Recent Articles & Comments

IOSCO's recommended "good practices" are rather basic and lack the detail and specifics of, for example,  ("Regulation Systems Compliance and Integrity")(17 CFR 242.1000 - 1007). As a result, these recommendations are likely to have little, if any, impact on how US regulators think about exchange regulation.

In the Report, IOSCO provides a good overview of the evolution of exchanges over the last two-plus decades, as well as an interesting discussion of the risks and challenges…

Trading by 24X National Exchange outside the 4 a.m. to 7 p.m. window is dependent upon the equity data plans making changes that would facilitate overnight trading.

This means that it may be some time before we see overnight trading in the US. Assuming overnight trading in the US does actually happen, it will be interesting to see whether the Exchange can capture a meaningful share of overnight trading that now takes place in the Asia-Pacific markets. It will also be interesting to…

In this matter, the firm appears to have made at least three mistakes. First, its WSPs did not specify how the firm would document its review of employees' outside securities account statements. Second, the WSPs did not specify how the firm would track completed reviews. Third, the firm, for an almost two-year period, failed to conduct required quarterly reviews, including failing to review 14 employee accounts entirely during this time, it seems likely that the last of these was the…

To add a bit of color, FINRA brought the issue relating to mid-point peg orders to the firm's attention in September of 2022, but the firm failed to remedy its reporting of these orders until April of the following year, that is, more than six months later. Possibly, it was not feasible for the firm to have updated its systems and reports any quicker than that, though it is also possible that FINRA thought the firm should have fixed this problem more promptly. The other issues raised in the…