Request for Comments – Proposed Amendments to the Universal Market Integrity Rules

The Proposed Amendments would:
•repeal the rule and policies respecting the “best price” obligation of Participants;
•provide that the Order Protection Rule can not be avoided when a Participant is considering a trade on a foreign organized regulated market;
•require a Participant or Access Person to have adequate policies and procedures for the
handling of orders that do not rely on a marketplace to ensure compliance with the Order
Protection Rule;
•make a number of consequential changes to UMIR including:
repealing those portions of the rules and policies on trading supervision and gatekeeper reports dealing with the “best price” obligation from, confirming that the “best execution” obligation is subject to the Order Protection Rule, introducing a marker for a “directed action order” as defined for the Order Protection Rule, and extending the existing provisions of UMIR governing foreign currency translation and the calculation of the value of an order to the determination whether the execution of certain trades on a foreign organized regulated market may give rise to an obligation to fill “better-priced” orders on a marketplace.

About The Author

Felix Shipkevich

Felix Shipkevich is a Manhattan-based attorney and general counsel for Shipkevich Law Firm. He has extensive experience working with the CFTC and NFA on registration, compliance, and enforcement issues for CPOs, CTAs, FCMs, IBs, and RFEDs. Felix also practices intellectual property and corporate governance law.