CFTC Roundtable Participants Debate Regulation AT Proposal (With Delta Strategy Group Summary)

Participants at a CFTC roundtable debated elements of proposed Regulation Automated Trading ("AT"). The participants discussed: (1) amendments to the proposed definition of "Direct Electronic Access" that would be consistent with and in furtherance of Regulation AT's proposed registration regime; (2) quantitative measures to establish the population of AT Persons; (3) an alternative to imposing direct CFTC pre-trade risk control and development, testing and monitoring standards on AT Persons; (4) AT Persons' compliance with elements of the proposed rules when using third-party algorithm or systems; and (5) source code access and retention.

Two CFTC commissioners issued statements pertaining to the meeting. CFTC Commissioner Sharon Y. Bowen identified "the positive impact" the proposed regulation will have on market stability and emphasized that the roundtable itself was intended to encourage discussion of stakeholders' concerns. Nonetheless, she stressed that "time