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MOSCOW — Never let it be said that the government of Georgia thinks small.
Among the audacious plans to come out of Tbilisi in recent years: To become the first city with free WiFi throughout (has not happened). To replace all Russian-language college textbooks with equivalents in English (efforts well under way). To expunge the hulking legacy of Soviet architecture (good luck).
In that spirit, this week Georgia announced plans to replace its entire fleet of state-owned cars with electric or hybrid vehicles within four years. Georgia is the first country in the world to make this commitment, said Vera Kobalia, whose ministry — formerly the Ministry of the Economy — has been renamed the Ministry of the Economy and Sustainable Development.
Ms. Kobalia said Georgia — which has a rich supply of cheap hydroelectric power from dams in the Caucasus Mountains — could act as a global laboratory for the use of electric cars.
"We can see how the program will work in Georgia, on a smaller scale, and we hope that other countries will catch up," she said.
Mikheil Saakashvili, the New York-educated lawyer turned president, has a predilection for bold initiatives. His government is also flush with foreign aid, having received commitments of $4.55 billion after the 2008 war with Russia; the $1 billion pledged by the United States at the time made Georgia one of the largest recipients of American aid, after Israel, Egypt and Iraq.Continue reading the main story
Georgia is in talks with several companies, including General Motors, about the purchase of about 4,000 vehicles. Trucks and larger cars, including those in the presidential motorcade, will be exempted, since the electric vehicles available today are inadequately powered or armored, Ms. Kobalia said.
As part of the sale, manufacturers will be asked to build service and recharging stations, easing the way for ordinary Georgians to switch to electric cars.
Based on retail prices in the United States, and not including the American federal income tax rebate, 4,000 Chevy Volt sedans would cost Georgia about $164 million, while the same number of Nissan Leafs or Toyota Priuses would cost $128 million and $88 million, respectively.
Since becoming president in 2004, Mr. Saakashvili has vigorously cultivated ties with the United States and sought to reduce dependency on Russia. The Georgian Army has committed troops to Iraq and Afghanistan and switched from Kalashnikovs to American-made M-4 rifles.
General Motors, a majority of which is still owned by the United States government, confirmed it is in talks with Tbilisi, but suggested in a statement that its initial production run of Chevy Volts was not focused on Georgia.
"We appreciate their strong interest and will continue the dialogue," the statement said. "At this time, our primary focus is on a successful U.S. Volt launch."Continue reading the main story


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Outdoor Activities Can Be Rewarding For Gamers
Gaming is an immensely self-fulfilling activity. You see, gaming can allow you to meet new, interesting people over the internet, and perfect your gaming skills and even eke out a living that will sustain you in the gaming world.
Gaming is limitless with possibilities. In fact, you can even consider gaming full-time and get your revenue by turning it into business and linking it with blogs, YouTube channels and other related merchandise.
And you shouldn't be anxious about your traffic; indeed, a lot of YouTube subscribers love watching gamers execute their roles. So, such a hefty pay is guaranteed. And there are plenty of games, gaming platforms, and related websites; and for this reason, your chance to find new and interesting people is something that is practical. Things have changed considerably when it comes to gaming.
However, spending most of your time playing games can pose negative health risks in your life. You may even injure your relationships; always have in mind that you have loved ones who need your time for bonding. What is more, you may begin to experience problems with your circulatory system, elevated heart rate and develop sleeping disorders.
And there are the chances of gaining weight unnecessarily – this is burdensome. And yes, gaming is irresistibly great – but then you need not forget that you have a responsibility to manage yourself. Read on and build your knowledge on some of the best outdoor activities that can ensure you are leading a healthy life while at the same time maintaining your gaming lifestyle.
To start with, you should play some AR Games. And these Augmented Reality games are amazing – you have an opportunity to play it on your smartphone and get such amazing feeling. Augmented reality games, just like Pok?mon Go, you can play your AR game even when going about your duties. Some of the best AR gamers that you can get these days are Follow Me Dragon, ARZombie and Arise.
It is also converting to go on hiking. It is such an amazing way to rejuvenate yourself and enjoy the great landscapes. And you get a chance to meet new people – you get to build your spirits and get motivated. You also have chance to build the spirit of teamwork. You can even get contacts of your major opponents. That is why you should ensure that you meet people in real life. You may even choose to participate in some fabulous real-time sports together.
If you love online role-playing games or those games that have plot development and coherent storyline, then you take a live-action role.
If you feel you want to know more about this, you may have to view here for more or visit this website here!


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The Single Strategy To Use For Xtreme Termite Control
Boracare is a unique borate-based product which offers prevention and control for Termites, Carpenter Ants, Powderpost Beetles and Decay Fungi. Boracare can be used on many unfinished or raw timber including plywood, particleboard, and timber structural components. Boracare can also be used to prevent subterranean termites from forming tubes on surface such as concrete, block, brick, metals, and PVC plumbing pipes found in structures.
Please refer to the product label for the right usage rate for your specific needs. Boracare should be mixed with warm water in a bucket until it's thoroughly dispersed in the water. Boracare should never be mixed right in sprayers as the product is quite thick and will clog the sprayer if it is not premixed in warm water.
Indoors, Boracare can be applied on infested wood, wooden elements of furniture, wood flooring, and stud walls. Apply Boracare until surfaces are soaked, but not to the point of runoff. Use Boracare in a well-ventilated place, or use a respirator during application in confined locations like crawl spaces or attics. .
Outdoors, all raw wooden elements such as fenceposts, decks, and new wooden siding can be treated. Do not apply within 48 hours of rain or snow. For elements that are going to be exposed to rain and sunlight, wait at least 48 hours for Boracare to dry before painting, staining, or sealing with a water resistant product.
5 Easy Facts About Xtreme Termite Control Described
Termites can be one of the most damaging insects to your house. Theyre not just annoying, but they can really damage the structural integrity of the most important investment. In the southern United States it is estimated that there can be anywhere from 15-25 active termite colonies in any given acre of land.
At Do My Own Pest Control we've got all of the different pest control products you need to live pest free, even from termites. .
Termites are a massive problem and a severe threat to the value and structural integrity of your home. But on account of their reclusive nature, it can be tough to tell whether or not your home is troubled by these insects. Therefore you ought to know the following termite signs which may indicate a problem in your home and plan to act to eliminate them if they're present. .
What Does Termite Control Yellow Pages Do?
The most common signs of termite infestation are a raised tunnel of grime also known as a termite mud tube that contributes to the home that is under siege. These tunnels can also be found on the home itself, and therefore are a surefire way of knowing that you have termites.
These tunnels also present a serious threat to the wood in your house, since it does not take long for all these wood-destroying insects to cause serious harm. .
Another of those tell-tale termite signs is finding their waste products around the wood in your home. It is generally a powder together with the consistency and appearance of sawdust, and if it appears near cracked or cracked timber, you can be sure you have a problem on your hands.
All About Termite Control Yellow Pages
Any one of these signs of termite damage are reason enough to begin a termite treatment plan straight away. .
The process for how to tell if you've termites is most readily done by looking for both of these signs, even though there are various additional methods that can help. Examining the actual interior of your home in crawlspaces and underneath your home can tip you off if you see the signs of termite in home.
