Shipkevich Bitcoin and ICO Attorney
Felix Shipkevich November 13, 2009

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.

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