oversight

Futures Markets: Use of Automation to Detect Trade Abuses

Published by the Government Accountability Office on 1990-08-24.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

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United   States   General   Accounting   Office

Report to the Chairman and Ranking
Minority Member, Committee on
Agriculture, Nutrition, and Forestry,
lJ.S. Senate


FUTURES MARKETS
Use of Automation to
Detect Trade Abuses



                                                           Q
                                                  llllllllllllll
                                                    142270




 V--Not                to be released outside the
 General Accounting Offlce unless spedfically
 approved by the Office of Congressional
 Relations.
.-“”   -..._.   _.   -._“lll-_-”   .-^.   .-------..--   ---
                                                               ---   /
United States
General Accounting Office
Washington, D.C. 20548

Information Management and
Technology Division

B-234478

August 24,lQQO

The Honorable Patrick J. Leahy, Chairman
The Honorable Richard G. Lugar, Ranking
  Minority Member
Committee on Agriculture, Nutrition, and
  Forestry
United States Senate

In our September 1989 reports, we noted that weaknesses in controls
over futures trading’ at exchanges provide dishonest trading floor par-
ticipants with the opportunity to defraud customers by falsifying their
trade records, which exchanges use to detect abuses.2 While detecting
every abuse may never be possible, we pointed out that abuses could be
better detected with more accurate trade records. We concluded that to
obtain such records the exchanges- not the trading floor participants-
needed to independently and precisely record when (1) customer orders
are received on the exchange floors, (2) orders are received by trading
floor participants, (3) trades are executed, and (4) trades are reported
off the exchange floors. We further pointed out that automation can be
used to improve the accuracy of trade records needed to detect abuses,
but that exchanges and the Commodity Futures Trading Commission
needed to control the new risks associated with automation.

Your Commodity Futures Trading Commission reauthorization bill
(S 1729) would require the futures exchanges to maintain independent,
precise, and complete trade records. In this connection, your office
requested that we identify automation initiatives of the 14 U.S. futures
exchanges that could record accurate trade times. Additionally, your
office requested that we perform limited risk assessments of two auto-
mated trading systems that were being developed by the Chicago Board
of Trade and the Chicago Mercantile Exchange, and identify steps taken
by the Commodity Futures Trading Commission to assess automation
initiatives. As agreed with your office, we limited the scope of this
review to exchanges’ automation initiatives and did not assess other
means by which exchanges could maintain independent, precise, and

‘We are defining futures trading as the trading of futures contracts and options on futures contracts.
A futures contract is an agreement to buy or sell a commodity for future delivery at a price deter-
mined at initiation of the contract. An option on a futures contract gives the buyer the right, but not
the obligation, to perform on the terms of the contract within the life of the option.
“Futures Markets: Strengthening Trade Practice Oversight (GAO/GGD-89-120, Sept. 7, 1989); and
Futures Markets: Automation Can Enhance Detection of Trade Abuses But Introduces New Risks
(GAOFilTFC 89_ -



Page 1
                   R234478                                                                ,




                                                                                     *




                   complete trade records. In conducting this work, we reviewed documen-
                   tation and interviewed officials of the Commission and the 14 U.S.
                   futures exchanges. Details of our objectives, scope, and methodology are
                   included in appendix I.


                   Five U.S. futures exchanges are designing, developing, or implementing
Results in Brief   10 automated systems that could provide more accurate trade records to
                   detect abuses. As currently planned, however, the use of some systems
                   will be optional, and others may be limited to certain trading locations.
                   Consequently, it is uncertain at this time whether and to what extent
                   these systems will be implemented.

                   In addition, our limited risk assessments of the after-hours trading sys-
                   tems planned by the Chicago Board of Trade and the Chicago Mercantile
                   Exchange identified internal control areas that the exchanges needed to
                   strengthen before each system’s implementation. The risks associated
                   with these areas include those that could affect the security of the sys-
                   tems. The Commission and the exchanges agree with the need for strong
                   internal controls of the systems. The exchanges have plans to incorpo-
                   rate needed improvements as part of their continuing system develop-
                   ment efforts.

                   The Commodity Futures Trading Commission has taken steps to
                   increase its oversight of automation initiatives, and to obtain the addi-
                   tional technical expertise needed to assess these initiatives. Because
                   most of the Commission’s efforts are in the formative stages, it is too
                   early to assess their effectiveness.