There are three different kinds of termites which are most likely to infest your house: Subterranean termites, drywood termites, and dampwood termites. Here is a short description of each kind.
The 2-Minute Rule for Xterm Termite Control
Subterranean: Main reproductives are black to light yellow-brown in colour; Wings are pale or smoky grey to brown in color with few observable veins; to 3/8 inch long. Secondary reproductives are white to cream in color, wingless, or very short wings. Workers make up the majority of a colony and are white in colour, wingless, and to 3/8 inch long.
Drywood: These colonies contain a caste system of workers, soldiers and reproductives, that can be up to inch longer than subterranean termites. Workers make up most the colony; they're about 1/8 inch long, white to cream in color, and have no wings. Critics defend the colony against other insects which may attack the click here to find out more colony; they're white and wingless with big brown heads and limbs.
Dampwood: The Dampwood termite is occasionally known as the"rotten wood" termite and is connected with high moisture content and timber rot. In 3/8" into" long, the dampwood termite is larger than both the drywood and subterranean. Soldiers defend the colony against other insects which may attack the colony; they've a flattened brown head with long dark brown to black mandibles.


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By Alistair Wong , December 8, 2018. 1:30 pm
<img style = "display: inline; border: 0px;" title = "Joker" src = "http://www.siliconera.com/wordpress/wp-content/uploads/2018/12/joker_thumb.png" alt = "Joker" width="554″ height="313″ border="0″ />
A new rumor has surfaced Persona 5 to the Nintendo Switch, which is particularly relevant after the announcement of the main character Joker Super Smash Bros. Ultimate as a DLC fighter.
The information comes from the Persona Central author Mystic Distancewho have stated in a series of now-deleted tweets that they "have a good authority from good sources," with clear evidence Persona 5 comes in 2019 to the switch.
Although the name or exact release window was not revealed, MysticDistance said that a switch version has been under consideration for some time since mid-2017 and will contain game customizations to include new aspects in the scenario along with other requested additions. The upgraded version also appears to be announced for Switch on the day that Joker is playable Super Smash Bros. Ultimate,
As early as April 2017, MysticDistance discovered that a number of Atlus domains were registered under "ryusoffice Corp, Inc.". Possibly related to Persona 5 are the following domains:
Persona 5 is available for the PlayStation 4.
Video game stories from other websites on the Internet. These links leave Siliconera.


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Read Lal Kitab book reviews & author details and more at Shri Girdhari Lal Sharma, the author of the original 'Lal Kitab' proposed remedies that . Lal Kitab (Teesra Hissa) is the third book of the five volumes written by Pt. the monopoly of handful of people who were not ready to share the original. 10 Sep Lal Kitab is not a name of one single book. There are five books published during year to written by Pt. Roop Chand Joshi. Written in.
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This book is very useful for every one. So as to make it easy for its readers, Pandit Ji makes use of verse in his writing.
Tag: free download original lal kitab in hindi
Also he has created few of his own hypotheses that may or may not be true. Published on 9 April Soon after, the market was flooded with various versions of Lal Kitab, but the original versions of it were believed to have been written by Pandit Roop Chand Joshi of Punjab, original lal kitab in There are many new editions available on Lal Kitab. Keeping in mind a original lal kitab in of conduct, dharma, practical aspects, good conduct and the basic principles of life and the need for proper discipline in society, the author had suggested the remedies which were accepted by the common men by heart.
What is Lal Kitab? Reply to this topic Notify me of new comments via email.
The basics of a horoscope and Lal Kitab astrology are introduced. The book has been popular in both Indian and Pakistan, many of its astrological remedies upaya or farmans have become part of every day culture in the subcontinent, like throwing coins into a river while passing over it, original lal kitab in grass to cow, bread lak a dog and offering meals to unmarried girls etc.
February 10, at 9: There are five editions of Lal Kitab written during the period laal to by Pt.
Add to Spiritual Diary. Likewise in case of an afflicted sun, throwing a copper coin in flowing water is very useful.
Yogita – favorite favorite favorite favorite favorite – March 17, Subject: This year Dussehra is falling on a Saturday, know why original lal kitab in auspicious for you. Posted March 29, Most of the people in India are very well acquainted with the name of Lal Kitbag, originally this book was written by Lzl Girdhari Lal Sharma in Urdu language. But if you cannot, it becomes more difficult and depends upon which language you can read better.
I was expecting remedies for everyday usage but it kind of teaches you astrology which was not my intent. One Rupee six Annas Was Available from: They will be of immense value for those who know Urdu, and oroginal who do not know Urdu they will original lal kitab in a good collectors item.
Self-Healing Through the Stars. It is not mentioned which Arun Samhita is translation of which edition of Lal Kitab. There are five books published during year to written by Pt. Remedy 3 Try to get the blessings roiginal elderly people in your neighborhood, office or workplace.
But few writers had changed the actual code of Lal Kitab. This book contains almost nothing about oritinal astrology dominates origiinal volume.
Product details Paperback Language: Pandit Ji was also very eager to share his knowledge with his readers and therefore, he published these books in quick succession.
First publishing Apart from the original scriptures on Astrology, Lal Kitab is also gaining ppopularity day-by-day. Published on 26 May The names of the five set of books authored original lal kitab in Pt.
Lal Kitab: The mystery behind it
Difficult to follow what is given in the book. A Rare Book on Astrology. Poetic verses with philosophy and hidden nuances form the core farmanns or upaya remedy recommended of the book.
Upload or insert images from URL. See all 12 reviews. Urdu Number of copies printed: Now these books are available for unrestricted download from: Also introduced is the amazingly simple Varshphal table for making annual progressed horoscopes.
Lal Kitab – Wikipedia
Later on, acknowledging the paucity of money and time, Shri Girdhari Lal Sharma, the author of the original 'Lal Kitab' proposed remedies that were simple and required least expense kittab money.
A copy of first book published in is preserved in Lahore Museum. Original lal kitab in try again later.


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The lunar new year of the snake has brought positive signals of another successful national tourism year 2013 with significant increase in the number of tourists to Vietnam in general and Quang Nam Province specifically.
|Cu Lao Cham
According to Mr. Tran Tan Dung - The Secretary of Party Committee of Tan Hiep Town, Hoi An City, from the 1st to the 8th day of the lunar new year, Cu Lao Cham welcomed more than 4,000 visitor (increase by 50% compared to the same period last year).
On the 2nd day and 7th day of Tet Holiday, this famous tourism destination even reached 800 visitors each day. Mr. Tran Tan Dung explained this great achievement is thanks to restless attempt of the local government to improve the service quality in Cu Lao Cham, as well as the support of the nice weather to attract more visitors to come and worship Hai Tang Pagoda.
This unspoiled destination will help to boost tourism to Danang – Hoi An. Tourists now can enjoy exotic sight-seeing with better travel services. Visit Grayline Vietnam and check out more about our new Danang – Hoi An day tours. Leave your feedback and enquiry at firstname.lastname@example.com and we will get back to you as soon as possible.


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Pointers and/or advice on *low tech* marine tanks?
When you started in freshwater did you start with a planted tank?
