The CFTC has issued guidance and a number of exchanges, including CME and ICE, have issued express rules prohibiting disruptive trading practices. The guidance and the rules provide broad prohibitions yet limited detail on the types of practices that are prohibited. As such, there is a lack of clarity regarding whether existing trading practices may raise red (or yellow) flags.
Cadwalader, Wickersham & Taft LLP will host an intimate and interactive roundtable discussion regarding the application of the new disruptive trading practices guidance and rules to existing trading practices. In particular, the roundtable will discuss:
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What is “spoofing” and what are the common elements in recent spoofing cases? Is there a requirement for an impact on price?
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Do the common elements in recent spoofing cases foreshadow future cases?
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In an illiquid market, how do we expect the CFTC or the exchanges to evaluate whether the concept of “waking up the market” constitutes spoofing?
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Does “testing” the market constitute spoofing?
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What are the factors to differentiate best practices in execution and allegedly disruptive conduct?
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Do limit orders or a spread executed as separate trades raise concerns about the CFTC’s prohibition against violating bids or offers?
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Cadwalader attorneys Tony Mansfield, Anne Tompkins, and Neal Kumar, along with Dr. Greg Leonard, Vice President with Cornerstone Research, will facilitate the interactive discussion.
