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000-M48 - Lotus Web Content Management Technical Sales Mastery Test v2 - BrainDump Information

Vendor Name : IBM
Exam Code : 000-M48
Exam Name : Lotus Web Content Management Technical Sales Mastery Test v2
Questions and Answers : 30 Q & A
Updated On : January 16, 2019
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000-M48 exam Dumps Source : Lotus Web Content Management Technical Sales Mastery Test v2

Test Code : 000-M48
Test Name : Lotus Web Content Management Technical Sales Mastery Test v2
Vendor Name : IBM
Q&A : 30 Real Questions

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here's why application developers are worried about IBM's $34 billion acquisition of purple Hat | killexams.com Real Questions and Pass4sure dumps

IBM just announced a gigantic deal to acquire red Hat for a whopping $34 billion. or not it's respectable news for IBM in the cloud market, analysts say, however some application builders are panicking.

Valued at $a hundred ninety a share, red Hat will be the third-largest US tech acquisition ever, and IBM's largest deal in its 107-yr background.

or not it's also a big wager on open source, by which builders worldwide make a contribution their time and expertise to constructing free utility projects gigantic and small for any one, anyplace, to use as they'd like. purple Hat turned into one of the first corporations to show open source into a possible enterprise model, and it remains a luminary within the house.

the rise of open source seems to be a reoccurring theme in tech this 12 months. simply closing week, Microsoft formally acquired GitHub, a platform for open-supply coding initiatives, for $7.5 billion. previous this month, Cloudera and Hortonworks merged in a $5.2 billion deal. And previous this yr, Salesforce got MuleSoft for $6.5 billion.

still, the deal has raised some alarm bells in Silicon Valley and beyond, as some agonize that IBM is rarely the right lengthy-time period domestic for pink Hat — and that the realm of open supply will suffer for it.

What does pink Hat do?

red Hat makes open-source software for groups. it be some of the greatest distributors of Linux, an open-supply operating device often used to energy corporate facts centers. Linux is an working device, similar to home windows and MacOS, that has been around for the reason that the '90s, but pink Hat peculiarly develops a custom edition of Linux for businesses.

or not it's ideal commonplace for pink Hat business Linux, a really good edition of the working gadget. whereas downloading RHEL is free, pink Hat expenses for application enhancements and the technical assist that corporations want, equivalent to upkeep, help and setting up.

soon, other startups all started following red Hat's lead during this company strategy — even nowadays, scorching startups like Docker and Mesosphere have followed in purple Hat's lead in discovering how you can use free utility to generate earnings.

What does IBM plan to do with red Hat?

IBM plans to use purple Hat's software to bridge these Linux-powered company records facilities with the foremost cloud computing platforms in a mannequin known as "hybrid cloud." purchasers working crimson Hat utility on their servers would get a simple path to circulation some or all of their applications to the cloud, at their personal tempo, IBM says.

apart from its personal IBM Cloud, IBM additionally plans to preserve and nurture crimson Hat's partnerships with different primary cloud suppliers like Amazon internet capabilities, Microsoft Azure, Google Cloud, and Alibaba. To that end, IBM plans to run pink Hat as an impartial subsidiary, in order to retain its neutrality among cloud systems.

in addition, IBM has talked about it may not cease purple Hat from contributing to open-source projects or from managing the regularly occurring initiatives it already maintains, just like the CentOS operating device or the Ansible IT automation device.

Analysts expect this stream to have vast-accomplishing ramifications for the cloud landscape, and it might provide IBM an aspect to keep up with key players in the cloud computing market, comparable to Amazon, Microsoft and Google. In other phrases, this acquisition keeps IBM valuable, at the same time as its personal cloud lags behind Amazon's and Microsoft's.

nevertheless, now not every person is convinced that this deal will be a superb issue.

Why are individuals mad about it?

despite IBM's assurances that crimson Hat will preserve its independence, and hold contributing to open source, many apprehensive Linux builders (and as a minimum one person claiming to be a crimson Hat employee) see this as yet an additional instance of a tech colossal gobbling up a beloved open-supply utility company.

