prince7
09-30 02:56 PM
Hi Smartboy75 & Wawa, I also received the same update on Sep 28th ,I am in pending h1b transfer and uscis tried to reopen my previous approved h1b .
I am June filer and got all the receipts. Please keep me posted as well.
Appreciate your inputs.
I am June filer and got all the receipts. Please keep me posted as well.
Appreciate your inputs.
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masouds
06-12 02:45 PM
What are you talking? which part of the world do you belong? Obama is the democratic candidat for 2008 Presidential Elections Its conformed.He is not still fighting and also he how can you justify that he is a weak person? do you know he was no where in the picture and no one expected he will won the nomination when the Democratic Primary was begun..now he is the democratic PRESIDENTIAL NOMINEE..by now you should have undestand how powerful he is.
Weak or strong, either he (or Sen. McCain) will be president, and not king. They may have a strong influence in the Congress, but they can't boss it around. Specially since a minority in congress (be it Democrat or Republican) has its own way of stalling bills they don't like. I hope next president brings sanity back to the Washington.
Weak or strong, either he (or Sen. McCain) will be president, and not king. They may have a strong influence in the Congress, but they can't boss it around. Specially since a minority in congress (be it Democrat or Republican) has its own way of stalling bills they don't like. I hope next president brings sanity back to the Washington.
trueguy
08-12 02:02 PM
http://www.visi.com/juan/congress/
Once the Break is Over in 2nd week of September, We all should call members of congress , as many as possible, to get their Support for Visa Recapture Bill. If that bill passes, it will help all the EB categories.
Chances of this bill passing through all the steps are very slim in this year.
Once the Break is Over in 2nd week of September, We all should call members of congress , as many as possible, to get their Support for Visa Recapture Bill. If that bill passes, it will help all the EB categories.
Chances of this bill passing through all the steps are very slim in this year.
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abhijitp
12-03 05:24 PM
One of the approaches can be for state chapters to be involved and solicit donations from local members. I liked the idea for donations from immigrants who have already obtained green cards and online ADS from google as long as we do not overdo it. I am leaning more towards funding drives. For reasons that people in the process understand better than I do, I agree that the amounts cannot be disclosed. Hence it would be nice to have offline discussions or discussions on PMs on targets between state chapter members.
I for one am not for monthly payments or memberships. That just makes for exclusive organization and we want to be more inclusive.
I also had another important question we need to ask ourselves. Do we want to solicit funding or donations or participation? They are two very different things. Participation is not limited to monetary involvement but can include time and ability (designing banners, websites, writing letters et al.) donation.
Cheers
Every member is welcome to contribute time and/or money. Both are important.
Monthly subscriptions do not make this an exclusive club, they just allow IV to budget and plan future campaigns.
Some of these campaigns will give everyone easy access to the (very exclusive) "AOS applied" club!
The biggest campaign of them all... will give us all a quicker route to the extremely very exclusive Green Card club.
To know why amounts cannot be disclosed please check out logiclife's and aman's videos on youtube!
Thank you.
I for one am not for monthly payments or memberships. That just makes for exclusive organization and we want to be more inclusive.
I also had another important question we need to ask ourselves. Do we want to solicit funding or donations or participation? They are two very different things. Participation is not limited to monetary involvement but can include time and ability (designing banners, websites, writing letters et al.) donation.
Cheers
Every member is welcome to contribute time and/or money. Both are important.
Monthly subscriptions do not make this an exclusive club, they just allow IV to budget and plan future campaigns.
Some of these campaigns will give everyone easy access to the (very exclusive) "AOS applied" club!
The biggest campaign of them all... will give us all a quicker route to the extremely very exclusive Green Card club.
To know why amounts cannot be disclosed please check out logiclife's and aman's videos on youtube!
Thank you.
more...
sbabunle
08-19 04:59 PM
Not a bit sir.
>> Are you making money? (bottom line hehe)
How does that bother you? Thanks for the good laugh, BTW. :D
>> Are you making money? (bottom line hehe)
How does that bother you? Thanks for the good laugh, BTW. :D
harikris
05-14 05:13 PM
A very sensible post. You dont need to have ur life around the GC and Priority dates. You need to do what u want to as much as within ur limits.. But one thing is USCIS can be staright forward and say EB-I wont move for such and such time and people can still plan better... :)
I agree. On an average, it seems, one spends just about 6 yrs to get his/her GC. That's nearly 20% of our productive "employment" life. At some point in the process, one starts to wonder if he/she can lay their roots in this country.
It is not an easy or trivial task to "just move on" and pursue plan B or plan C.
With passage of time, the priorities and the drive of people change.
So, the immigration system should be quick and transparent.
If you notice in daily life, there is always a "good-faith" disclosure of terms and conditions before signing up for anything. And both parties strive to keep their end of the deal.
