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Algorithmic source code repository proposed by CFTC

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 Mary Irwin, Futures/Derivatives Legal and Compliance Consultant

 Thursday, April 28, 2016

Algorithmic source code repository proposed by CFTC


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7 comments on article "Algorithmic source code repository proposed by CFTC"

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 Mary Irwin, Futures/Derivatives Legal and Compliance Consultant

 Thursday, April 28, 2016



This informative FT article refers to the CFTC's proposed Reg AT, which was unanimously approved by the CFTC on November 24, 2015. The algorithmic source code repository is only a part of a much larger proposal that the CFTC has announced it intends to final rules on by the end of 2016.


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 R. Rene Carson, General Counsel at Matrix Markets

 Friday, April 29, 2016



Absurd notion.


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 Michael Moor, Trader/Analyst

 Tuesday, May 3, 2016



This is a total violation of any decent business practice. Are they serious? They want us to just 'turn over' the code our experience has taken us years/decades to come up with?? There is NO WAY they could guarantee the people that work for them wont take those ideas and use them to their own benefit, or just alter them a bit and call them their own. This has little to do with compliance, and a lot to do with outright stealing.


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 private private,

 Tuesday, May 3, 2016



@Michael Moor: you may be right but that is regulators for you.

If you don't comply you will be shut down...


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 Michael Moor, Trader/Analyst

 Tuesday, May 3, 2016



I don't think this has anything to do with regulation, although they may want to pose it as that. If they had correct rules and monitoring in place (like not allowing incessant bidding and offering that has no real purpose except for manipulation--on the floor you were held to orders you put out for a period of time), then there would be no need for source code. But besides that, it is still a crooked business practice--I will call it what I see it as, and gross oversight in an area that is inappropriate to look at. Where does it go from there?? If you have a system that is fantastic, are they going to tell you it makes too much money? Are they going to say your decision making process must be made public??--which is essentially what they are saying. There is WAY to much incentive for corruption.


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 Doug Q., Senior Developer at Bloomberg LP

 Wednesday, May 4, 2016



This is one of the dumber ideas proposed. Who is going to look at this? Who will keep it secure? Government agencies have a dismal track record on information security, at best.


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 Mary Irwin, Futures/Derivatives Legal and Compliance Consultant

 Thursday, May 5, 2016



Unfortunately, this proposal was part of a larger package of rules unanimously approved by CFTC Commissioners and published for comment in early December, 2015. The comment deadline was March 16, 2016 and the CFTC has expressed its intent to arrive at final rules in this area by year-end. However, I've read the many comments that have been registered in opposition to the proposal to deposit source code in a repository and it seems like there will be an effort to oppose it on constitutional grounds. In the end, even though it looks like many parts of the proposal will go forward, it doesn't seem this part of the new regulations will be on the same timeline (just my opinion, though).

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