                   Currently, most futures contracts and options on futures contracts at
Background         U.S. exchanges are traded at centralized trading floor locations, called
                   trading pits. Trading floor participants in the pits are called floor bro-
                   kers and floor traders. Floor brokers trade for others and may also trade
                   for themselves, while floor traders trade strictly for themselves.

                   Although variations exist among exchanges, a customer order, on the
                   Chicago Board of Trade and the Chicago Mercantile Exchange, typically
                   is transmitted to a booth on the trading floor through the telephone or




                   Page 2
                         B-234478




                         computer of a member firm. These firms are referred to as futures com-
                         mission merchants.:3 A member firm’s clerk in the booth first prepares an
                         order ticket and time-stamps it. The clerk then sends the customer’s
                         order to a floor broker who attempts to execute it by offering or bidding
                         the order to other trading pit participants. This process is generally
                         referred to as open-outcry trading. If accepted, the broker reports the
                         trade results back to a member firm’s employee at the booth, where the
                         order ticket is time-stamped again, and the trade results are transmitted
                         back to the futures commission merchant. Floor brokers and traders also
                         record their executed trades on trading cards, and trade results are
                         reported back to the exchanges.

                         To deter trade practice abuses, the Commodity Futures Trading Com-
                         mission requires that futures exchanges maintain surveillance and other
                         programs to detect trading violations. As part of their surveillance, the
                         exchanges and the Commission generally use trade records submitted by
                         trading floor participants. However, the accuracy of the trade timing
                         data that are handwritten or manually stamped on order tickets or
                         trading cards is questionable because floor participants can intention-
                         ally or accidentally provide erroneous information. Additionally, dis-
                         honest floor participants could manipulate reported trade times and
                         prices because trade records are not always turned in immediately fol-
                         lowing each trade. For example, the Chicago Board of Trade and the
                         Chicago Mercantile Exchange allow trading cards to be maintained by
                         trading floor participants for up to 45 minutes. Because a trading par-
                         ticipant can execute a number of trades at different prices in a minute,
                         information that is only seconds old can be used to alter trading records
                         and potentially cheat a customer without detection.


                         The Chicago Board of Trade, the Chicago Mercantile Exchange, and the
Automation Holds         Commodity Exchange, Incorporated, are pursuing six automation initia-
Potential to Precisely   tives for their open-outcry trading processes that could provide
Record the Timing of     improved trade records. The two Chicago exchanges have individually
                         developed exchange-managed, order-routing systems that are designed
Trades                   to electronically transmit customer orders from futures commission
                         merchants to exchange floors. In addition, the Chicago exchanges are
                         separately developing workstations to provide floor brokers and their
                         assistants with an automated means to receive and manage customer

                         :‘The futures commission merchants are individuals, corporations, associations, partnerships, and
                         trusts that solicit or accept orders to buy or sell futures contracts, and accept payment from or
                         extend credit to those whose orders are accepted.



                         Page 3
orders, and record executed trades near the trading pits. The two
exchanges are also cooperating in a fifth initiative to develop hand-held
trading terminals. The terminals are intended to electronically receive
orders in the trading pits and enable floor brokers and traders to record
all transactions that the system will automatically time-stamp. Initially,
the exchanges plan to issue terminals to floor traders. Chicago Board of
Trade officials said that they were actively pursuing efforts to have
hand-held terminals for floor brokers within the next 2 years. Chicago
Mercantile Exchange officials did not envision such terminals within
this time frame.

The Commodity Exchange, Incorporated, is also developing hand-held
trading terminals. Unlike the Chicago exchanges’ initiative, the Com-
modity Exchange is initially developing hand-held terminals that will
not directly communicate with a supporting computer. Users will preset
the terminal’s starting time at the beginning of the trading day, and the
terminal will then be used throughout the day to record trades, which
will be automatically time-stamped and stored on an internal-memory
device for later loading into a supporting computer. Phase two of the
initiative includes the development of hand-held terminals that will
communicate directly with a supporting computer, which will maintain
accurate times for the purpose of time-stamping trades.