That's all we are really asking from the SYSTEM - "If you are willing to open the gates for immigrants, please process their applications to the best extent possible and don't hold up our lives"
What is missing in this system is "empathy". Rules are fine and we also understand the over-subscription in certain categories. But at the end of day, the controlling or executive authorities have to show some empathy to those that are left hanging. Rules are made to help people and they should not become an excuse to punish [PR process delayed is justice denied, truly] the common folks instead.
President Obama has stated he would like have an empathetic judge on the supreme court. Likewise, we need someone heading the immigration system that empathizes with the lives of prospective PR lot.
What can we do to seek such a leader or change?
I agree. On an average, it seems, one spends just about 6 yrs to get his/her GC. That's nearly 20% of our productive "employment" life. At some point in the process, one starts to wonder if he/she can lay their roots in this country.
It is not an easy or trivial task to "just move on" and pursue plan B or plan C.
With passage of time, the priorities and the drive of people change.
So, the immigration system should be quick and transparent.
If you notice in daily life, there is always a "good-faith" disclosure of terms and conditions before signing up for anything. And both parties strive to keep their end of the deal.
That's all we are really asking from the SYSTEM - "If you are willing to open the gates for immigrants, please process their applications to the best extent possible and don't hold up our lives"
What is missing in this system is "empathy". Rules are fine and we also understand the over-subscription in certain categories. But at the end of day, the controlling or executive authorities have to show some empathy to those that are left hanging. Rules are made to help people and they should not become an excuse to punish [PR process delayed is justice denied, truly] the common folks instead.
President Obama has stated he would like have an empathetic judge on the supreme court. Likewise, we need someone heading the immigration system that empathizes with the lives of prospective PR lot.
What can we do to seek such a leader or change?
more...
bluekayal
05-20 12:55 PM
Could anyone recommend medical insurance for parents over 80?
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StuckInTheMuck
04-28 07:21 AM
is 2, 3, 4, 5 important for citizenship?
As I said in the preface of the list, the bigger objective here is to take certain steps, including proper documentation (e.g. points 2, 3, 4 and 5), in order to maintain PR status. Besides, you never know what documents you would be asked to produce, given that the citizenship process involves more extensive background checks than the GC process. Also, having a log of exit/entry details (point #5) should help quickly fill out Part 7 of the citizenship form (http://www.uscis.gov/files/form/N-400.pdf).
Added to Wiki here After GC Dos and Donts (http://immigrationvoice.org/wiki/index.php/US_Life_After_GC)
Thanks a bunch, coopheal. As I keep updating the list (based on feedbacks from subsequent posts), is there an easy way to update the Wiki page too?
Never mind, I managed to update it myself.
As I said in the preface of the list, the bigger objective here is to take certain steps, including proper documentation (e.g. points 2, 3, 4 and 5), in order to maintain PR status. Besides, you never know what documents you would be asked to produce, given that the citizenship process involves more extensive background checks than the GC process. Also, having a log of exit/entry details (point #5) should help quickly fill out Part 7 of the citizenship form (http://www.uscis.gov/files/form/N-400.pdf).
Added to Wiki here After GC Dos and Donts (http://immigrationvoice.org/wiki/index.php/US_Life_After_GC)
Thanks a bunch, coopheal. As I keep updating the list (based on feedbacks from subsequent posts), is there an easy way to update the Wiki page too?
Never mind, I managed to update it myself.
more...
mirage
08-12 07:03 PM
more than 200 people have taken this poll, if only half of us send these letters, it could make a difference..
To, 08/05/2008
Charles Oppenheim / Visa Section
U.S. Department of State
2201 C Street NW
Washington, DC 20520
From,
Your Name/Your Address/EB-3 India Applicant
Priority Date: May 2003
Some City,
OK-2#####
Dear Sir/Madam,
Sub: Statistics on Employment Based AOS(Adjustment of Status) applications pending at USCIS under various categories
I am writing to you to express my sense of helplessness over the unpredictability of Visa Number allotment to various employment based category. I want to bring to your attention that it�s been nearly a �Decade� since we saw any meaningful Visa Date movement from year 2001 for EB-3 Green Card applicants from India.
It is important to know that despite of severe visa retrogression and random visa cutoff date movements, USICIS or DOS hasn�t released any official information on how many Adjustment of Status applications are pending at USCIS under various categories which leaves thousands of AOS(Adjustment of Status) applicants in complete darkness and dependent on guessing games by various Law firms.
A green card application requires enormous amount of efforts and money from the beneficiary and his/her employer. People who are waiting for 7-8 years now would have had already spent average $15,000-$20,000, in maintaining their statuses and keep the Green Card process going on. Being stuck in a green card process keeps us bonded with 1 employer, job type etc.