"i am absolutely greatly surprised via this information," mentioned one Reddit consumer who claims to work for purple Hat. "No indication that purple Hat became going to be obtained. earnings had been good. Open source neighborhood became extraordinary. no longer to point out, IBM is essentially the anti-crimson Hat when it involves their values."

greater without delay, there is a feeling among lovers of crimson Hat's open-source application that the company tradition on the a good deal-bigger IBM can have some variety of bad influence on its items.

those enthusiasts be anxious that it be best a depend of time earlier than IBM either mandates sweeping changes at purple Hat or disassembles and absorbs it wholesale. These concerns echo the furor after Microsoft announced it turned into paying for GitHub, the open-supply group hub, for $7.5 billion. That deal closed last week.

"IBM has an extended tune checklist of buying wonderful companies and wreaking havoc on their tradition," one Reddit person posted. "think of it like corporate colonialism. from time to time it outcomes in an exodus of ability which severely influences future product updates and assist."

What's greater, the tech business has considered IBM as a corporation that has fallen in the back of the times as one of the oldest tech corporations, and in recent years, IBM has struggled to benefit footing in the cloud wars with Amazon and Microsoft. First headquartered in 1911, IBM has misplaced most of its recognition as an innovator.

"IBM's popularity with open source is first-class in reality; it's the leisure of their recognition i am worried about," a different Reddit person posted.

reasons to be optimistic

certainly, IBM and open source go means returned, which consultants say could supply purple Hat enthusiasts reason to be optimistic.

"there may be loads of individuals saying, here is going to be a problem for red Hat, and open supply will be bluewashed for IBM," Chris Gardner, a senior analyst at Forrester, told enterprise Insider. "or not it's all this stuff that to me is in fact unhealthy analysis. IBM has had loads of push into open supply in the closing decade or more."

IBM has certainly in the past supported open-supply projects as an early supporter of Linux, and like crimson Hat, it be one of the most properly 10 contributors to Linux. It has invested billions of dollars in Linux and is a member of The Linux foundation. It even created a expertise core notably for Linux.

The Linux foundation, which oversees the building of the working device, has stepped up to compliment the flow as a reflection of the importance of open source.

"IBM's announcement that it's buying crimson Hat gifts a massive chance for both corporations and highlights the magnitude of open supply within the tech sector," Jim Zemlin, the director of The Linux basis, wrote in a press release on the acquisition. "IBM has been a big open supply advocate for over two decades: promotion and defending Linux and open supply at important facets in its heritage."

around the time that Steve Ballmer, then the CEO of Microsoft, all but declared conflict on the theory of open source, IBM boldly introduced its support for Linux, embracing it wholeheartedly. more lately, Microsoft has made a a hundred and eighty-diploma turn on its attitude toward open supply, but IBM has an extended historical past of help.

bill Karpovich, a former executive for IBM Cloud who's now the government vice president of the open-source application firm Sonatype, told enterprise Insider that IBM's pledging aid for Linux became a "main flow in opposition t legitimizing this stream."

IBM, he noted, had "always had a business mannequin that supports open supply. He brought: "they may be placing their money where their mouth is. With this acquisition, they actually are placing huge bucks on the open-source model."

nevertheless, Gardner has the same opinion that developer considerations over the deal could have some benefit. both corporations do have very distinctive cultures: IBM is a century-historical tech large with a bureaucratic way of life and the largest of big shoppers, whereas the fairly more youthful red Hat, situated in 1993, serves a frequently smaller clientele and is more geared toward taking risks.

"there may be abilities for problems right here," Gardner noted. "now not dramatic existence-amending problems, but there may be a significant difference in lifestyle and how they handle enterprise purchasers."

To make this acquisition work, he says, IBM should still keep red Hat with best a lightweight contact.

"It needs to permit crimson Hat to do its element," Gardner mentioned. "provided that IBM has that gentle contact, everything is super. They are attempting to override the subculture a bit bit, and that's the reason not going to work."


In IBM's $34B purple Hat deal, Boston tech sector sees validation | killexams.com Real Questions and Pass4sure dumps

No outcome found, are trying new key phrase!Dries Buytaert, the founder and chief know-how officer of Acquia Inc., stated he saw the deal pretty much as good news for his company, a late-stage startup that commercializes an open-supply content ... like Ama...

right here's What Analysts Are saying About IBM's Blockbuster Plans to buy crimson Hat for $34 Billion | killexams.com Real Questions and Pass4sure dumps

IBM’s plan to purchase commercial enterprise utility enterprise pink Hat for $34 billion is the largest acquisition in massive Blue’s background.