None of the six initiatives individually will provide accurate trade
records to document when (1) orders are received on exchange trading
floors, (2) orders are received by trading floor participants, (3) trades
are executed, and (4) trade results are reported off the exchange floors.
However, if the Chicago exchanges’ initiatives are successfully imple-
mented, the resulting systems could collectively provide accurate
records in three of the four areas and potentially for the fourth as well.
The precise time of trade execution may not be captured because the
broker workstations and hand-held terminals are intended to record the
time when trades are recorded, not when they are executed. However, if
hand-held terminals are used by all floor brokers and traders in the
trading pits, the times recorded should closely approximate the execu-
tion times. Table 1 provides system descriptions, the development status
of the initiatives, and plans for each system to automatically provide
accurately timed trade records.




Page 4
Table 1: Six Planned Automation Initiatives That Could Provide Accurately Timed Records for Open-outcrv Trading
                                                                                 Accurate trade times for when:
                                                                 customer                          executed       executed
Exchange                                                         orders are      orders are        orders are     orders are
name(s) and                                                      received on     received by       recorded by    reported off
NJ;:;   name                                      Status of      exchange        floor broker8 or tradin floor    exchange
                 Syrtem description               development    floors          their asststants partic apants   floors
                An order-routing system is             Currently         X                                              X
                being developed to transmit            testing system
                orders from futures                    functions.
                commission merchants to and            Implementation
                from the trading floor and the         planned to
                planned after-hours trading            start within 18
                system.                                months,

Chicago Board   Broker workstations are being          In an early                                      X
of Trade        developed to extend                    development
                automated order-routing to             stage.
                and from the floor brokers or          Implementation
                their assistants at the edge of        planned to
                the trading pits. Orders can be        start within 2
                accepted and maintained until          years.
                execution, and trade results
                can be recorded.
Chicago Board   The two exchan es are                  Software                       .X                X
of Trade and    developing han 8 -held trading         testing
Chicago         terminals to electronically            expected in
Mercantile      record trade results in the            late 1990.
Exchange        trading pits.                          Implementation
   Automated                                           planned to
   Data Input                                          start within 18
   Terminal                                            months.
   (AUDIT)
Chicago         An order-routing system is             System testing    X                                             X
Mercantile      being developed to transmit            is complete.
Exchange        orders from futures                    Currently
  Trade Order   commission merchants to and            marketing the
  Processing    from the trading floor.                system to
  System                                               members.
  (TOPS)
Chicago         Broker workstations are being          General                         X                X
Mercantile      developed to extend                    system design
                automated order-routing to             is complete.
Ex:Kge          and from the floor brokers or          Currently
  ;;zesal       their assistants at the trading        testing models.
                pits. Orders can be accepted           Implementation
                and maintained until                   planned to
  ~t!2?)        execution, and trade results           start within 18
                can be recorded.                       months.

Commodity       A hand-held trading terminal is        In system                                        X
Exchange,       beingdeveloped    to record            testing. No
Incorporated    trade executions of floor              date for
                brokers and floor traders.             implementatron.




                                                  Page 5
                                                                                                                    <’
                      0234478




                      Although these initiatives could provide the exchanges with accurate
                      trade timing data to detect abuses, the extent to which the systems will
                      be used to record accurate times depends on how exchanges finally
                      decide to implement the systems. For example, Chicago Mercantile
                      Exchange officials said that the mandatory use of their systems is a
                      policy issue that is under consideration. Also, Chicago Board of Trade
                      officials are studying whether the automation initiatives can be effec-
                      tively implemented in the pit where futures on U.S. Treasury bonds are
                      traded because such initiatives could impair the existing process.


                      Automated trading systems are being developed by the Chicago Board
Four Automated        of Trade, the Chicago Mercantile Exchange, and the New York Mercan-
Trading Systems Are   tile Exchange for after-hours trading when their open-outcry markets
Being Developed by    close, and by the Amex Commodities Corporation in New York, for
                      normal daytime trading hours4 The records that the systems are
Exchanges             intended to produce can help detect trading abuses. For example,
                      exchange officials said that the systems can accurately record when
                      users enter orders into the systems and can automatically time all
                      trading transactions to within a second or fraction of a second. Although
                      the systems are intended to provide accurately timed records, effec-
                      tively detecting trade practice abuses will depend on how exchanges use
                      such records. At the time of our review, not all the exchanges had final-
                      ized their plans to use the records these systems can provide.” Informa-
                      tion on the four automated trading system initiatives is provided in
                      appendix II.


                      Although five exchanges are developing initiatives to automate trade
Other Exchanges       records, the successful implementation of these initiatives could benefit
Could Eknefit From    others. Both Chicago exchanges have announced that other exchanges
Ongoing Automation    could share in the hand-held trading terminal technology they are devel-
                      oping. In addition, other exchanges are reviewing the feasibility of using
Initiatives           one of the after-hours trading systems when they are implemented.

