Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 16 DECEMBER 2015

CFTC Proposes "Regulation AT" For Automated Trading

WilmerHale
WilmerHale
Contributor
WilmerHale

WilmerHale

WilmerHale's London office was established more than 40 years ago. With lawyers qualified in the...

View firm profile
Explore more from WilmerHale

On November 24, 2015, the Commodity Futures Trading Commission (CFTC or Commission) proposed a new regulatory regime for automated trading on US designated contract markets (DCM) (Regulation AT or the proposal).

United StatesFinance and Banking
Paul M. Architzel
Paul M. Architzel
Dan M. Berkovitz
Dan M. Berkovitz
Bruce Newman
Bruce Newman
Jeanette Boot
Jeanette Boot
Dino Wu
Dino Wu
Douglas J. Davison
Douglas J. Davison
Daniel J. Martin
Daniel J. Martin
Ted Serafini
Ted Serafini
Gail Bernstein
Gail Bernstein
Author LinkedIn connections

On November 24, 2015, the Commodity Futures Trading Commission (CFTC or Commission) proposed a new regulatory regime for automated trading on US designated contract markets (DCM) (Regulation AT or the proposal). The Commission describes the proposal as "a comprehensive approach to reducing risk and increasing transparency in automated trading." Regulation AT would impose a series of risk controls and other regulatory requirements on several layers of market participants: (a) market participants meeting the definition of an "AT Person"; (b) clearing member futures commission merchants whose customers are AT Persons; and (c) DCMs executing orders from AT Persons. According to the Commission, the proposal enshrines many of the best practices already adopted by industry and generally takes a principles-based approach to risk control requirements and other measures. This client alert provides an overview of the CFTC's proposal and highlights several important areas for

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

SEC Advances “Responsible Retailization” Through A Potential Accredited Investor Exam And Potential Regulated Fund Reforms

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).
United StatesFinance and Banking
Proskauer Rose LLP
Proskauer Rose LLP
Article

OCC Issues Examiner Framework For Banks’ Use Of Artificial Intelligence

The Office of the Comptroller of the Currency has released a new framework for evaluating banks' deployment of artificial intelligence and agentic AI systems in their business operations. This guidance establishes how examiners will assess AI through existing risk management disciplines rather than creating separate regulatory requirements, with review intensity scaled to each use case's potential consequences and level of human oversight.
United StatesFinance and Banking
Sheppard
Sheppard
Article

SEC Proposes Rule Amendments To Expand Retail Access To Private Markets

The SEC has proposed sweeping amendments to expand retail investor access to private market strategies, including changes to performance-based compensation rules for registered investment advisers and modernization of the interval fund framework. The proposals also explore new credential-based pathways for individuals to qualify as accredited investors, potentially opening private offerings to a broader pool of eligible participants.
United StatesFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

23x5 Trading Comes To US Exchanges: What Firms Should Know Before Launch

US national securities exchanges are preparing to launch 23x5 trading by December 6, 2026, marking the most significant expansion of trading hours in decades. This comprehensive analysis examines the regulatory approvals, operational infrastructure changes, investor protection mechanisms, and issuer considerations necessary to support overnight equity trading from Sunday through Thursday evenings.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

PTAB/USPTO Update - October 2026

The USPTO has released new templates and guidance for AIA trial proceedings, announced key appointments including a Chief AI Officer, and published updated procedures for patent applications and subject matter eligibility declarations. Director Squires delivered multiple addresses emphasizing the constitutional importance of intellectual property rights while the agency expanded its community engagement efforts and international collaboration through WIPO's Global IP Assignment Platform pilot program.
United StatesIntellectual Property
WilmerHale
WilmerHale
Article

23x5 Trading Comes To US Exchanges: What Firms Should Know Before Launch

US national securities exchanges are preparing to launch 23x5 trading by December 6, 2026, marking the most significant expansion of trading hours in decades. This comprehensive analysis examines the regulatory approvals, operational infrastructure changes, investor protection mechanisms, and issuer considerations necessary to support overnight equity trading from Sunday through Thursday evenings.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

SEC Approves FINRA’s New “Outside Activities” Rule

The Securities and Exchange Commission has approved FINRA Rule 3290, which will replace existing rules governing outside business activities and private securities transactions for registered persons. This new rule narrows the scope to focus on investment-related activities while maintaining similar supervisory obligations for member firms. Understanding the key changes and implementation requirements will be critical for broker-dealers as they update their compliance policies and procedures.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

Lame Duck, High Stakes: Congress’s Postelection Agenda

As Congress prepares for its postelection lame-duck session, lawmakers face critical decisions on government funding, defense authorization, and potential debt-limit increases. The election outcome will determine whether Republicans push through major legislation before potentially surrendering control, or whether both parties defer negotiations into 2027. With permitting reform, tax extenders, and reconciliation packages on the table...
United StatesGovernment, Public Sector
WilmerHale
WilmerHale
Article

California Adopts Law To Impose New Guardrails On Attorneys And Arbitrators Use Of AI

California's new SB 574 establishes the first statutory framework governing attorneys' and arbitrators' use of generative artificial intelligence, imposing verification requirements and disclosure obligations that take effect in January 2027. The law responds to recent court sanctions for AI hallucinations while leaving unresolved critical questions about privilege, work-product protection, and the boundaries between permissible assistance and impermissible delegation.
United StatesCorporate/Commercial Law
WilmerHale
WilmerHale
Article

SEC 2027 Exam Priorities: Familiar Priorities, Evolving Markets

The SEC Division of Examinations has released its fiscal year 2027 examination priorities, signaling continued focus on investment adviser fiduciary obligations, broker-dealer financial responsibility, and Regulation Best Interest while adapting to evolving market practices. Private credit, artificial intelligence governance, and retail investor protection emerge as prominent areas of scrutiny, with examiners expected to probe valuation practices, conflicts of interest, and technology controls across regula
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

Section 232 Pharmaceutical Tariffs Are Now In Effect: It’s Not Too Late To Consider Duty-Mitigation Strategies

On September 29, 2026, the final phase of Section 232 pharmaceutical tariffs took effect, imposing an additional 100 percent ad valorem duty on many imported patented pharmaceuticals and ingredients. While these duties may substantially increase import costs, several customs and trade mechanisms may be available to reduce, eliminate, or defer the tariffs.
GlobalInternational Law
WilmerHale
WilmerHale
Article

The SEC’s Transfer Agent Modernization Proposal: Implications For Onchain Recordkeeping

The SEC has proposed a comprehensive overhaul of transfer agent regulations that would formally recognize distributed ledger technology and blockchain-based recordkeeping systems within the existing regulatory framework. This modernization effort imposes enhanced operational, safeguarding, and compliance obligations while establishing technology-neutral standards that could significantly impact tokenization initiatives and digital asset market infrastructure.
United StatesFinance and Banking
WilmerHale
WilmerHale