The deal, introduced Sunday, additionally marks a tremendous change from the enterprise’s recent excessive-profile acquisitions below CEO Ginni Rometty. In 2016, IBM purchased healthcare company Truven health for $2.6 billion after paying a said $2 billion for The climate company.

The Truven fitness and weather business acquisitions centered mostly on IBM’s Watson information crunching know-how, which Rometty has previously pitched as critical to her business’s long-time turnaround effort. IBM hoped the sizeable troves of healthcare and climate statistics would assist it educate technology to foretell rain storms that might keep truck drivers off the road and support docs more advantageous diagnose illnesses.

but those records-situated acquisitions have yet to drastically lift IBM’s earnings, which fell wanting analyst forecasts within the most recent quarter. furthermore, profits in IBM’s Cognitive solutions unit, which consist of Watson linked services, dropped 6% year-over-year to $4.1 billion within the third quarter.

through purchasing red Hat, IBM gains a neatly-dependent enterprise software business that has profits nowadays instead of a mere opportunity sooner or later. red Hat may additionally now not be general for leading edge synthetic intelligence technologies, nevertheless it does have a acceptance as some of the few groups with a successful business constructed on open source, or free, software—which, in red Hat’s case, is the Linux working equipment used in company servers international.

David Holt, an analyst with market analysis firm CFRA, talked about that the deal makes experience for each IBM and purple Hat considering that they were already large companions. up to now, IBM has teamed with purple Hat on consulting and utility for working the Linux operating equipment on IBM’s mainframe computers.

Holt additionally outlined that IBM can use its huge income team and current relationships with large businesses to sell purple Hat’s hybrid cloud know-how to greater consumers. crimson Hat’s business of marketing hybrid cloud features, which corporations use to manage their apps that run in each inside information centers and cloud statistics facilities, is smaller than its core company situated round paid assist for Linux.

Toni Sacconaghi, an analyst with Bernstein research, stated in a analysis observe that the acquisition makes sense for IBM as a result of red Hat already has a “mighty foothold within the cloud.” pink Hat’s Linux OS is used in most cloud computing statistics facilities via customers like Amazon web capabilities and Microsoft’s Azure cloud service.

Sacconaghi observed that the acquisition is a “huge win” for red Hat as a result of buyers have punished its shares in contemporary months because of slowing increase in its core Linux business. IBM is providing to pay a 63% top class on crimson Hat’s shares based on their closing fee on Friday, which is big by tech necessities.

however some buyers are skeptical that the acquisition, a mix of money and debt, will occur at all. red Hat’s shares rose best forty five% to $169.63 on Monday, neatly under the $190 present expense, a telltale sign of Wall street’s doubts.

Sacconaghi introduced that IBM’s acquisition of purple Hat may well be IBM’s management admitting defeat in its previous facts-concentrated approach—or, at the least, that it become not lifting the company quickly enough. He also mentioned that Rometty will turn sixty two by the point the deal closes, which is older than the retirement age of some old IBM CEOs like Sam Palmisano and Lou Gerstner.

Rometty’s age and the proven fact that the deal seems to be a “foremost pivot” from her current method could indicate that she may also depart IBM after two or three years, Sacconaghi observed. On CNBC on Sunday, Rometty tried to quell rumors about stepping down, asserting “I’m nevertheless young and i’m not going anywhere.”

Dennis Gaughan, Gartner’s lead analyst on functions, advised Fortune in an e mail that it’s uncertain no matter if the acquisition is a good idea. “It’s challenging to assert who the winners and losers should be at this element,” he noted.

Gaughan defined that IBM is pitching the deal as important to its “hybrid clouds” method. The challenge, besides the fact that children, is that every one of IBM’s “cloud opponents” like Microsoft and Google, are all pushing the same method, which skill that IBM will nevertheless face tough competition.

Daniel Ives, an analyst with Wedbush, referred to in a research notice that the deal represents “a huge shot throughout the bow” via IBM towards properly cloud avid gamers comparable to Amazon (AWS), Microsoft (Azure), and Google (Google Cloud). “there's a further participant on the town that plans to aggressively compete during this big secular hybrid cloud shift,” Ives said.

despite the fact Ives believes that Amazon and Microsoft should be cloud computing leaders for the arriving years, the deal might help IBM profit market share in an industry he expects to be massive.

