MMI Comment Letter to the CFTC Regarding Reg AT

MMI Comment Letter to the CFTC Regarding Reg AT
We believe updating Commission rules in response to the evolution from pit trading to electronic trading is not only needed, but can ensure that the Agency is at the forefront of establishing a suitable regulatory regime reflecting contemporary market circumstances. That support stated, which covers the vast majority of the Proposal, we have grave concerns with section § 1.81(a), that AT Persons must produce for inspection “a source code repository.”  We believe this will place the trade secrets and intellectual property of algorithmic trading firms at precarious, unwarranted and unnecessary risk.