We need to know if there is any light at the end of the tunnel. We need to know for how long we have to live our life in limbo. If there is hope than we need to be patient and plan to live like that for another 1-2 years. But if there�s no light at the end of the tunnel than we need to move on with our careers and other family commitments. Only your office and USCIS can help us by releasing statistics on the number and categories of applications pending with USCIS people waiting in this category can plan their lives accordingly.
It will be a great help if DOS or USCIS could tell us about the number of AOS application pending at USCIS along with their Categories(EB-3, EB-2, EB-1) and chargeable country.
We have been waiting for a decade and continue to wait would it be reasonable to request you for some guidance with regards to the Visa allotment. I request your office to provide some statistics on home many Adjustment of Status applications are pending at USCIS.
We understand that you work with in the limits of the law as set by the Congress and are limited by various constraints that are beyond your agency realm of work. We appreciate your hard work and sincerely thank you for all the hard work.
God Bless America!
Thank you for you attention,
(Your Name OR EB-3 India Applicant )
Priority Date: April 02
Category: EB-3
Member ImmigrationVoice.Org
Copy Sent to
Honorable Secretary of State
Dr. Condoleezza Rice
U.S. Department of State
2201 C Street NW
Washington, DC 20520
Honorable Director, USCIS
U.S. Citizenship and Immigration Service
20 Massachusetts Avenue, NW
Washington, D.C. 20529
Citizenship and Immigration Services Ombudsman
Department of Homeland Security
Attention: Case Problems
Mail Stop 1225
Washington, D.C. 20528-1225
Senator John Cornyn
Chairman - United States Senate Judiciary Subcommittee on
Immigration, Border Security and Citizenship
517 Hart Senate Office Bldg.
Washington, DC 20510
Main: 202-224-2934
Fax: 202-228-2856
Congresswoman Zoe Lofgren
Chairwoman - United States House Judiciary Subcommittee on Immigration, Citizenship,
Refugees, Border Security, and International Law
102 Cannon HOB
Washington, D.C. 20515
Telephone (202) 225-3072
To, 08/05/2008
Charles Oppenheim / Visa Section
U.S. Department of State
2201 C Street NW
Washington, DC 20520
From,
Your Name/Your Address/EB-3 India Applicant
Priority Date: May 2003
Some City,
OK-2#####
Dear Sir/Madam,
Sub: Statistics on Employment Based AOS(Adjustment of Status) applications pending at USCIS under various categories
I am writing to you to express my sense of helplessness over the unpredictability of Visa Number allotment to various employment based category. I want to bring to your attention that it�s been nearly a �Decade� since we saw any meaningful Visa Date movement from year 2001 for EB-3 Green Card applicants from India.
It is important to know that despite of severe visa retrogression and random visa cutoff date movements, USICIS or DOS hasn�t released any official information on how many Adjustment of Status applications are pending at USCIS under various categories which leaves thousands of AOS(Adjustment of Status) applicants in complete darkness and dependent on guessing games by various Law firms.
A green card application requires enormous amount of efforts and money from the beneficiary and his/her employer. People who are waiting for 7-8 years now would have had already spent average $15,000-$20,000, in maintaining their statuses and keep the Green Card process going on. Being stuck in a green card process keeps us bonded with 1 employer, job type etc.
We need to know if there is any light at the end of the tunnel. We need to know for how long we have to live our life in limbo. If there is hope than we need to be patient and plan to live like that for another 1-2 years. But if there�s no light at the end of the tunnel than we need to move on with our careers and other family commitments. Only your office and USCIS can help us by releasing statistics on the number and categories of applications pending with USCIS people waiting in this category can plan their lives accordingly.
It will be a great help if DOS or USCIS could tell us about the number of AOS application pending at USCIS along with their Categories(EB-3, EB-2, EB-1) and chargeable country.
We have been waiting for a decade and continue to wait would it be reasonable to request you for some guidance with regards to the Visa allotment. I request your office to provide some statistics on home many Adjustment of Status applications are pending at USCIS.
We understand that you work with in the limits of the law as set by the Congress and are limited by various constraints that are beyond your agency realm of work. We appreciate your hard work and sincerely thank you for all the hard work.
God Bless America!
Thank you for you attention,
(Your Name OR EB-3 India Applicant )
Priority Date: April 02
Category: EB-3
Member ImmigrationVoice.Org
Copy Sent to
Honorable Secretary of State
Dr. Condoleezza Rice
U.S. Department of State
2201 C Street NW
Washington, DC 20520
Honorable Director, USCIS
U.S. Citizenship and Immigration Service
20 Massachusetts Avenue, NW
Washington, D.C. 20529
Citizenship and Immigration Services Ombudsman
Department of Homeland Security
Attention: Case Problems
Mail Stop 1225
Washington, D.C. 20528-1225
Senator John Cornyn
Chairman - United States Senate Judiciary Subcommittee on
Immigration, Border Security and Citizenship
517 Hart Senate Office Bldg.
Washington, DC 20510
Main: 202-224-2934
Fax: 202-228-2856
Congresswoman Zoe Lofgren
Chairwoman - United States House Judiciary Subcommittee on Immigration, Citizenship,
Refugees, Border Security, and International Law
102 Cannon HOB
Washington, D.C. 20515
Telephone (202) 225-3072
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smsthss
09-17 11:32 AM
immigration thing being discussed
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santa123
06-11 07:07 PM
I called all the reps:D
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willwin
09-17 02:08 PM
I strongly believe that they will mark up the bill HR 5882 today; it may go late in to the evening and may happen with minimal resistance.