Get facts Sheet, Fortune’s technology publication.

a large challenge for IBM might be creating compelling hybrid cloud functions that work with competitors like AWS and Azure while additionally convincing businesses to make use of IBM’s public cloud provider, Gartner’s Gaughan noted.

moreover, IBM challenges other business tech giants like Hewlett Packard commercial enterprise and Cisco in pitching their personal technologies and capabilities for valued clientele to control corporate infrastructure, whether it be in inner records facilities or with cloud suppliers.

As for no matter if the IBM’s pink Hat acquisition will work greater than its previous facts-heavy deals like Truven fitness, Gaughan stated “probably sure, and given the expense tag they are paying they completely want it to!”




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000-M48 exam Dumps Source : Lotus Web Content Management Technical Sales Mastery Test v2

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Symphony Now Available on OpenFin Through Open Source Contribution to Symphony Software Foundation | killexams.com real questions and Pass4sure dumps

By Business Wire

Article Rating:

February 8, 2018 09:04 AM EST  

OpenFin, the desktop operating system built specifically for the needs of capital markets, announced today that it has publicly contributed code to the Symphony Software Foundation that allows, for the first time, any OpenFin customer to deploy Symphony Chat on the OpenFin operating system. The integration, currently in beta testing, enables seamless deployment and interoperability of Symphony alongside the expanding ecosystem of applications already running on OpenFin.

The Symphony Software Foundation (the Foundation), is a nonprofit organization fostering innovation in financial services through open source software (OSS). The OpenFin contribution code is based on a standard developed collaboratively by the Foundation’s Desktop API Working Group and is now open source at https://github.com/symphonyoss/symphony-of under the Apache License v2. OpenFin has been a Gold Member of the Foundation and an active participant in the working group.

The Symphony Software Foundation now counts more than 50 projects, 100 plus contributors, four active working groups, and 25 member organizations; The Foundation has recently hosted a notable Open Source Strategy Forum, the first Open Source conference for Financial Services who brought together more than 300 thought leaders and innovators.

“A commitment to open source software has been a core guiding principle at OpenFin and we’ve always strongly supported the Foundation’s efforts to bring that ethos to finance,” said Mazy Dar, CEO of OpenFin. “By enabling Symphony to run on the OpenFin operating system, we are making it easy for our mutual customers to unify the Symphony desktop experience with their other OpenFin-based apps.”

OpenFin's customers include more than 45 of the world’s largest banks and trading platforms. OpenFin OS is licensed across more than 125,000 desktops and is used to deploy hundreds of applications to over 400 major banks and buy-side firms. Using a modern, open technology stack, OpenFin is dedicated to addressing the specific needs of these customers, enabling rapid deployment and interoperability, while simultaneously improving security.

Gabriele Columbro, executive director, Symphony Software Foundation said, “I am particularly thrilled to see OpenFin leveraging open source and open standards to integrate with another Member’s platform. By embracing open source, vendors can benefit from each other’s ecosystems, enabling each firm’s best-in-class technology to reach the widest number of developers. And by leveraging open standards, they can ensure high longevity integration to their customers, resulting in a positive-sum game for the entire industry. It’s through efforts like these, under the transparent and independent forum of our Foundation, that we are sparking innovation on new, high-value collaborative solutions which have the potential of reshaping Wall Street."

About OpenFin

Move fast. Break nothing. OpenFin is the financial industry's first universal operating system, enabling rapid and secure deployment, native experience and desktop interoperability. The world’s largest banks and trading platforms use OpenFin to deploy desktop applications both in-house, and to their buy-side and sell-side customers. OpenFin investors include Bain Capital Ventures, DRW Venture Capital, Euclid Opportunities, J.P. Morgan, Nyca Partners and Pivot Investment Partners among others. The company is based in New York with offices in London.

