June 1, 2015
The modernization of regulation requires the broker-dealer transmit raw data in real time to a centralized processor under the supervision of the regulator.
The benefits of this structure is it removes a conflict of interest of the broker-dealer manipulating its books, it eliminates the need for exmiantion of process, and. Regulatory infractions can be detected instantaneously.
For the 125 HFT proprietary trading firms which will no longer be 15b9-1 exempt, I look forward to working with the SEC on providing the effect of algorithmic trading on 15c3-1 in real time to prevent the next flash crash.
If a HFT trading firm falls below net capital level, then an electronic transmission can be sent to the exchanges in real time to stop trading in real time.
I encourage the advisory committees to reach out to Kenneth Goodman of Exmainations Office for a history of progress. I have been working with the Office of Commissioner Sharon Bowen at the CFTC as well as many partipants fall under 15c3-1 as well.Www.systemicriskregulation.com