The reason I asked is because you might wish to consider starting
with a FOWLR system (fish only with live rock). This is a marine
tank, just not a full fledged REEF tank. They seem much less
intensive than a full reef.. I've been going about two years and am
just now starting down the reef road.
IMO, you can learn a lot without a major investment. Simple hang on
filter, maybe an airstone powered in-tank skimmer, live sand, live
rock, and some damsel fish and clowns. At $4 to $9 a pound your live
rock will probably be the most expensive item in the tank. If you
mess up your only out a few inexpensive, but colorful, fish. Mess up
badly and your out the life on your live rock too (but that can be
probably be reseeded). Your not out a group of expensive corals.
Another plus is you can slowly build up your equipment as you go
without doing it all at once.
Getting your coralline growing and growing well in a less complicated
fowlr system should be one sign of a healthy tank. Also, later on you
can put some pulsing zenia (not very expensive, but cool to watch, and
grows like crazy in good conditions) in the tank. I have been told
that zenia are a great barometer of your water quality and overall
tank health. If you can keep them growing and multiplying then you
are about ready for the reef. Some LFS will even take them in trade
for store credit.
There are pluses for starting out this way. There are pluses for
starting out with a full reef or nano-reef (be sure to check out
www.garf.org ). It will ultimately be what your comfortable with.
Hell, my daddy taught me to swim by throwing me in the deep end of a
stock tank. And I learned to swim real fast. The only real problem I
had was getting out of the burlap sack.
Merry Christmas,
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Table of Contents Back to Top
- Electronic Comments
- Paper Comments
- I. Background
- A. IEX's Form 1
- B. Regulation NMS Concept of an Automated Quotation and Protected Quotation
- C. IEX's Access Delay
- D. Comments on IEX's Proposed Access Delay
- II. Commission's Proposed Interpretation
- III. Solicitation of Comment
- Footnotes
DATES: Back to Top
Comments should be received on or before April 14, 2016.
ADDRESSES: Back to Top
Comments may be submitted by any of the following methods:
Electronic Comments
- Use the Commission's Internet comment form (http://www.sec.gov/rules/sro.shtml); or
- Send an email to email@example.com. Please include File Number S7-03-16 on the subject line.
Paper Comments
- Send paper comments in triplicate to Brent J. Fields, Secretary, Securities and Exchange Commission, 100 F Street NE., Washington, DC 20549-1090.
All submissions should refer to File Number S7-03-16. This file number should be included on the subject line if email is used. To help the Commission process and review your comments more efficiently, please use only one method. The Commission will post all comments on the Commission's Internet Web site (http://www.sec.gov/rules/other.shtml). Comments are also available for Web site viewing and printing in the Commission's Public Reference Room, 100 F Street NE., Washington, DC 20549, on official business days between the hours of 10:00 a.m. and 3:00 p.m. All comments received will be posted without change; the Commission does not edit personal identifying information from submissions. You should submit only information that you wish to make publicly available.
FOR FURTHER INFORMATION CONTACT: Back to Top
Richard Holley III, Assistant Director, at (202) 551-5614, Michael Bradley, Special Counsel, at (202) 551-5594, or Michael Ogershok, Attorney-Advisor, at 202-551-5541, all in the Office of Market Supervision, Division of Trading and Markets, Securities and Exchange Commission, 100 F Street NE., Washington, DC 20549-7010.
SUPPLEMENTARY INFORMATION: Back to Top
I. Background Back to Top
A. IEX's Form 1
On August 21, 2015, Investors' Exchange LLC ("IEX") submitted to the Commission a Form 1 application seeking registration as a national securities exchange under Section 6 of the Securities Exchange Act of 1934 ("Act"). [1] On September 9, 2015, IEX submitted Amendment No. 1 to its Form 1 application. [2] Notice of IEX's filing of its Form 1 application, as amended, was published for comment in the Federal Register on September 22, 2015. [3] Recently, IEX submitted three additional amendments to its Form 1 application. [4] Simultaneously with the issuance of this proposed interpretation, the Commission issued a release to notice Amendment Nos. 2, 3, and 4 to IEX's Form 1 application, instituted proceedings to consider whether to grant or deny IEX's application, and designated a longer period for Commission action to accommodate those proceedings. [5]
The Commission has received extensive comments on IEX's Form 1 application, [6] and IEX has submitted several letters in response to concerns raised by commenters. [7] Among other things, a number of commenters on IEX's Form 1 application asserted that a unique feature of IEX's design—specifically, its Point-of-Presence ("POP") and "coil" access delay—would preclude IEX's best-priced quotation from being a "protected quotation" under Regulation NMS if the Commission grants IEX's exchange registration. [8] IEX contests this assertion, as do certain other commenters. [9]
As discussed more fully below and as highlighted by a number of commenters on IEX's Form 1 application, [10] the Commission preliminarily believes that IEX's proposed POP/coil structure raises questions about prior Commission statements with respect to the definition of an "automated quotation" under Regulation NMS. In light of market and technological developments since the adoption of Regulation NMS in 2005, the Commission is proposing and requesting comment on an updated interpretation to permit more flexibility for trading centers with respect to automated quotations to allow them to develop innovative business models that do not undermine the goals of Rule 611 of Regulation NMS. Specifically, the Commission is proposing to interpret "immediate" when determining whether a trading center maintains an "automated quotation" for purposes of Rule 611 to include response time delays at trading centers that are de minimis, whether intentional or not.
