Technological Changes on Market Integrity & Efficiency

SIFMA provides comments to the International Organization of Securities Commissions (IOSCO) on the IOSCO Technical Committee Consultation Report: Regulatory Issues Raised by the Impact of Technological Changes on Market Integrity and Efficiency.  SIFMA responds to the questions posed in the IOSCO report and offers views on high frequency trading (HFT) and other issues.  Regarding HFT, SIFMA notes that, when considering the various practices and tools often utilized in HFT, it is important to keep in mind that HFT is a type of trading and not a type of trader.  Not all market participants engage in HFT, and not all market participants that are generally categorized as “high frequency traders” actually employ HFT strategies. SIFMA believes that HFT provides many benefits to the markets, but also supports a review of HFT in our markets and of whether additional regulatory measures are needed or not.