Disruptive Trading Practices Regulation - Comment Letter - CME Group - May 17, 2011

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Timeline, Interpretive Guidance on Disruptive Practices
Proposal Date Comment Deadline Effective Date
March 18, 2011 May 17, 2011 May 28, 2013

Antidisruptive Practices
May 17, 2011

According to the comment letter, although the interpretive order "clarifies such terms as 'spoofing,' 'violates bids and offers,' 'orderly,' 'closing period,'" CME Group does not believe that the order "offers the necessary guidance to market participants." CME Group further states that the proposed order "is still unclear in several important respects" as to prohibited behavior, and thus is "still susceptible to constitutional challenge."



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