B. Regulation NMS Concept of an Automated Quotation and Protected Quotation
In general, Rule 611 under Regulation NMS (the "Order Protection Rule," or "Trade-Through Rule") protects the best automated quotations of exchanges by obligating other trading centers to honor those quotes by not executing trades at inferior prices or "trading through" such best automated quotations. [11] Only an exchange that is an "automated trading center" [12] displaying an "automated quotation" [13] is entitled to this protection. [14] Trading centers must establish, maintain, and enforce written policies and procedures that are reasonably designed to prevent trade-throughs of protected quotations, unless an exception or exemption applies. [15]
When it adopted Regulation NMS, the Commission explained that the purpose of the Order Protection Rule was to incentivize greater use of displayed limit orders, which contribute to price discovery and market liquidity. [16] In discussing whether to apply order protection to manual quotations, the Commission stated that "providing protection to manual quotations, even limited to trade-throughs beyond a certain amount, potentially would lead to undue delays in the routing of investor orders, thereby not justifying the benefits of price protection." [17] The Commission also noted that "those who route limit orders will be able to control whether their orders are protected by evaluating the extent to which various trading centers display automated versus manual quotations." [18]
There are several provisions in Regulation NMS that impact whether the Order Protection Rule applies. First, Rule 600(b)(58) defines a "protected quotation" as a "protected bid or a protected offer." [19] Rule 600(b)(57), in turn, defines a "protected bid or protected offer" as a quotation in an NMS stock that is: (i) Displayed by an "automated trading center," (ii) disseminated pursuant to an effective national market system plan, and (iii) an "automated quotation" that is the best bid or best offer of a national securities exchange. [20]
In order for an exchange to operate as an "automated trading center," it must, among other things, have "implemented such systems, procedures, and rules as are necessary to render it capable of displaying quotations that meet the requirements for an `automated quotation' set forth in [Rule 600(b)(3) of Regulation NMS]." [21] Rule 600(b)(3) defines an "automated quotation" as one that:
i. Permits an incoming order to be marked as immediate-or-cancel;
ii. Immediately and automatically executes an order marked as immediate-or-cancel against the displayed quotation up to its full size;
iii. Immediately and automatically cancels any unexecuted portion of an order marked as immediate-or-cancel without routing the order elsewhere;
iv. Immediately and automatically transmits a response to the sender of an order marked as immediate-or-cancel indicating the action taken with respect to such order; and
v. Immediately and automatically displays information that updates the displayed quotation to reflect any change to its material terms. [22]
Any quotation that does not meet the requirements for an automated quotation is defined in Rule 600(b)(37) as a "manual" quotation. [23]
In the Regulation NMS Adopting Release, the Commission elaborated on the meaning of the terms "immediate" and "automatic" as those terms are used in the Rule 600(b)(3) definition of an automated quotation. Specifically, with respect to the meaning of the term "immediate," the Commission stated that "[t]he term `immediate' precludes any coding of automated systems or other type of intentional device that would delay the action taken with respect to a quotation," [24] and that the standard for responding to an incoming order "should be `immediate,' i.e., a trading center's systems should provide the fastest response possible without any programmed delay." [25]
The Commission provided context in the Regulation NMS Adopting Release as to the intent behind the Order Protection Rule and the distinction between "automated quotations" and "manual quotations." At the time of the adoption of Regulation NMS, manual quotations and markets that primarily were centered around human interaction in a floor-based trading environment, including "hybrid" trading facilities that offer automatic execution of orders seeking to interact with displayed quotations while also maintaining a physical trading floor, experienced processing delays for inbound orders that were measured in multiple seconds. [26] In contrast to floor-based and hybrid markets, at the time Regulation NMS was adopted, newer automated matching systems removed the human element and instead immediately matched buyers and sellers electronically. The Commission sought to achieve the goals of the Order Protection Rule and maintain the efficiencies of the markets by protecting only automated quotations that were "immediately" accessible, and allowing trade-throughs of those that were not. [27]
In Rules 600 and 611, the Commission did not set a maximum response time for a quotation to be an "automated quotation." [28] While a number of commenters on Regulation NMS advocated for a specific time standard, ranging from one second down to 250 milliseconds, [29] for distinguishing between manual and automated quotations, [30] the Commission declined to set such a standard, noting that "[t]he definition of automated quotation as adopted does not set forth a specific time standard for responding to an incoming order." [31] Rather, the Commission specifically sought to avoid "specifying a specific time standard that may become obsolete as systems improve over time," and agreed with commenters that "the standard should be `immediate' i.e., a trading center's systems should provide the fastest response possible without any programmed delay." [32]
However, the Commission believed that "immediate" should not be construed in a way to frustrate the purposes of Rule 611 and crafted several exceptions to Rule 611, two of which use a one second standard. [33] Specifically, Rule 600(b)(1) addresses the applicability of the trade-through requirements with respect to quotations of automated trading centers that experience a "failure, material delay, or malfunction," by allowing other trading centers to trade-through such quotations. [34] In the Regulation NMS Adopting Release, the Commission provided an interpretation of the phrase "material delay" as one where a market was "repeatedly failing to respond within one second after receipt of an order." [35] The Commission similarly established a one-second standard for the exception in Rule 611(b)(8), which excepts trade-throughs where the trading center that was traded-through had displayed, within the prior one second, a price equal or inferior to the price of the trade-through transaction. [36] In discussing the 611(b)(8) exception, the Commission stated that it "generally does not believe that the benefits would justify the costs imposed on trading centers of attempting to implement an intermarket price priority rule at the level of sub-second time increments. Accordingly, Rule 611 has been formulated to relieve trading centers of this burden." [37]
C. IEX's Access Delay
IEX, which currently operates a trading platform as an alternative trading system, is seeking to register as a national securities exchange. If its registration is granted, IEX would operate an electronic order book for NMS stocks. [38] IEX's POP and coil infrastructure is how IEX users ("Users") would connect to IEX. [39]
IEX has represented that access to IEX by all Users would be obtained through a POP located in Secaucus, New Jersey. [40] According to IEX, after entering through the POP, a User's electronic message sent to the IEX trading system would traverse the IEX "coil," which is a box of compactly coiled optical fiber cable equivalent to a prescribed physical distance of 61,625 meters (approximately 38 miles). [41] After exiting the coil, the User's message would travel an additional physical distance to the IEX system, located in Weehawken, New Jersey. [42] IEX has represented that routable orders would thereafter be directed to the IEX routing logic, and non-routable orders would be directed to the IEX matching engine. [43] According to IEX, the coil, when combined with the physical distance between the POP and the IEX system, would provide IEX Users sending non- routable orders to IEX with 350 micro seconds [44] of one-way latency. [45] For purposes of this notice, IEX's process for handling non-routable orders is hereinafter referred to as the "POP/coil delay."
According to IEX, all incoming messages (e.g., orders to buy or sell and any modification to a previously sent open order) from any User would traverse the proposed POP/coil delay. [46] In addition, all outbound messages from IEX back to a User (e.g., confirmations of an execution that occurred on IEX) would pass through the same route in reverse. [47] IEX's direct proprietary market data feed, which is an optional data feed that IEX would make available to subscribers, also would traverse the coil before exiting at the POP. [48] As a result, a non-routable immediate-or-cancel ("IOC") order, which is a type of order that IEX would permit Users to send to the IEX system, would traverse the proposed POP/coil (and its attendant 350 microsecond delay) before arriving at the IEX system and potentially executing against a displayed quotation on IEX. Likewise, the response from the IEX system to the User indicating the action taken by the IEX system with respect to such IOC order also would traverse the POP/coil and experience a 350 microsecond delay. [49]
D. Comments on IEX's Proposed Access Delay