About Symphony Software Foundation

The Symphony Software Foundation is an independent nonprofit organization building an open source community and development ecosystem to foster innovation in financial services. Its Community leverages Symphony, other open source platforms and open standards to drive efficient inter-firm collaboration in this industry. The Foundation offers an Open Developer Platform (ODP) to all its open source contributors, providing open API access to Symphony and a compliant open source development process. Foundation OSS Projects are Apache 2.0 licensed and available on GitHub To learn more, visit http://symphony.foundation To become a member http://symphony.foundation/#become-a-member

Copyright © 2009 Business Wire. All rights reserved. Republication or redistribution of Business Wire content is expressly prohibited without the prior written consent of Business Wire. Business Wire shall not be liable for any errors or delays in the content, or for any actions taken in reliance thereon.

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Software provides enterprise learning management solution. | killexams.com real questions and Pass4sure dumps

Press Release Summary:

Lotus® Learning Management System (LMS) provides scalable, configurable platform for creating and managing classroom-based and e-learning activities, curriculums, and courseware across enterprise. It helps organize and track required materials, students, and resources. Software also integrates with other Lotus products so that learning environment can be enhanced with collaborative tools such as instant messaging, live virtual sessions, and discussion databases.

Original Press Release: IBM Lotus Learning Management System V1.0.5 Builds on IBM's Leadership in Enterprise Learning Management Solutions

Overview

IBM Lotus® Learning Management System (LMS) is a scalable, highly configurable platform for creating and managing classroom-based and e-learning activities, curriculums, and courseware across the enterprise. Whether the training is to be delivered online or in person, the award-winning Lotus LMS helps organize and track the materials, students, and resources required.

Lotus LMS is also designed to integrate seamlessly with other Lotus products, such as IBM Lotus Virtual Classroom, IBM Lotus Domino(TM) V5, and IBM Lotus Instant Messaging and Web Conferencing, so that the learning environment can be enhanced with valuable collaborative tools such as instant messaging, live virtual sessions, and discussion databases.

What's new in Lotus LMS V1.0.5

As the next maintenance release of the product, Lotus LMS V1.0.5 addresses various customer requests to further enhance the stability and reliability of the application. A few feature enhancements are also available such as:

· The addition of new Web service APIs to extend the current application. Some of the new APIs available will allow external systems to:

- Create classroom-based course masters and offerings in LMS

- Export courses and enrollments from LMS

- Create resources (for example, instructors and classrooms) in LMS

- Create new profiles and profile categories in LMS

· Certification of new releases of currently supported platforms (IBM WebSphere® V5.1).

· The addition of IBM Tivoli® Directory Integrator V5.2 as part of the LMS package. This component facilitates the integration with multiple LDAP directories and can be used to ease the implementation and maintenance of the learning system.

Key prerequisites

LMS servers (Learning server and Delivery server) support the following operating systems:

· Microsoft(TM) Windows 2000 (as of R1.0.3, Microsoft Windows NT(TM) Release 4.0 is no longer supported)

· AIX® V5.1, or later (PowerPC® RISC architecture - IBM pSeries®)

· Sun Solaris V8, or later (UltraSPARC 32/64 architecture - not on Intel(TM))

· Linux(TM) V2.2, or later (Intel 32/64 architecture with SUSE 7.2, or later, and Red Hat 7.2, or later, only)

· Linux Advanced Server 2.1

Planned availability dates

· September 30, 2004: Electronic software delivery

· October 15, 2004: Media and documentation

At a glance

IBM Lotus LMS is a strategic blend of advanced administrative and technical features, which include:

· Continued support of industry standards. Lotus LMS supports SCORM and AICC specifications for content interoperability. These enable organizations to use conformant third-party courseware and the courses they have already created in-house, protecting customers' investments in third-party courseware libraries.

· Easy-to-use authoring. The powerful yet intuitive Authoring Tool allows instructors, or Subject Matter Experts (SMEs), to create courses with minimal technical training; SMEs can create curriculums and custom courseware with no programming skills.

· Seamless collaboration between students and teachers. As the leader in collaboration software, Lotus software helps provide a robust environment within LMS for students and instructors to interact online. Lotus LMS features, such as threaded discussions and chats, are based on Lotus' synchronous and asynchronous collaboration technology. In addition, Lotus LMS is designed from the ground up to interoperate with IBM Lotus Virtual Classroom to deliver a complete e-learning solution. It also provides tight integration with IBM Lotus software tools and portals.

