or appropriate? Do we need Regulation AT?
- If so, what should Regulation AT accomplish? What are the right goals?
- Overview of Current Proposal and Definitions
- Application to AT Persons
- Application to Clearing FCMs and DCOs
- Supplemental Regulations – Responsive of CFTC to industry comments
- Why does the Current Proposal focus on Registration of some AT Persons? Is this a precursor to requiring other non-intermediary end users to register?
- Does the Current Proposal's definition of AT Persons strike the right balance? Do the Current Proposal's substantive requirements for AT Persons meet a cost-benefit test?
- Has the Commission imposed undue obligations on DCMs and FCMs? What should their role be in an appropriate Reg AT?
Who Should Attend:
- Floor Brokers
- Swap Dealers
- Swap Participants
- Commodity Pool Operators
- Commodity Trading Advisors
- Introducing Brokers
- Propriety Traders
- Automated Trading Firms
Mark D. Young is co-head of the firm’s Derivatives Group. His practice focuses on financial services regulation, derivatives and agency litigation, legislative advocacy, and business and transactional counseling.
In the area of financial services regulation, Mr. Young represents exchanges and clearinghouses, trading platforms, swap dealers, banks, pension organizations, trading firms and investment managers before the U.S. CFTC, SEC, Department of Labor and federal banking agencies. He is actively advising clients on the development of and compliance with federal derivatives regulations implementing the Dodd-Frank Act.
Mr. Young, who is a former CFTC assistant general counsel, played a lead role in connection with every major piece of legislation to amend the Commodity Exchange Act, the statute administered by the CFTC, since 1978. These bills have focused on financial regulatory reform, swaps and other derivatives, energy prices and jurisdictional disputes between the CFTC and the SEC. He has also argued landmark appellate cases involving the CFTC.
Mark D. Young is co-head of the firm’s Derivatives Group. His practice focuses on financial services regulation, derivatives and agency …
Ms. Okoshi is a seasoned corporate, transactional and regulatory counsel who focuses her practice on investment management, finance and international transactions. She has broad experience in corporate transactions and advice, joint ventures, securities offerings, corporate finance, derivatives and the offering and regulation of investment managers and products. She represents investment advisers and commodity trading advisors in connection with the organization, offering and management of funds, managed accounts and commodity pools and advises them on regulatory matters, transactions, product structuring and offerings, trading agreements and derivatives. She has significant experience in the organization and representation of on-shore and off-shore hedge funds and managed futures funds, formation of managed account platforms and private equity funds, and expertly guides investment advisers and commodity trading advisors through securities and futures regulatory requirements and compliance. Ms. Okoshi graduated from the University of Pennsylvania with a B.A. and M.A. and received her law degree from Stanford Law School. She is fluent in English, Japanese and Mandarin Chinese.
Ms. Okoshi is a seasoned corporate, transactional and regulatory counsel who focuses her practice on investment management, finance and international …
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NASBA Field of Study:
Business Law - Technical
NY Category of CLE Credit:
Areas of Professional Practice
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About Warshaw Burstein, LLP
With roots dating back to 1927, Warshaw Burstein, LLP is a full-service law firm with offices in New York City that has distinguished itself through superior and cost-effective legal services, and personalized client care and attention.
Warshaw Burstein, LLP is a mid-sized law firm, concentrating in the following practice areas: banking and finance, construction, corporate and securities, creditors’ defense litigation and compliance, entertainment and media, exempt organizations, financial services, intellectual property, litigation, matrimonial and family law, real estate, tax, and trusts and estates. It has comprehensive experience representing a wide range of international, national and local businesses of all sizes, as well as governmental authorities and many prominent families and individuals, in an extensive array of litigation and transactional matters.