Several commenters on IEX's Form 1 application questioned whether IEX's operation of the proposed POP/coil would be consistent with the Order Protection Rule. [50] Their main assertion is that the 350 microsecond latency caused by the POP/coil calls into question whether IEX's quotations meet the definition of "automated quotation," and therefore would be a "protected quotation," under Regulation NMS and Rule 611 in particular. [51] These commenters generally cited to language, discussed above, from the Regulation NMS Adopting Release where the Commission elaborated on what it means for a quotation to be an "automated quotation," including statements that the term "immediate," as it relates to the definition of an automated quotation, means that "a trading center's systems should provide the fastest response possible without any programmed delay" [52] and "precludes any coding of automated systems or other type of intentional device that would delay the action taken with respect to a quotation" (emphasis added). [53] Based on this language, these commenters contended that IEX's quotation is not consistent with the definition of automated quotation, or at least questioned whether it can be so considered. [54]
Several commenters urged the Commission not to decide this question in the context of IEX's Form 1 application. [55] One commenter urged the Commission, should it disagree with the contention that IEX's quotation cannot be protected, to explain its reasoning in a rulemaking proceeding or exemptive order that is subject to public vetting. [56] Another commenter urged the Commission "to articulate clear standards regarding the precise amount of time an intentional device can delay access to the quotation of a registered exchange and still be considered an automated quotation." [57] This commenter supported an interpretation of the definition of an automated quotation that would include the delay resulting from IEX's POP/coil, but further urged the Commission to articulate clear regulatory standards that would be applicable to all trading venues and market participants. [58]
Other commenters offered support for IEX's proposed access delay, and challenged the assertion that IEX's quotation would not meet the definition of "automated quotation" under Regulation NMS. [59] According to one commenter, the Commission's "larger plan" in requiring protected quotes to be "immediately and automatically" accessible under Regulation NMS was "to encourage automated markets and prevent exchanges from favoring their own manual markets, so the SEC protected an exchange's lit, automated quotes and banned any programmed tricks or devices an exchange might use to give human traders a chance to intervene or any kind of an edge over automated quotes." [60] In addition, this commenter further asserted, "[t]hat `immediately' simply prohibits discrimination favoring manual markets is all the more obvious in the [Regulation NMS] Adopting Release's discussion of self-help" where, according to the commenter, "[t]he SEC had every opportunity to define `immediately' in absolute terms and declined to do it," and instead "only went as far as suggesting one second was a reasonable upper bound for declaring self-help and left it up to the marketplace to reward fast markets or punish slow markets." [61]
Several commenters noted that there is latency associated with the transmission of orders to protected quotations at existing market venues—and in some cases, those latencies are greater than that associated with transmitting orders to IEX even factoring in the proposed POP/coil delay. [62] One commenter argued that the 350 microsecond proposed POP/coil delay "would be so de minimis as to have no appreciable impact on market behavior" and is "not much more than the normal latency that all trading platforms impose." [63] Another commenter did not find the proposed POP/coil delay "particularly problematic, as the time gap is minimal, and (even including the speed bump) IEX matches orders faster than a number of other markets." [64] One commenter noted that the POP/coil 350 microsecond delay "is orders of magnitude shorter than the variable lags between the SIP and the proprietary feeds," and asserted that the proposed POP/coil delay is consistent with existing practices already approved by the Commission. [65]
IEX asserted that the language of the Order Protection Rule and the Regulation NMS Adopting Release, when considered in light of the context in which the Order Protection Rule was adopted, do not compel the conclusion that IEX's quotes should be considered "manual quotations" instead of "automated quotations." [66] In addition, IEX noted that not all exchange matching systems are located in the same vicinity and asserted that "there is no reason to think that the Commission by referring to `intentional device' meant somehow to set geographic standards with regard to exchange matching system connections generally, or to prescribe the exact length of cable that is or is not allowable." [67]
According to IEX, its POP/coil structure "represents a form of prescribed physical distance to which all users are subject when submitting orders to IEX's trading system" and "[i]n this sense, it is no different from means that all exchanges impose to set the terms by which users can connect to their systems." [68] IEX stated that "the amount of latency imposed by the POP is less than or not materially different than that currently involved in reaching various exchanges based on geographic factors," and refers, by way of example, to the geographic distance that an order from the Chicago Stock Exchange's Secaucus, New Jersey data center must physically traverse before reaching the Chicago Stock Exchange's trading system in Chicago. [69] IEX also provided data from certain subscribers to IEX's ATS that, according to IEX, indicate that those subscribers' average latency when trading on IEX is comparable to that when trading on certain other exchanges, "is an order of magnitude less than that of the Chicago Stock Exchange," and "is on average less than the round-trip latency of the NYSE as well." [70]
II. Commission's Proposed Interpretation Back to Top
As discussed above, at the time Regulation NMS was adopted, the concept of an "automated quotation" was intended to address manual and hybrid automated-manual trading systems in relation to the trade-through requirements of Rule 611. Under Regulation NMS, a trading center must provide an "immediate" response for its quotation to be an "automated quotation." [71] Although the Commission did not set a maximum response time in Rule 600 or Rule 611 for a quotation to be an automated quotation, in the Regulation NMS Adopting Release the Commission stated that an immediate response meant "the fastest response possible without any programmed delay." [72] When Regulation NMS was adopted, however, the Commission was focused on the response time delays generated by manual interaction, and crafted exceptions to Rule 611 based on response times of one second. [73] Delays in the realm of sub-milliseconds, as presented by the IEX Form 1 application, were not contemplated by the Commission because they generally were not relevant or material for the slower trading technologies used by market participants at the time. [74]
As the speed of trading technology has increased since the adoption of Regulation NMS, [75] some trading centers have begun to explore ways to reduce the relevance of speed differentials of very small increments. [76] Proposals like IEX's POP/coil that intentionally delay access to an exchange's quotation, albeit by a sub-millisecond amount, raise questions about the prior interpretation with respect to the definition of an automated quotation under Regulation NMS. Accordingly, the Commission is proposing and soliciting comment on an updated interpretation from that provided in the Regulation NMS Adopting Release. [77]
Specifically, the Commission preliminarily believes that, in the current market, delays of less than a millisecond in quotation response times may be at a de minimis level that would not impair a market participant's ability to access a quote, consistent with the goals of Rule 611 and because such delays are within the geographic and technological latencies experienced by market participants today. For example, IEX's proposed POP/coil would introduce a 350 microsecond delay for a non-routable IOC order before it could access the IEX matching engine. The additional delay introduced by the coil itself, which is approximately 38 miles long, is effectively equivalent to the communications latency between venues that are 38 miles apart. [78] The Commission understands that today the distances between exchange data centers, or between the order entry systems of market participants and exchange data centers, may exceed, sometimes by many multiples, a distance of 38 miles. The Commission does not believe that these naturally-occurring response time latencies resulting from geography are inconsistent with the purposes of Rule 611. [79] At the same time, permitting the quotations of trading centers with very small response time delays, such as those proposed by IEX, to be treated as automated quotations, and thereby benefit from trade-through protection under Rule 611, could encourage innovative ways to address market structure issues.
Accordingly, the Commission today is proposing to interpret "immediate" when determining whether a trading center maintains an "automated quotation" for purposes of Rule 611 of Regulation NMS to include response time delays at trading centers that are de minimis, whether intentional or not. [80]
III. Solicitation of Comment Back to Top
The Commission requests comment all aspects of this proposed interpretation, including:
1. Would delays of less than a millisecond in quotation response times impair a market participant's ability to access a quote or impair efficient compliance with Rule 611?
2. In the current market, should the Commission interpret "immediate" as including a de minimis delay of less than one millisecond? Should the Commission consider other lengths? If so, what should they be?
3. Should the Commission be concerned about market manipulation? If so, specifically, what should the Commission focus on?
4. Should the Commission consider an alternative interpretation? If so, what should it be?
By the Commission.
Dated: March 18, 2016.
