MFA Submits Comments on Hong Kong Consultation on Electronic Trading

On September 23, MFA submitted comments to the Hong Kong Securities and Futures Commission on its consultation paper on the regulation of electronic trading.  In the letter, MFA supports the requirement that intermediaries implement pre- and post-trade risk controls.  MFA believes, in regulating electronic trading, there should be an important distinction between an intermediary/vendor that provides electronic connectivity services (i.e., connectivity and routing access to liquidity centers) and an end-user, such as a Fund Manager, who uses such service.  An end-user should be responsible for technology, such as software programs, it develops to implement its trading strategy; but it should be held to a different standard because its trades will/should be filtered through an intermediary’s electronic trading system.  As such, an end-user’s trading activity will be less likely to cause market disruptions and will present less financial risk to the financial system.  Intermediaries should be held to a higher standard with regard to electronic trading because they are selling the connectivity and technology to the public.  As the access point to an exchange or other market centers, intermediaries present greater financial risk.