Dear CII Members:

CII staff would be very interested in fund member views/comments on the following high frequency trading topics.  Please provide any views and comments you may have to CII General Counsel Jeff Mahoney at jeff@cii.org by May 12, 2015.  The source of any information received will be treated as confidential information by CII staff.  

1. Whether you believe that HFT improves liquidity or market efficiency to the benefit of your fund?  Please explain the basis for your view.

2. Whether you believe that HFT includes harmful strategies or unfair advantages that disadvantage your fund?  Please explain the basis for your view.

3. Whether you believe that any of the following approaches to addressing concerns about HFT are appropriate (or inappropriate)?  Please explain the bases for your views. 

1. Data Driven Approach – Improve Regulatory Information – Consolidated Audit Trail, Large Trader Reporting, MIDAS

2. Enhance Risk Controls/Technology Oversight – Market Access Rule, Regulation SCI

3. Address Regulatory Gaps – Dealer Registration, FINRA Membership

4. Improve Market Transparency – Institutional Order Routing, ATS Operations

5. Anti-Disruptive Trading Rule

4. Whether you have any other views or opinions about HFT that you would like to share with CII staff.

Thank you for your time and support of CII.

Warmly,

Jeff Mahoney