Brent J. Fields,
[FR Doc. 2016-06633 Filed 3-23-16; 8:45 am]
Footnotes Back to Top
2. In Amendment No. 1, IEX submitted updated portions of its Form 1 application, including revised exhibits, a revised version of the proposed IEX Rule Book, and revised Addenda C-2, C-3, C-4, D-1, D-2, F-1, F-2, F-3, F-4, F-5, F-6, F-7, F-8, F-9, F-10, F-11, F-12, and F-13. IEX's Form 1 application, as amended, including all of the Exhibits referenced above, is available online at www.sec.gov/rules/other.shtml as well as at the Commission's Public Reference Room.Back to Context
3. See Securities Exchange Act Release No. 75925 (September 15, 2015), 80 FR 57261. On December 18, 2015, IEX consented to an extension of time to March 21, 2016 for Commission consideration of its Form 1 application. See Letter from Sophia Lee, General Counsel, IEX, to Brent J. Fields, Secretary, Commission, dated December 18, 2015.Back to Context
4. In Amendment No. 2, filed on February 29, 2016, IEX proposed changes to its Form 1 application to, among other things, redesign its outbound routing functionality to direct routable orders first to the IEX router instead of directly to the IEX matching engine. See Letter from Sophia Lee, General Counsel, IEX, to Brent J. Fields, Secretary, Commission, dated February 29, 2016, at 1. In this manner, the IEX router would "interact with the IEX matching system over a 350 microsecond speed-bump in the same way an independent third party broker would be subject to a speed bump." See id. In Amendment No. 3, filed on March 4, 2016, IEX proposed changes to its Form 1 application to clarify and correct revisions to its rulebook that it made in Amendment No. 2. See Letter from Sophia Lee, General Counsel, IEX, to Brent J. Fields, Secretary, Commission, dated March 4, 2016. In Amendment No. 4, filed on March 7, 2016, IEX proposed changes to its Form 1 application to update Exhibit E to reflect changes it proposed in Amendment No. 2. See Letter from Sophia Lee, General Counsel, IEX, to Brent J. Fields, Secretary, Commission, dated March 7, 2016.Back to Context
5. See Securities Exchange Act Release No. 77406 (March 18, 2016) (File No. 10-222).Back to Context
6. The public comment file for IEX's Form 1 application (File No. 10-222) is available on the Commission's Web site at: http://www.sec.gov/comments/10-222/10-222.shtml.Back to Context
7. See Letters from Sophia Lee, General Counsel, IEX, to Brent J. Fields, Secretary, Commission, dated November 13, 2015 ("IEX First Response"); November 23, 2015 ("IEX Second Response"); and February 9, 2016 ("IEX Third Response"). See also Letter from Donald Bollerman, Head of Markets and Sales, IEX Group, Inc., to File No. 10-222, dated February 16, 2016 ("IEX Fourth Response") and Letter from IEX Group, Inc., to File No. 10-222, dated February 19, 2016 ("IEX Fifth Response").Back to Context
8. See, e.g., FIA First Letter; NYSE First Letter; Citadel First Letter.Back to Context
9. See IEX First Response and IEX Second Response. See also, e.g., Verret Letter; Leuchtkafer Second Letter.Back to Context
10. See infra text accompanying notes 49-57 (discussing comments on IEX's Form 1).Back to Context
11. See 17 CFR 242.611.Back to Context
12. See 17 CFR 242.600(b)(4).Back to Context
13. See 17 CFR 242.600(b)(3).Back to Context
14. See 17 CFR 242.600(b)(57) (defining "protected bid or protected offer"), 242.600(b)(58) (defining "protected quotation"); see also Securities Exchange Act Release No. 51808 (June 9, 2005) 70 FR 37496, 37504 (June 29, 2005) ("Regulation NMS Adopting Release") (stating that "[t]o qualify for protection, a quotation must be automated").Back to Context
15. 17 CFR 242.611(a)(1).Back to Context
16. See Regulation NMS Adopting Release, supra note 14, at 37516 and 37517.Back to Context
17. Id. at 37518.Back to Context
18. Id.Back to Context
19. 17 CFR 242.600(b)(58).Back to Context
20. 17 CFR 242.600(b)(57).Back to Context
21. 17 CFR 242.600(b)(4). Rule 600(b)(4) contains additional requirements that must be satisfied in order to be an automated trading center. Those requirements are not at issue for purposes of this proposed interpretation.Back to Context
22. See 17 CFR 242.600(b)(3). See also Regulation NMS Adopting Release, supra note 14, at 37504.Back to Context
23. Regulation NMS Adopting Release, supra note 14, at 37534. See also 17 CFR 242.600(b)(37) (defining "manual quotation").Back to Context
24. Regulation NMS Adopting Release, supra note 14, at 37534. The Commission also stated that, for a quotation "[t]o qualify as `automatic,' no human discretion in determining any action taken with respect to an order may be exercised after the time an order is received," and "a quotation will not qualify as `automated' if any human intervention after the time an order is received is allowed to determine the action taken with respect to the quotation." Id. at 37519 and 37534.Back to Context
25. Id. at 37519. In the case of IEX, its access delay involves hardware (i.e., coiled cable) and geographic dispersion, not software programming. See infra text accompanying notes 40-45. Nevertheless, it is an intentional delay. See id.Back to Context
26. See Regulation NMS Adopting Release, supra note 14, at 37500 n.21 ("One of the primary effects of the Order Protection Rule adopted today will be to promote much greater speed of execution in the market for exchange-listed stocks. The difference in speed between automated and manual markets often is the difference between a 1-second response and a 15-second response. . . .").Back to Context
27. See id. at 37501. More broadly, the Commission stated that the definition of "automated trading center" in Rule 600(b)(4) "offers flexibility for a hybrid market to display both automated and manual quotations, but only when such a market meets basic standards that promote fair and efficient access by the public to the market's automated quotations." Id. at 37520. This definition was an outgrowth of two floor-based exchanges' intention to operate "hybrid" trading facilities that would offer automatic execution against their displayed quotations, while at the same time maintaining a traditional trading floor. See id. at 37518. The Commission also explained that the Order Protection Rule took a substantially different approach to intermarket price protection than the existing trade-through protection regime at the time—the Intermarket Trading System ("ITS") Plan. See id. at 37501. As the Commission noted, the ITS provisions did not distinguish between manual and automated quotations and "fail[ed] to reflect the disparate speed of response between manual and automated quotations" as they "were drafted for a world of floor-based markets." Id. As a result, "[b]y requiring order routers to wait for a response from a manual market, the ITS trade-through provisions can cause an order to miss both the best price of a manual quotation and slightly inferior prices at automated markets that would have been immediately accessible." Id. See also supra note 26 (citing to footnote 21 of the Regulation NMS Adopting Release).Back to Context
28. See also id. at 37519 ("The definition of automated quotation as adopted does not set forth a specific time standard for responding to an incoming order.").Back to Context
29. A millisecond is one thousandth of a second.Back to Context
30. See id. at 37518.Back to Context
31. Id. at 37519.Back to Context
32. Id.Back to Context
33. See 17 CFR 242.611(b)(1) and (8).Back to Context
34. See 17 CFR 242.611(b)(1).Back to Context
35. See Regulation NMS Adopting Release, supra note 14, at 37519.Back to Context
36. See 17 CFR 242.611(b)(8).Back to Context
37. See Regulation NMS Adopting Release, supra note 14, at 37523.Back to Context
38. For more detail on IEX's proposed trading system, see IEX's full Form 1 application and Exhibits, as amended, which are available on the Commission's Web site at http://www.sec.gov/rules/other/otherarchive/other2015.shtml.Back to Context