                      Some exchanges have affiliations or agreements with exchanges pur-
                      suing initiatives, and others are waiting to review the results of the cur-
                      rent initiatives before they decide to use automation. The MidAmerica
                      Exchange in Chicago, and the Chicago Rice and Cotton Exchange are

                      4Amex Commodities Corporation is a subsidiary of the American Stock Exchange, Incorporated.
                      “Although the exchanges were pursuing individual initiatives during our review, the Chicago
                      exchanges announced their intentions to use the same after-hours trading system.



                      Page 6
                       B-234473




                       affiliated with the Chicago Board of Trade, and a representative of all
                       three exchanges said that the Board’s automation initiatives would also
                       be applied to the other two exchanges. The Coffee, Sugar, and Cocoa
                       Exchange in New York, the Commodity Exchange, Incorporated, in New
                       York, the New York Cotton Exchange, the New York Futures Exchange,
                       and the New York Mercantile Exchange have agreed in principal to com-
                       bine efforts to finance research and development of hand-held trading
                       terminal technology. To date, these efforts have included reviewing and
                       monitoring the Chicago exchanges’ and the Commodity Exchange’s ini-
                       tiatives for hand-held terminals. Additionally, officials of the Kansas
                       City Board of Trade and the Minneapolis Grain Exchange said that if the
                       Chicago hand-held initiative is successful and the resulting system is
                       affordable, the exchanges will consider the use of this automation on
                       their trading floors.

                       The two remaining futures exchanges are not considering the use of
                       automation initiatives. A representative of the Philadelphia Board of
                       Trade said the Board has no automation plans for futures trading given
                       the low volume traded on that exchange. At the time of our review, the
                       Pacific Futures Exchange was not trading futures.


                       Our limited risk assessments of the automated trading systems and facil-
Exchanges Agree With   ities planned for use by the Chicago Board of Trade and the Chicago
the Need to            Mercantile Exchange identified a number of areas where the exchanges
Strengthen Security    needed to ensure that internal controls were strengthened before they
                       implement their after-hours trading systems. The risks include weak-
and Other Internal     nesses that could affect the security of the systems. In addition, the
Controls               Commission also performed a limited risk assessment of the planned
                       computer facility for the Chicago Mercantile Exchange’s system and
                       identified similar weaknesses. We have not disclosed the specific weak-
                       nesses in this report, because of the sensitive and proprietary nature of
                       the systems, and because the systems were not fully developed.

                       Officials representing the exchanges said they would be taking steps to
                       address identified weaknesses as part of their continuing systems’
                       development efforts, which were on-going during our review. For
                       example, the Chicago Mercantile Exchange hired an independent outside
                       auditor to evaluate the risks associated with the operations of its
                       system.




                       Page 7
                         B-234478




                                                                                          .




                         The Commodity Futures Trading Commission has recently initiated sev-
The Commission           era1 actions that respond to the recommendation in our September 1989
Moves to Strengthen      report that it acquire the technical expertise needed to assess
Oversight of             exchanges’ automation initiatives.” These actions include (1) conducting
                         technical assessments of planned automated trading systems, (2) evalu-
Automation Initiatives   ating operational systems as part of its rule enforcement reviews,
                         (3) establishing a federal interagency task force to help the Commission
                         determine its role and approach in assessing systems, (4) initiating plans
                         to develop a formal policy for automated system assessments,
                         (6) increasing program staff’s oversight of automation, and (6) seeking
                         additional technical resources.

                         We believe these recent actions by the Commission are good steps
                         toward strengthening its oversight of automated systems.


                         Futures exchanges are developing systems intended to automate trade
Conclusions and          records, which can be used to better detect trading abuses. In this con-
Recommendations          nection, we endorse the requirement in Senate legislation (S. 1729),
                         pending in the Congress, that futures exchanges maintain independent,
                         precise, and complete times for all trades. The exchanges could meet this
                         requirement by using automation. However, it is unclear at this time
                         how extensively exchanges will implement these systems.

                         The Chicago Board of Trade and the Chicago Mercantile Exchange are
                         taking steps to correct security and other internal control weaknesses
                         identified in our limited risk assessments of their after-hours trading
                         systems. Because these steps have not been completed, it is too early to
                         assess their effectiveness.