For ordering, contact:Your IBM representative, an IBM Business Partner, or the Americas Call Centers at 800-IBM-CALL Reference: YE001

Related Thomas Industry Update Thomas For Industry

Regulators globally seek to curb supercomputer trading glitches | killexams.com real questions and Pass4sure dumps

By Christopher Elias

LONDON, Aug. 31, (Business Law Currents) – A series of stock market glitches has prompted regulators around the world to introduce new regulations to limit the impact of computer malfunctions on trading. Shielding markets from another Knight Capital disaster, the new rules seek to defend market participants from malicious machines and risky robots.

Stock market savior

Hoping to ride to the rescue of market participants are regulators in the U.S., Europe, Australia and Asia, which are hotly debating new rules to prevent further technology hiccups from impacting markets around the world.

Problems have arisen from a variety of sources including everything from sophisticated algorithm malfunctions to rather more mundane router failures.

In this year alone Knight Capital, Facebook, BATS, the Madrid Stock Exchange, the New York Stock Exchange and the Tokyo Stock Exchange have all suffered at the hands of technology as outages and flash crashes traverse the world’s exchanges.

With computers playing an ever greater role on stock markets, regulators are waking up to their potential dangers. Capable of executing millions of trades a minute, sophisticated technology now does much of what their human counterparts used to. However, with great speed comes great responsibility, and, as the Knight Capital incident demonstrated, potentially great losses.

With computers trading securities in microseconds they are able to cause sudden and sharp changes in stock markets. Most recently a software glitch in an algorithm operated by Knight Capital was able to inflict $440 million of losses on the company in under an hour.

Making the matrix

According to some surveys, high frequency trading firms – firms that operate computerised algorithms capable of trading in a fraction of a second – now account for 73 percent of all equity orders (by volume) in the United States, 40 percent in Europe and between 5 percent and 10 percen of orders in Asia.

The largest high-frequency trading (HFT) firms in the U.S. include Getco LLC, Knight Capital Group, Jump Trading and Citadel, all of which seek to make razor-thin margins on a massive number of trades every day.

HFTs work by placing enormous numbers of securities trades, hoping to make individually small but collectively large margins on tiny discrepancies in the markets. Technology based trading systems are not confined to the HFT industry, however. A number of other algorithmic traders work by employing a range of trading strategies on a much slower timescale.

Recently, however, fears have grown that algorithmic (including HFT) trading has the potential to cause massive adverse effects to stock markets and their participants. Most notable was the recent software glitch at Knight Capital that almost put the company out of business, as shareholders saw their holdings almost wiped out from a hefty rescue package from its competitors.

Knight Capital

As part of software upgrades to the firm’s systems in preparation for the launch of the NYSE’s new retail liquidity program, Knight Capital inadvertently turned on an old piece of software that flooded U.S. stock markets with errant trades.

The software problem caused Knight Capital to buy and sell about 150 different stocks over a period of 30 to 45 minutes, amassing a $7 billion position it later had to unload at a loss.

According to Knight Capital, the loss resulted from a technology issue at the open of trading at the NYSE on August 1, 2012. The issue related to an installation that day of trading software and resulted in Knight Capital sending numerous erroneous orders in NYSE-listed and NYSE Arca securities into the market. Although the software was subsequently removed, it resulted in the company realising a pre-tax loss of approximately $440 million.

As a result of the software malfunction, Knight Capital disclosed that it was the subject to litigation by parties alleging that they have been damaged by this technology issue, including its shareholders. Knight Capital also faces possible SEC or other regulatory action over the issue.

Following the trading glitch, Knight Capital was forced to accept a rescue package from Blackstone, Getco, Jefferies and others to avoid bankruptcy. The rescue, a de facto takeover, demonstrates just how costly the glitch was to the company, with shareholders suffering around a 75 percent dilution as a result of the rescue package.

Japanese jitters

Technology was also responsible for problems on the other side of the Pacific recently, as trading in derivatives on Japan’s largest exchange was halted. A broken router in the TSE’s Tdex+ derivatives trading system, installed last November, affected all trading of Topix futures, government bond futures and options for more than 90 minutes in early trading as an automatic switch to a backup router failed to work properly.

The glitch comes six months after the TSE suffered a breakdown in its data distribution system that knocked out an entire morning’s trading of stocks, at the height of the third-quarter reporting season.

Similar technology faults were seen in Spanish equities, which were disrupted for more than four hours at the beginning of the month when a technical glitch hit the systems of stock market operator Bolsas y Mercados Espanoles SA (BME).

