Market Access Rule Panel Discussion
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1 Market Access Rule 15c3-5 Discussion Document NASDAQ OMX Panel Discussion February 16, 2011 Market Access Rule Panel Discussion Rule 15c3-5 Relevant Scenarios Material based on FIF Market Access Working Group Risk Controls Survey by Scenario. For questions regarding this document or to join the FIF Market Access WG, please contact Manisha Kimmel at or (312) For Discussion Purposes Only
2 Market Access Rule 15c3-5 Discussion Document NASDAQ OMX Panel Discussion February 16, 2011 Overview In order to highlight implementation activities and challenges, our panel will consider the following scenarios: 1. Sponsored Access Provider: Broker dealer provides sponsored access to registered BD client with no customers of its own, e.g., a prop shop. Client trades equities and options. 2. Correspondent Clearing Firm: Clearing firm executes orders on behalf of correspondents using the clearing firm s MPID. Clients are registered BDs with institutional and retail clients. Clients trade equities, options and fixed income. 3. Broker Dealer Providing Execution Only: Broker dealer executes orders on exchanges/atss but is not the prime broker or clearing broker for client. Client trades equities and options. 4. Options Consolidator Allocating Certain Regulatory Risk: Options consolidator executes on behalf of order entry BD with retail clients. Allocates responsibility for certain regulatory requirements to order entry firm. 5. BD Offering Options Day Trading: Broker dealer executes options orders for day trading customers. 6. Institutional BD Executing Global Basket: Institutional broker dealer executes a non-u.s. client s basket including ETFs and common stock traded on multiple desks in different time zones. 2 For Discussion Purposes Only
3 Market Access Rule 15c3-5 Discussion Document NASDAQ OMX Panel Discussion February 16, 2011 Scenario #1: Sponsored Access Provider Broker dealer provides sponsored access to registered BD client with no customers of its own, e.g., a prop shop. Client trades equities and options. Pre-Set Credit/Capital Thresholds (Identify Applicable regulatory requirements (Please Erroneous order prevention (Identify price/size Prevent trading in restricted securities (Please Duplicate order prevention (Identify Prevent access to trading system (Please Post-Trade surveillance reports (Identify reports) Applicable regulatory requirements (Please overall effectiveness (Identify overall effectiveness (Identify 3 For Discussion Purposes Only
4 Market Access Rule 15c3-5 Discussion Document NASDAQ OMX Panel Discussion February 16, 2011 Scenario #2: Correspondent Clearing Firm Clearing firm executes orders on behalf of correspondents using the clearing firm s MPID. Clients are registered BDs with institutional and retail clients. Clients trade equities, options and fixed income. Pre-Set Credit/Capital Thresholds (Identify Applicable regulatory requirements (Please Erroneous order prevention (Identify price/size Prevent trading in restricted securities (Please Duplicate order prevention (Identify Prevent access to trading system (Please Post-Trade surveillance reports (Identify reports) Applicable regulatory requirements (Please overall effectiveness (Identify overall effectiveness (Identify 4 For Discussion Purposes Only
5 Market Access Rule 15c3-5 Discussion Document NASDAQ OMX Panel Discussion February 16, 2011 Scenario #3: Broker Dealer Providing Execution Only Broker dealer executes orders on exchanges/atss but is not the prime broker or clearing broker for client. Client trades equities and options. Pre-Set Credit/Capital Thresholds (Identify Applicable regulatory requirements (Please Erroneous order prevention (Identify price/size Prevent trading in restricted securities (Please Duplicate order prevention (Identify Prevent access to trading system (Please Post-Trade surveillance reports (Identify reports) Applicable regulatory requirements (Please overall effectiveness (Identify overall effectiveness (Identify 5 For Discussion Purposes Only
6 Market Access Rule 15c3-5 Discussion Document NASDAQ OMX Panel Discussion February 16, 2011 Scenario #4: Options Consolidator Allocating Certain Regulatory Risk Options consolidator executes on behalf of order entry BD with retail clients. Allocates responsibility for certain regulatory requirements to order entry firm. Pre-Set Credit/Capital Thresholds (Identify Applicable regulatory requirements (Please Erroneous order prevention (Identify price/size Prevent trading in restricted securities (Please Duplicate order prevention (Identify Prevent access to trading system (Please Post-Trade surveillance reports (Identify reports) Applicable regulatory requirements (Please overall effectiveness (Identify overall effectiveness (Identify 6 For Discussion Purposes Only
7 Market Access Rule 15c3-5 Discussion Document NASDAQ OMX Panel Discussion February 16, 2011 Scenario #5: BD Offering Options Day Trading Broker dealer executing options orders for day trading customers. If yes, please add sub-bullets with your information into each of the cells. Include any additional comments or considerations in the last column. Pre-Set Credit/Capital Thresholds (Identify Applicable regulatory requirements (Please Erroneous order prevention (Identify price/size Prevent trading in restricted securities (Please Duplicate order prevention (Identify Prevent access to trading system (Please Post-Trade surveillance reports (Identify reports) Applicable regulatory requirements (Please overall effectiveness (Identify overall effectiveness (Identify 7 For Discussion Purposes Only
8 Market Access Rule 15c3-5 Discussion Document NASDAQ OMX Panel Discussion February 16, 2011 Scenario #6: Institutional BD Executing Global Basket Institutional broker dealer executes a non-u.s. client s basket including ETFs and common stock traded on multiple desks in different time zones. If yes, please add sub-bullets with your information into each of the cells. Include any additional comments or considerations in the last column. Pre-Set Credit/Capital Thresholds (Identify Applicable regulatory requirements (Please Erroneous order prevention (Identify price/size Prevent trading in restricted securities (Please Duplicate order prevention (Identify Prevent access to trading system (Please Post-Trade surveillance reports (Identify reports) Applicable regulatory requirements (Please overall effectiveness (Identify overall effectiveness (Identify 8 For Discussion Purposes Only
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