Prohibiting the Aggregation of Orders to Satisfy Minimum Block Sizes or Cap Size Requirements - Comment Letter - Wholesale Market Brokers’ Association, Americas - July 26, 2012

From Markets Reform Wiki
Jump to navigation Jump to search
Timeline-Block Trade Aggregation Prohibition
Proposal Date Final Rule Issue Effective Date
June 27, 2012 May 31, 2013 July 20, 2013

Wholesale Market Brokers’ Association, Americas - August 1, 2012[edit]

Prohibiting the Aggregation of Orders to Satisfy Minimum Block Sizes or Cap Size Requirements
August 1, 2012

From the comment letter:

  • "the WMBAA urges the Commission to recognize the significant differences between futures markets and OTC swaps markets, including the number of products traded, the average daily trading volume, and, importantly, the distinct statutory regimes."
  • "The WMBAA believes that the Commission’s intent to prohibit the 'aggregation of orders for different accounts in order to satisfy the minimum block trade size or the cap size requirement' specified in proposed section 43.6 does not relate to the concept of 'work-up'"
  • "The WMBAA believes that prohibiting 'work-up' will have significantly harmful implications for OTC swaps markets, to the detriment of market participants in the form of wider bid-ask spreads, less trading volume, and less transparent price discovery."


MarketsReformWiki Sponsors

RSM US LLP ADM Investor Services Cinnober Fidessa