Comment Text:
Dear CFTC,
1. One of the pre-trade risk controls required by Regulation AT, is a maximum execution frequency per unit time.
Q. Execution frequency would be out of the control of the AT Person, since the executions are determined by the resting order/s on the books of the DCM, the DCM's software handling of the interaction between an incoming order from an AT Person and the orders resting on the DCM's books.
For this particular risk control, exactly what is CFTC looking for the AT person to do in the way of pre-trade risk controls? What type of limits, alerts or preventative measures does CFTC envision to be feasible?
Thank you,
Carmen G Lelli Jr.
ULLink Inc.
