MFA and AIMA Submit Letter to BaFin on the Interpretation of the German HFT Law

The Managed Funds Association (MFA) and the Alternative Investment Management Association (AIMA) submitted a letter to BaFin, the German regulator, on the interpretation of the German High Frequency Trading Act.  In the letter, MFA and AIMA request that BaFin issue guidance that an investment manager trading on behalf of its funds would not be interpreted to be “dealing on own account” and subject to the definition of high frequency trading and the associated licensing regime.  MFA and AIMA also make recommendations on the interpretation of certain terms used in the HFT Act, including infrastructure intended to minimize latency times, high intraday message rate, algorithmic trading, and flagging of algorithmic orders.