                         Because automation can improve trade records, we recommend that the
                         Chairman of the Commodity Futures Trading Commission ensure that
                         exchanges maximize to the extent practicable the potential of automated
                         systems to accurately record trade times. We also, recommend that the
                         Chairman ensure that the Chicago Board of Trade and the Chicago Mer-
                         cantile Exchange strengthen the security and other internal controls we
                         identified in our limited risk assessments before their systems become
                         operational.




                         “GAO/IMTEC-89-68, Sept. 7,1989.



                         Page 8
z
    B-224478




    We discussed the contents of this report with senior officials of the Com-
    modity Futures Trading Commission and the 14 U.S. futures exchanges,
    who generally agreed with the accuracy of the information presented.
    We have incorporated their comments in the report as appropriate. We
    also discussed the specific control weaknesses identified in our limited
    risk assessments with officials of the Commission and the respective
    exchanges.

    As arranged with your office, unless you publicly announce the contents
    of this report earlier, we plan no further distribution until 30 days from
    the date of this letter. At that time we will distribute copies of this
    report to the Commodity Futures Trading Commission, the 14 US.
    futures exchanges, other interested members of Congress, other execu-
    tive branch agencies, and the public. We will also make copies available
    to others upon request.

    This work was performed under the direction of Howard G. Rhile,
    Director, General Government Information Systems, who can be reached
    at (202) 275-3465. Other major contributors are listed in appendix III.




    Ralph V.ICarlone
    Assistant Comptroller General




    Page 9
Contents


Letter                                                                              1

Appendix I                                                                         12
Objectives, Scope,and
Methodology
Appendix II                                                                        14
Four Exchanges’
Planned Automated
Trading Systems
Appendix III                                                                       16
Major Contributors to
This Report
Tables                  Table 1: Six Planned Automation Initiatives That Could      5
                            Provide Accurately Timed Records for Open-outcry
                            Trading
                        Table II. 1: Four Exchanges’ Plans for Fully Automated     16
                            Trading Systems




                        Abbreviations

                        GAO       General Accounting Office
                        GGD       General Government Division
                        IMTEC     Information Management and Technology Division


                        Page 10
Page 11
                                                                                /
Appendix I                                                                           I
Objectives, Scope,and Methodology


               Our objectives were to (1) identify and provide information on the 14
               U.S. futures exchanges’ automated initiatives that could provide accu-
               rately timed trade records, (2) perform limited risk assessments of the
               after-hours trading systems being developed by the Chicago Board of
               Trade and the Chicago Mercantile Exchange, and (3) identify the steps
               taken by the Commodity Futures Trading Commission to assess
               exchanges’ automation initiatives.

               We limited the scope of this review to exchanges’ automation initiatives
               and did not assess other means by which exchanges could maintain
               independent, precise, and complete trade records. In conducting our
               work, we discussed automation plans with representatives from each of
               the 14 exchanges. Specifically, we reviewed documentation of systems
               being planned by the Amex Commodities Corporation in New York, the
               Chicago Mercantile Exchange, the Chicago Board of Trade, the Com-
               modity Exchange, Incorporated, in New York, and the New York Mer-
               cantile Exchange. During these visits, we discussed how the exchanges
               plan to develop and use automation. In addition, we obtained and
               reviewed information on their plans to (1) obtain accurately timed
               trading records, (2) detect trading abuses with accurately timed trade
               records, and (3) make the systems’ use mandatory or optional for
               trading participants. We also requested information on system descrip-
               tions and implementation schedules.

               We requested through telephone interviews information from officials
               of the nine other futures exchanges: the Chicago Rice and Cotton
               Exchange, the Coffee, Sugar, and Cocoa Exchange in New York, the
               Kansas City Board of Trade, the MidAmerica Commodity Exchange in
               Chicago, the Minneapolis Grain Exchange, the New York Cotton
               Exchange, the New York Futures Exchange, the Pacific Futures
               Exchange in Los Angeles and San Francisco, and the Philadelphia Board
               of Trade. We discussed their future plans for automation, including their
               interests in other exchanges’ automation initiatives.

               To perform our limited risk assessment of the after-hours trading sys-
               tems under development by the Chicago Mercantile Exchange and the
               Chicago Board of Trade, we reviewed available systems’ documentation,
               interviewed officials responsible for the facilities about planned internal
               controls including system security provisions, and performed an assess-
               ment of the facilities. We discussed the results of each assessment with
               officials of the Commodity Futures Trading Commission and the respec-
               tive exchange.



