Hudson River Trading Comment Letter to the CFTC Regarding Reg AT

Hudson River Trading Comment Letter to the CFTC Regarding Reg AT
(MMI Founding Member) Hudson River Trading supports the Commission’s objective of updating regulations to recognize and adapt to modern, automated markets.  Although these requirements will pose an additional cost and staffing burden on automated trading firms, they will provide important safeguards for the market.  Although we are broadly supportive of the Commission’s objectives, we are concerned about the requirement of proposed Regulation AT that AT Persons provide unfettered access to their Algorithmic Trading Systems (“ATS”) source code to both the Commission and the U.S. Department of Justice.