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FIA PTG Letter on Defining High-Frequency Trading

Date 13/12/2011

The Commodity Futures Trading Commission is discussing how to define high-frequency trading at a meeting today of the CFTC’s Technology Advisory Group.  The meeting was organized by CFTC Commissioner Scott O’Malia, who issued a proposed definition of HFT a few weeks ago and asked for public comment.  The FIA Principal Traders Group responded to O’Malia’s request by submitting the attached letter.  In addition, several members of the FIA PTG are participating in today’s discussion. The main point that the FIA makes in the letter and in today’s presentations is that the CFTC’s regulatory concerns would be best served by tracking all automated trading systems.  This would avoid having to make arbitrary distinctions on how many trades would meet the definition of “high frequency.” In addition, this would allow the CFTC to leverage existing resources, such as the data already being collected by the major U.S. exchanges on orders submitted by automated trading systems.  More detail is in the attached letter.  For more information about the FIA PTG, including a list of members, please visit the FIA'S website at http://www.futuresindustry.org/ptg/