               Page 12
.   Appendix I
    Objectives, Scope, and Methodology




    We also interviewed the Chairman of the Commodity Futures Trading
    Commission and senior officials within the Commission’s Division of
    Trading and Markets, Office of Information Resources Management, and
    Office of the Inspector General, and obtained available documentation in
    our review of the Commission’s efforts to acquire the technical expertise
    needed to oversee exchanges’ automation initiatives.

    Our work was performed from November 1989 through July 1990, in
    accordance with generally accepted government auditing standards.




    Page 13
Appendix II

Four Exchanges’ Planned Automated
Tradin$ systems

              Our review of automated trading systems being developed by four US.
              futures exchanges showed that three exchanges plan to use their sys-
              tems for after-hours trading when their open-outcry markets close,
              while the fourth exchange plans to use its system during normal day-
              time trading hours. The systems are similar to the six foreign systems
              we reported on in April 1990, in that they are used to match and execute
              buy and sell orders received from exchange members and report the
              results of such trades.’ As was the case with the foreign systems, we
              found that some differences exist in how systems receive customer
              orders and match trades.

              The Chicago Mercantile Exchange and the New York Mercantile
              Exchange are developing systems that automatically execute trades sub-
              mitted on system terminals by members when buy and sell prices coin-
              cide. These systems are designed to sort unexecuted buy and sell orders
              by price and time of receipt so that when the market moves to an avail-
              able order price, the orders at this price are executed in the same
              sequence received by these systems. The systems will then automati-
              cally transmit trade results back to the members. The Amex Commodi-
              ties Corporation and the Chicago Board of Trade plan similar processes,
              but each has some differences.

              The Amex Commodities Corporation plans to use clerks at exchange
              locations to enter trade data received from exchange members rather
              than having the members directly enter their own data. This plan, how-
              ever, is on hold because the firm originally selected to provide and
              manage the clerks has decided not to assume this role.

              The system planned by the Chicago Board of Trade is not based on the
              automatic matching of orders at a common price, but instead is being
              developed to replicate the Board’s open-outcry trading process. Buy and
              sell orders at the best prices are available for other members to execute
              against, and members can choose whom they execute against once the
              first order available at the best price is filled.

              Table II. 1 provides additional information obtained from the exchanges
              on the status of the four planned automated trading systems.




              1Futures Market: Information on Sii Foreign Automated Trading Systems (GAO/IMTEC-90-43FS,
              Apr. 27,lQQO)



              Page 14
          1,

     /
-.

                                       Appendix II
                                       Four Exchauges’      Planned Automated
                                       -lhldhg systems




Table 11.1:Four Exchanges’ Plans for
Fully Automated Trading Systems        Exchange name and system name            Status of development
                                       Chicago Board of Trade                   Plannin to start software testing and user training,
                                         Aurora                                 but the % oard is also negotiating a unified system
                                                                                with the Chicago Mercantile Exchange. The unified
                                                                                system is intended to include a special role for
                                                                                $.rmre;and utilize the network and technology of


                                       ChiciE;xMercantile      Exchange         Testing software and negotiating a unified system
                                                                                with the Chicago Board of Trade. According to the
                                                                                latest estimate, operation will begin in November
                                                                                1990.

                                       New York Mercantile Exchange             Completed functional specifications. Requested
                                         Computer Assisted Trading System       proposals from vendors to develop the system.

                                       Amex Commodities Corporation             Completed development. Quality assurance testing
                                         Amex Commodities Corporation           and real-life testing are planned after selection of a
                                         Electronic System (ACCESS)             firm to enter trade data received from exchange
                                                                                members.




                                       Page 15
Appendix III

Major Contributors to This Report


                       Richard J. Hillman, Project Director
Information
--                     William D. Hadesty, Technical Assistant Director
Management and         Leonard Baptiste, Jr., Project Manager
                       Brenda E. Anderson, Senior Evaluator
Technology Division,   Rajiv Gujral, Technical Specialist
Washington, DC.

                       Alexandra Y. Martin, Staff Evaluator
Chicago Regional       Delano B. Pulido, Staff Evaluator
Office

                       Jeffrey Shapiro, Staff Evaluator
New York Regional
Office




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