In April, BME switched to a new, faster platform better suited to high-frequency trading, although the changeover has not been without its complications. The temporary shutdown paused trading in the Ibex 35, Spain’s benchmark index, before having a knock-on impact on Smartpool and NYSE Arca Europe, who both host instruments that take their main feed from stocks listed on the Spanish exchange.

These high profile problems follow difficulties with company IPOs that saw trading in Facebook shares severely limited and BATS failing to pull off an IPO on its own exchange.

Such failings have led to a rush in regulator initiatives designed to curb some of the more obvious risks of technology based trading.

Regulatory developments

ESMA guidelines

Effective 1 May 2012, the European Securities and Markets Authority (ESMA) has issued guidelines on algorithmic and high frequency trading that seek to protect markets within the European Union.

Covering regulated markets and multilateral trading facilities, it also applies to investment firms including those that operate algos as well as those firms proving direct market access as part of the service of the execution of orders on behalf of clients.

The guidelines are not restricted to the trading of shares but cover trading in an automated environment of any financial instrument (as defined by MiFID).

Among other things, the guidelines require investment firms to:

  • Provide a feed of the firm’s orders in as close to real time as possible and require systems that monitor these orders. ESMA also proposes that firms have staff members present who can monitor these systems on a continuous basis and be able to respond to enquiries from competent authorities or trading venues;
  • Establish a governance and compliance process to consider the commercial, technical, risk and compliance considerations that out to relevant to electronic trading systems, including trading algorithms;
  • Develop testing methodologies for new algorithms that might include performance simulations/back testing or offline testing within a trading platform testing environment;
  • Place limits on the number and value of trades being placed by a new algorithm;
  • Be able to block or cancel orders that do not meet set price or size parameters.
  • In respect of trading platforms, the guidance includes that firms should:

  • Make use of clearly delineated development and testing methodologies prior to deploying an electronic trading system, and prior to deploying updates;
  • Develop standardized conformance testing to ensure that systems being used to access a trading platform have a minimum level of functionality that is compatible with the platform’s electronic trading system and will not pose a threat to the fair and orderly trading on that platform;
  • Have the ability to limit access, cancel or amend transactions and prevent the excessive flooding of the order book at any one moment in time, through limits per participant on order entry capacity;
  • Have throttling limits to prevent capacity limits being breached;
  • Have effective arrangements to prevent Ping Orders (small orders design to ascertain hidden orders on dark platforms), Quote Stuffing (entering large numbers of orders and/or cancellations to camouflage trading strategies), Momentum Ignition (entry of orders or a series of orders to start or exacerbate a trend) and Layering and Spoofing (submitting multiple orders on one side of the order book to extract a trade at a certain value on the other side of an order book).
  • Australia

    In Australia, the Australian Securities & Investments Commission (ASIC) has put forward similar draft rules on market integrity, although with a few nuances of their own.

    As well as rules on testing, monitoring and cancellations, the ASIC is proposing a self certification process by which investment firms will be required to provide evidence of the systems put in place to control their algorithms (known as “AOPs” in Australia).

    Part of these rules will see the ASIC require annual testing by market participants of their automated operating process (“AOP”) systems, policies and software, to ensure that they continue to function as expected.

    Investment firms will be required to provide an annual notification to ASIC within 10 business days of conducting an annual review detailing the checks made and declaring that nothing came to the attention of the firm during the previous 12 months that would indicate that the firm was unable to comply with the AOP rules.

    Before using an automated order processing system, a market participant will also be required to obtain written representations that it has the appropriate organizational and technical resources, arrangements and controls in place.

    The written representation must be provided by a person suitably qualified and experience in algorithmic trading, include the names of the people making the representation and set out the methodology used to calculate the appropriate security arrangements, testing preparation and system controls.

    Hong Kong

    In July, Hong Kong’s Securities and Futures Commission (SFC) issued a consultation paper on the regulation of electronic trading. It noted that in line with other major international markets, it had observed that market players in Hong Kong are also using complex trading algorithms for the execution of sophisticated trading strategies.

    At present, the SFC relies on the general principles in existing codes and guidelines to regulate algorithmic trading and is considering adding specific rules for algos.

