Comment Text:
Automated Trading is something that should not be permitted. They are highly dangerous to the economy due to the risks of speculation.
It should be universal knowledge that a cause of the collapse of the markets a decade ago was speculative trading. This housing crisis was caused by speculation. When the bubble burst, it brought much of the economy down. It should also be remembered that Lehman Brothers was caused due to short selling.
Their prohibition would help the economy. Automated trading encourages companies to quickly purchase and sell stock, and bypass the layers of review and judgement needed to protect investors against another Enron or Lehman Brothers.
The Commodities Futures Trading Commission should also, in the future, break rulemakings as large as this up. This is a large number of questions, and simply because I did not comment on a question does not mean that I endorse the CFTC position.
2. Algorithms should be all systems where at least one critical parameter is not user defined before execution of said trade, but does not include forwards and futures.
3. No. How any computer algorithm works is irrelevant to the dangers.
4. Algorithms should not matter. In fact, discriminating due to operating speed encourages acting, regardless as whether such trade makes economic sense.
7. This should be done in another rulemaking. This proposed rule is too long.
11. This cannot be predicted or controlled.
14. This is done by corporations.
15. Both should be traders. Using an automated pool on behalf of another is the same as a pass through.
23. Yes. See comment 24.
24. All firms doing automated trading should register. See comment 95.
25. This should be done in another proposed rulemaking. This proposal, with over 500 footnotes and 150 questions, is exceedingly long.
27. Floor traders is irrelevant. If not an automated trader, this rule should not apply to such person.
30. This is the mandatory automated system that Dodd-Frank authorizes and mandates.
37. No.
39. Dodd-Frank does not include any requirements for automated trading, because it never authorizes such trading. Automated trading should be prohibited.
47. The answer is undoubtedly yes.
67. See comment 79.
75. This is why these should be banned.
76. It is not practical to use plain English to describe these requirements. This information is unlikely to be helpful to consumers who do not know how the stock market works and about swaps, derivatives, options, etc. This cannot be written effectively below a college level.
79. Discretion and the minimums should be limited solely to reduce the maximum, not increase.
90. Self trading is not a concern, and can be dealt with in another rulemaking procedure. This procedure is already excessively long and should be split up.
93. No balance is required.
95. All orders should be included. In addition, aggregate orders should also be limited. Note the proposal of Senator Sanders from Vermont to impose a Financial Transaction Tax on these transactions, because they caused the 2008 crisis.
97. Yes. A month is sufficient time for the market to plunge into a recession.
109. See comment 138.
111. See comment 159.
116. No. Unless automated transactions, no additional costs are required.
127. The benefits outweigh the costs.
132. The automated alerts are required by Dodd-Frank.
138. The Cost Benefit analysis could be fixed by allowing entities that both own and trade less than $50,000,000 annually (including all affiliates and parent organizations) from requirements other than maximums, provided that they are not dealing with protected funds (such as ERISA Pensions).
140. The Commission should not grant any exemption from registration. This is very dangerous, and Small Entities, if not dealing with ERISA Pensions or other protected funds, can be exempted subject to the maximum.
147. The transparency requirement is a trade secret concern. This trade secret cannot be avoided, and further demonstrates why automated trading is a mistake.
157. If automated trading is still permitted, the Commission should not permit the preset levels to be changed to increase trading speed.
159. The cost benefit analysis that my proposed plan has, would be preventing harmful trading, reducing regulatory compliance cost by establishing clear rules. The prohibition of these trades would be better.
Automated Trading is something that should not be permitted. They are highly dangerous to the economy due to the risks of speculation.
It should be universal knowledge that a cause of the collapse of the markets a decade ago was speculative trading. This housing crisis was caused by speculation. When the bubble burst, it brought much of the economy down. It should also be remembered that Lehman Brothers was caused due to short selling.
Their prohibition would help the economy. Automated trading encourages companies to quickly purchase and sell stock, and bypass the layers of review and judgement needed to protect investors against another Enron or Lehman Brothers.
The Commodities Futures Trading Commission should also, in the future, break rulemakings as large as this up. This is a large number of questions, and simply because I did not comment on a question does not mean that I endorse the CFTC position.
2. Algorithms should be all systems where at least one critical parameter is not user defined before execution of said trade, but does not include forwards and futures.
3. No. How any computer algorithm works is irrelevant to the dangers.
4. Algorithms should not matter. In fact, discriminating due to operating speed encourages acting, regardless as whether such trade makes economic sense.
7. This should be done in another rulemaking. This proposed rule is too long.
11. This cannot be predicted or controlled.
14. This is done by corporations.
15. Both should be traders. Using an automated pool on behalf of another is the same as a pass through.
23. Yes. See comment 24.
24. All firms doing automated trading should register. See comment 95.
25. This should be done in another proposed rulemaking. This proposal, with over 500 footnotes and 150 questions, is exceedingly long.
27. Floor traders is irrelevant. If not an automated trader, this rule should not apply to such person.
30. This is the mandatory automated system that Dodd-Frank authorizes and mandates.
37. No.
39. Dodd-Frank does not include any requirements for automated trading, because it never authorizes such trading. Automated trading should be prohibited.
47. The answer is undoubtedly yes.
67. See comment 79.
75. This is why these should be banned.
76. It is not practical to use plain English to describe these requirements. This information is unlikely to be helpful to consumers who do not know how the stock market works and about swaps, derivatives, options, etc. This cannot be written effectively below a college level.
79. Discretion and the minimums should be limited solely to reduce the maximum, not increase.
90. Self trading is not a concern, and can be dealt with in another rulemaking procedure. This procedure is already excessively long and should be split up.
93. No balance is required.
95. All orders should be included. In addition, aggregate orders should also be limited. Note the proposal of Senator Sanders from Vermont to impose a Financial Transaction Tax on these transactions, because they caused the 2008 crisis.
97. Yes. A month is sufficient time for the market to plunge into a recession.
109. See comment 138.
111. See comment 159.
116. No. Unless automated transactions, no additional costs are required.
127. The benefits outweigh the costs.
132. The automated alerts are required by Dodd-Frank.
138. The Cost Benefit analysis could be fixed by allowing entities that both own and trade less than $50,000,000 annually (including all affiliates and parent organizations) from requirements other than maximums, provided that they are not dealing with protected funds (such as ERISA Pensions).
140. The Commission should not grant any exemption from registration. This is very dangerous, and Small Entities, if not dealing with ERISA Pensions or other protected funds, can be exempted subject to the maximum.
147. The transparency requirement is a trade secret concern. This trade secret cannot be avoided, and further demonstrates why automated trading is a mistake.
157. If automated trading is still permitted, the Commission should not permit the preset levels to be changed to increase trading speed.
159. The cost benefit analysis that my proposed plan has, would be preventing harmful trading, reducing regulatory compliance cost by establishing clear rules. The prohibition of these trades would be better.