39. To obtain authorized access to the IEX System, each User must enter into a User Agreement with the Exchange. See IEX Rule 11.130(a). The term "Users," for purposes of this notice, does not include IEX Services LLC, IEX's affiliated outbound routing broker-dealer.Back to Context
40. See IEX Second Response at 2.Back to Context
41. See IEX First Response at 3.Back to Context
42. See Exhibit E to IEX's Form 1 submission, at 12. See also IEX First Response at 3.Back to Context
43. See Amendment Nos. 2 and 3 to IEX's Form 1 application.Back to Context
44. A microsecond is one millionth of a second.Back to Context
45. See IEX First Response at 3. See also Amendment Nos. 2 and 3. Users sending routable orders would experience 700 microseconds of one-way latency. See Letter from Sophia Lee, General Counsel, IEX, to Brent J. Fields, Secretary, Commission, dated February 29, 2016, at 2.Back to Context
46. See IEX First Response at 3-4.Back to Context
47. See id.Back to Context
48. See id.Back to Context
49. See id. at 3. Outbound transaction and quote messages from IEX to the applicable securities information processor ("SIP") would not pass through the POP/coil, but instead would be sent directly from the IEX system to the SIP processor. See id. at 3-4.Back to Context
50. See, e.g., NYSE First Letter at 5; BATS First Letter at 3; FIA First Letter at 2; Nasdaq First Letter at 2; Citadel First Letter at 3.Back to Context
51. See, e.g., BATS First Letter at 2-4; FIA First Letter at 2; NYSE First Letter at 5-7; Nasdaq First Letter at 2; Citadel First Letter at 2-4.Back to Context
52. See, e.g., Nasdaq First Letter at 2; NYSE First Letter at 6. See also Regulation NMS Adopting Release, supra note 14, at 37519.Back to Context
53. See, e.g., BATS First Letter at 3; FIA First Letter at 2; Citadel First Letter at 3; Citadel Second Letter at 3; see also Regulation NMS Adopting Release, supra note 14, at 37534.Back to Context
54. See BATS First Letter at 3; FIA First Letter at 2; NYSE First Letter at 6-7; Nasdaq First Letter at 2-3; Citadel First Letter at 3-4; Citadel Second Letter at 3-4; Hudson River Trading Second Letter at 3-4.Back to Context
55. See, e.g., Citadel Second Letter at 4; Nasdaq Second Letter at 1-4; Direct Match Letter at 2-4; Scott Letter.Back to Context
56. See, e.g., Citadel Second Letter at 4.Back to Context
57. BATS First Letter at 3; see also BATS First Letter at 4, 6. A second commenter writing in support of IEX's POP/coil similarly urged the Commission to articulate the extent of permissible intentional, geographical, or technological delays for registered exchanges. See T. Rowe Price Letter at 2. A third commenter urged the Commission to not approve IEX's POP/coil without also establishing a maximum permissible delay for registered exchanges. See Jon D. Letter.Back to Context
58. See BATS Second Letter at 2.Back to Context
59. One commenter argued that such an assertion "rests on an overly formalistic reading of Regulation NMS that fails to account for the rise of high speed trading in the last decade." See Verret Letter at 4. Another commenter similarly criticized that assertion as dependent "on a self-serving read of Reg NMS, leaving out its history, its original meaning, and its subsequent interpretation." See Leuchtkafer Second Letter at 1.Back to Context
60. Leuchtkafer Second Letter at 1-2 (emphasis in original). This commenter pointed out that "[t]he standard by which to measure automated and protected quotes was ITS, or, more precisely, human intervention, because it was human intervention the SEC wanted to firewall" and asserted that "`[i]mmediately and automatically' means without human intervention and with no chance of human intervention" and "does not mean as fast as an exchange, or any exchange, can go." Id. at 2.Back to Context
61. Id. at 2. Another commenter asserted that IEX's POP/coil structure is "entirely consistent with the overall policy objectives of Regulation NMS." Franklin Templeton Letter at 2. One commenter argued that IEX's proposed POP/coil delay does not constitute an "intentional device" under Rule 600 of Regulation NMS because IEX's dissemination of quote information to the SIP would not be subject to the delay, and thus IEX's POP/coil would not increase the uncertainty of the NBBO relative to current latencies. See Upson Letter at 2. One commenter noted that "the flip side of faster access is slower access if you don't pay" and with co-location "[t]he problem is that you have to pay to get into their data centers in the first place, and if you don't it sure looks like you are intentionally delayed compared to those who can and do pay." See Leuchtkafer First Letter at 1. That commenter noted that "if the IEX critics are right, by their own reasoning the exchanges will have to dismantle their co-location facilities and stop offering tiered high-speed network facilities. They are selling faster access to their markets, and if you don't pay, aren't you slower than you could be, aren't you intentionally delayed?" Id. at 2.Back to Context
62. See, e.g., BATS First Letter at 4; BATS Second Letter at 2-3; Healthy Markets Letter at 4; Angel Letter at 2; Kim Letter; Mannheim Letter; Wilcox Letter.Back to Context
63. Angel Letter at 3.Back to Context
64. Tabb Letter at 1.Back to Context
65. Healthy Markets Letter at 3.Back to Context
66. See IEX First Response at 6-7; see also IEX Third Response at 1-3. IEX noted that the Regulation NMS Adopting Release does not define a maximum allowable latency in order for quotations to qualify as automated quotations, and stated that "[t]he POP does not enable any human intervention to determine the action taken with respect to a quote or the order itself" and that "the POP clearly does not involve a `coding of automated systems'. . . ." IEX First Response at 6-7. IEX suggested that the POP is consistent with the purpose of Regulation NMS because "the POP helps to promote access to quotations by limiting the chance that a party displaying a quote on an exchange will use a signal from an execution on IEX to cancel its quote on that other market within microseconds." See IEX Second Response at 4 (emphasis in original).Back to Context
67. IEX First Response at 7; see also IEX Second Response at 4.Back to Context
68. IEX First Response at 5.Back to Context
69. See id. at 6; see also IEX Third Response at 2. One commenter made the same observation, noting that "[t]he NBBO already includes quotes with varied degrees of time lag" and that the length of IEX's coiled cable "is far less than the distance between NY and Chicago, and is remarkably similar to the distance between Carteret and Mahwah (36 miles)." See Healthy Markets Letter at 4. See also IEX Second Response at 11 (noting that the distance between Nasdaq's Carteret facility and NYSE's Mahwah facility is 42.8 miles (compared to the IEX coil's approximately 38 mile equivalent)). Other commenters similarly understood that the POP/coil latency is comparable to or shorter than natural and geographic latencies in today's market. See Angel Letter at 2; BATS First Letter at 4; BATS Second Letter at 2-3; Kim Letter; Mannheim Letter; T. Rowe Price Letter at 2-3; Wilcox Letter. Two commenters specifically suggested that such a delay would be inconsequential or de minimis. See Angel Letter at 2; Abel/Noser Letter at 2.Back to Context
70. IEX Second Response at 4 and 7. IEX compared its POP to the coiling of cable that existing exchanges utilize in their respective data centers for purposes of co-location access. See IEX First Response at 3-6; IEX Third Response at 2. IEX further contended that "the POP should no more be considered prohibited than existing access arrangements could be considered as designed to intentionally delay access to quotes by anyone who declines to pay for the privilege of the fastest access." IEX First Response at 7. According to IEX, "the POP clearly is not a `programmed delay' any more than the coiled cables connecting to every other exchange's matching systems could be considered as such." IEX Second Response at 4. IEX claimed that its 350 microsecond latency on inbound orders is actually less than the latency differential between the non-co-located access and the highest level of co-location offered by the Nasdaq Stock Market. See id. at 5-6.Back to Context