    Much like Europe and Australia, the HK rules place the burden on intermediaries to ensure that pre-trade risk management controls and post-trade monitoring exist to minimise the risk of flash crashes. Pre-trade controls include setting appropriate trading and credit thresholds for each client or proprietary account and alerting or preventing the entry of erroneous orders.

    In a slight divergence from Europe and Australia, the rules extend pre-trade risk protections on algorithmic trading to all internet trading provided to clients by brokers. This means that at least some of the risk management controls will extend to retail clients using internet trading services.

    The SFC’s consultation also suggests that it will implement requirements for testing of algorithms prior to launch by suitably qualified persons.

    U.S.

    Although the SEC produced an extensive report on the market events leading up to the ‘flash crash’ of May 6, 2010 formal rule making has been thin.

    In November 2010, the SEC introduced SEC Market Access Rule (15c3-5), designed to eliminate unfiltered” or “naked access” to equity execution venues and requires brokers to establish pre-trade risk controls in all cases but has made little formal regulations since.

    Rule 15c3-5 requires brokers to establish, document, and maintain a system of risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks, such as legal and operational risks, related to such market access.

    Specifically, the rule requires broker-dealers to limit the financial exposure of the broker or dealer that could arise as a result of market access and to ensure compliance with all regulatory requirements applicable with market access.

    The financial risk management controls and supervisory procedures must prevent the entry of orders that exceed pre -set credit or capital thresholds, or that appear to be erroneous.

    According to Rule 15c3-5 it may be appropriate for broker-dealers to fine-tune these thresholds on a sector or industry as well as an exchange by exchange basis. For example, it may be reasonable for a broker to set a credit limit for a customer of $1 million with individual market centre credit limits of $200,000 (for five exchanges or ATSs).

    Rule 15c3-5 does not, however, specify what would be an appropriate credit or capital limit for clients and instead devolves responsibility to brokers to determine what would be a reasonable restriction.

    On an annual basis, the CEO or equivalent of the broker-dealer will be required to certify that the risk management controls and supervisory procedures comply with Rule 15c3-5 and that a regular review of procedures and systems had been conducted.

    In March 2011, the CFTC Technology Advisory Committee recommended introducing pre-trade risk controls for firms providing direct market access for clients. These include ensuring that customers do not take on excessive risks through placing quantity limits on individual orders, introducing price collars (ensuring prices are too far away from current market rates), execution throttles, message throttles and kill buttons.

    The Financial Industry Regulatory Authority (FINRA) has also stated that it expects firms generating orders by the use of trading algorithms to have written policies and procedures in place that are reasonably design to ensure that such trading complies with applicable rules, regulations and laws, including anti-manipulation provisions.

    Fearing the machines

    Despite these regulatory developments a number of companies disclose the threat that flash crashes and market glitches may still pose to their businesses. For example, Abbey National Treasury Services Plc, part of the Santander Group, notes in its €2 billion German Note and Certificate Programme that the events such as the Flash Crash in New York on 6 May 2010 could mean that the value observed for notes that link to securities might not reflect the true value of the underlying assets.

    For example, Abbey notes that during the Flash Crash, the market moved significantly downwards before subsequently correctly shortly afterwards. While its securities may include provisions to allow the postponement of valuation in the event of certain disruptions in the market, not all significant market movements will be covered by these provisions. There may therefore become a disconnect between the value assigned to the relevant assets versus their actual value.

    Similar disclosures were made by investment funds that warned that sharp market movements could impact upon their strategies.

    Factorshares S&P GSCI 2X Crude Oil Premium stated that it might invest in substitute futures or financial instruments if the market for a specific Index Futures Contract experiences emergencies or disruptions, such as a trading halt or flash crash.

    MA Managed Futures funds disclosed that a flash crash could undermine the effectiveness of its stop-loss orders. It noted that stop-loss orders may be executed at a much lower level than the stop price if the market is falling rapidly, experiencing above average volatility, or undergoing a so-called “flash crash”. The effect of these would be to lock in large realized losses.

    Funds and others will be hoping that these latest regulations can indeed ensure an OK computer for all.

    (This article was first published by Thomson Reuters’ Business Law Currents, a leading provider of legal analysis and news on governance, transactions and legal risk. Visit Business Law Currents online at http://currents.westlawbusiness.com)



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