29. Would regulatory standards regarding the use of such technology provide additional protection to the markets?
30. Trading pauses, as currently implemented, can be triggered for multiple reasons. Are certain triggers more or less effective in mitigating the effects of market disruptions?
31. Are there additional triggers for which pauses should be implemented? If so, what are they?
32. What factors should the Commission or exchanges take into account when considering how to specify pauses or what thresholds should be used?
33. How should the re-opening of a market after a trading pause be effected?
Credit Risk Limits
34. What positions should be included in credit risk limit calculations in order to ensure that they are useful as a tool for limiting the activity of a malfunctioning ATS? Is it adequate for such a screen to include only those positions entered into by a particular ATS or should it include all the firm's positions?
35. Should pre-trade credit screens require a full recalculation of margin based on the effect of the order?
36. In light of your answers to the previous two questions, where in the lifecycle of an order should the credit limits be applied and what entity should be responsible for conducting such checks?
37. If credit checks are conducted post-trade, what should be done when a trade causes a firm to exceed a limit?
38. Please describe any technological limitations that the Commission should be aware of with respect to applying credit limits.
39. The Commission is particularly interested to receive public comment on the "hub" model and its applicability to different types of pre-trade risk controls. What are the strengths and weaknesses of this approach relative to other pre-trade or post-trade approaches to checking trades against credit limits? How would the latency between the "hub" and the exchanges be managed to provide accurate limits for high frequency ATS?
40. If you believe that post-trade credit checks would be an effective safeguard against malfunctioning ATSs, what is the maximum amount of latency that should be allowed for conducting such checks? What technological or information flow challenges would have to be addressed in order to implement post-trade checks with that degree of latency?
41. With respect to any entity that you believe should be responsible for applying credit risk limits, please describe the technology necessary to implement that risk control and the cost of such technology.
Order, Trade and Position Drop Copy
42. What order and trade reports are currently offered by DCMs and DCOs? What aspects of those reports are most valuable or necessary for implementing risk safeguards? Please also indicate whether the report is included as part of the exchange or clearing service, or whether an extra fee must be paid.
43. If each order and trade report described above were to be standardized, please provide a detailed list of the appropriate content of the report, and how long after order receipt, order execution, or clearing the report should be delivered from the trading platform to the clearing member or other market participant.
Trade Cancellation or Adjustment Policies
44. Is a measure that would obligate exchanges to make error trade decisions (i.e., decisions to cancel a trade or to adjust its price) within a specified amount of time after an error trade is reported feasible? If so, what amount of time would be sufficient for exchanges, but would be sufficiently limited to help reduce risk for counterparties to error trades?
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