71. See 17 CFR 242.600(b)(3) (defining "automated quotation").Back to Context
72. Regulation NMS Adopting Release, supra note 14, at 37519.Back to Context
73. See supra note 26 (citing to footnote 21 of the Regulation NMS adopting release where the Commission noted that "[t]he difference in speed between automated and manual markets often is the difference between a 1-second response and a 15-second response—a disparity that clearly can be important to many investors").Back to Context
74. The Commission notes that the smallest time increment suggested by commenters at the time Regulation NMS was adopted—250 milliseconds—is magnitudes slower than the latency introduced by IEX's proposed POP/coil delay. See Regulation NMS Adopting Release, supra note 14, at 37518.Back to Context
75. A number of factors affect the speed at which a market participant can receive market and quote data, submit orders, obtain an execution, and receive information on trades, including hardware, software, and physical distance. See, e.g., Securities Exchange Act Release No. 61358 (January 14, 2010), 75 FR 3594, 3610-11 (January 21, 2010) (Concept Release on Equity Market Structure). Recent technological advances have reduced the "latency" that these factors introduce into the order handling process, both in absolute and relative terms, and some market participants and liquidity providers have invested in low-latency systems that take into account the advances in technology. See id. at 3606.Back to Context
76. See, e.g., Securities Exchange Act Release No. 67639 (August 10, 2012), 77 FR 49034 (August 15, 2012) (SR-NASDAQ-2012-071) (order approving proposed rule change to provide for simultaneous routing).Back to Context
77. In particular, the POP/coil, because it delays inbound and outbound messages to and from IEX Users, raises a question as to whether IEX will, among other things, "immediately" execute IOC orders under Rule 600(b)(3)(ii), "immediately" transmit a response to an IOC order sender under Rule 600(b)(3)(iv), and "immediately" display information that updates IEX's displayed quotation under Rule 600(b)(3)(v). See 17 CFR 242.600(b)(3); see also Regulation NMS Adopting Release, supra note 14, at 37504.Back to Context
78. See supra note 69 (citing to the Healthy Markets Letter, which observed that the length of IEX's coiled cable "is far less than the distance between NY and Chicago, and is remarkably similar to the distance between Carteret and Mahwah (36 miles)"). See also IEX Second Response at 11 (noting that the distance between Nasdaq's Carteret facility and NYSE's Mahwah facility is 42.8 miles).Back to Context
79. See supra note 69 (citing to commenters who believe that IEX's POP/coil latency is comparable to or shorter than natural and geographic latencies in today's market). One market maker and liquidity provider on the IEX ATS notes that it "engages in precisely the same market making strategies on IEX as [it does] on automated trading systems run by other broker-dealers . . . as well as on registered stock exchanges" and that "IEX's `speed bump' has had no impact on [its] market making and liquidity provisioning on the platform." Virtu Letter at 1-2.Back to Context
80. An exchange that proposed to provide any member or user (including the exchange's inbound or outbound routing functionality, or the exchange's affiliates) with exclusive privileged faster access to its facilities over any other member or user would raise concerns under the Act, including under Section 6(b)(5) and 6(b)(8) of the Act, and would need to address those concerns in a Form 1 exchange registration application or a proposed rule change submitted pursuant to Section 19 of the Act, as applicable.Back to Context


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text: Carefully read through the handouts I have attached. The handouts have been scanned, but some I had to take pictures of so sorry if they're hard to read. I have also attached the instructions. Answer the questions in the instructions using the handout material. You are acting as a consultant. Make sure you reference SIOAR. There are a few examples in the handouts relating to it. Please let me know if you have any questions!! Thank you!!


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Graduate School
Repeating Courses
Students who meet the prerequisites and all other conditions for enrollment may repeat a course one time. A course may be repeated if the first grade is a B- or lower. The second grade will calculate into the grade point average. All grades earned will be retained on the student's permanent record (aka academic transcript), with repeats indicated. Courses that are dropped or from which a student has withdrawn are not counted as attempted repeats for the purpose of this policy. Credit and grade point calculations for repeated courses are determined by the following rules:
Credit Earned:
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Repeated Courses and Grade Point Average (GPA):
i. Courses that are dropped or from which a student has withdrawn are not counted as attempts for purposes of this policy.
ii. A course may be repeated once and only the last grade received will be used in determining the student's grade point average. As stated above, all course attempts with repeats indicated will remain on the permanent record (aka academic transcript), even if not used to determine the grade point average.
Petition for Modification or Waiver of Graduate School Academic and Administrative Policy
Instructions on how to use the online petition system can be found under Petitions for Modification/Waiver of Policy.


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Author: Jonathan Witt
Brangelina Fever Gets Its Own Darwinian Just-So Story
Darwinism is so flexible that it's able to explain almost any zoological phenomenon and its opposite.
Richard Dawkins's Weasel Program Is Bad in Ways You Never Dreamed
His reductive approach causes him to miss a delicious irony.
Guillermo Gonzalez, Nobel Laureates and Founders of Modern Science See Purpose as Best Explanation for Fine-Tuned Cosmic Habitat
In a weekend essay in the Des Moines Register, Iowa State Physics Professor John Hauptman explains that ISU astronomer Guillermo Gonzalez was denied tenure because Gonzalez argued that a purposive cause is the best explanation for certain features of our cosmic habitat. By this standard, Hauptman will also need to fire many of the most esteemed physicists and astronomers of our day, as well as the founders of modern science. Hauptman and his fellow thought police at Iowa State have their summer work cut out for them.
Intellectual Insecurity at Iowa State?
Following his May 16 piece, Lawrence Selden has more incisive commentary on the Guillermo Gonzalez denial of tenure scandal at Iowa State University: Is the faculty at Iowa State University intellectually insecure? The statement of two years ago signed by 120 members of the faculty perhaps suggests that, especially when compared with the actions of other schools and faculties. I wonder if they are afraid that others will think they are backward country bumpkins for allowing someone who is interested in exploring intelligent design on the faculty. Harvard University is not ashamed of Owen Gingerich, who had this to say about Gonzalez' book The Privileged Planet:
UV-Ray-Damage-Repairing Protein Evolution Proves Shy
Science Daily reports: Researchers from the J. Craig Venter Institute (JCVI) today announced the publication of several studies from the Sorcerer II Global Ocean Sampling Expedition (GOS) in PLoS Biology detailing the discovery of millions of new genes, thousands of new protein families and specifically the characterization of thousands of new protein kinases from ocean microbes using whole environment shotgun sequencing and new computational tools. This is extraordinary and exciting research, but what does any of this have to do with evolution news?


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