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DSLStart
09-17 02:01 PM
How much do these ppl eat? and Bush says food scarcity crisis is because of India ;)
Is 25 mins not up yet.... this is worse than the so called Indian Standard Time.
Is 25 mins not up yet.... this is worse than the so called Indian Standard Time.
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kumarc123
01-10 09:38 AM
I have been a IV member since 2006 . I have seen the ups/downs . donated money , sent letters , attended rallies and done whatever has been been proposed . But I see that many senior members who had the drive to motivate people are not sending or being part of any messages or threads at all and that is exactly why the movement seems to be losing steam .
The standard response that I see to any question is "have you donated money ? " . "Don't ask for anything till you have donated. " this is followed by some some red dots which normally works to silence the questions. People will be willing to donate when they believe in the movement . I remember we collected $ 30,000 in 1 month before the rally there was huge thread with all the donations . People were charged up and the money came up automatically . I am willing to donate but to be brutally honest I do not see the same level of motivation as was there in 2006 / 2007 days .Please use this as a wakeup call and not as reason to vent your frustration on me .
There are many senior members who I do not even see any more . Members joining in late 2007 or early 2008 will not know any of these guys .
Aman Kapoor . He is the founder of IV . I have not seen his messages since the past 3 years almost . Where is he ? Is it too much for him to send a greeting in New years eve motivating the members ? It takes just 2 minutes .
Mark Bartosik :- He was supposed to the spokesperson for IV .The guy with the MasterCard sign for immigration . I have not seen him for quite some time now
Where are the other senior leaders like
a) Walden Pond
b) There was a this British Girl from San Jose ( had a handle which had name like Rose or something )
c) Niloufer Bustani from Dallas. I see her once in a while but very sparingly .
The others even I have forgotten completely.
The only leadership/core that I see is Pappu and no one else . If you have a country where the prime minister shows his face only once in 4 years , how are the people supposed to believe in that movement ? Please don't reply with a message saying what have I done or why can't I contribute money ? I have done that I am looking for leadership to show us the way and motivate us . All campaigns don't need money donations( Letters , calls , faxes etc ) . We could start with that and then drum up support and momentum and then the money will start flowing in automatically . There has to be a synchronized campaign organized by the leadership and all I see is everybody putting their eggs in the basket called spillover.
Precisely,
they ask me for monthly contributions and I ask them to hold something big, a rally or something first, as I was not July2007 filer. That's why I am stopping to come here now. To ask for contributions, IV must hold something big,
The standard response that I see to any question is "have you donated money ? " . "Don't ask for anything till you have donated. " this is followed by some some red dots which normally works to silence the questions. People will be willing to donate when they believe in the movement . I remember we collected $ 30,000 in 1 month before the rally there was huge thread with all the donations . People were charged up and the money came up automatically . I am willing to donate but to be brutally honest I do not see the same level of motivation as was there in 2006 / 2007 days .Please use this as a wakeup call and not as reason to vent your frustration on me .
There are many senior members who I do not even see any more . Members joining in late 2007 or early 2008 will not know any of these guys .
Aman Kapoor . He is the founder of IV . I have not seen his messages since the past 3 years almost . Where is he ? Is it too much for him to send a greeting in New years eve motivating the members ? It takes just 2 minutes .
Mark Bartosik :- He was supposed to the spokesperson for IV .The guy with the MasterCard sign for immigration . I have not seen him for quite some time now
Where are the other senior leaders like
a) Walden Pond
b) There was a this British Girl from San Jose ( had a handle which had name like Rose or something )
c) Niloufer Bustani from Dallas. I see her once in a while but very sparingly .
The others even I have forgotten completely.
The only leadership/core that I see is Pappu and no one else . If you have a country where the prime minister shows his face only once in 4 years , how are the people supposed to believe in that movement ? Please don't reply with a message saying what have I done or why can't I contribute money ? I have done that I am looking for leadership to show us the way and motivate us . All campaigns don't need money donations( Letters , calls , faxes etc ) . We could start with that and then drum up support and momentum and then the money will start flowing in automatically . There has to be a synchronized campaign organized by the leadership and all I see is everybody putting their eggs in the basket called spillover.
Precisely,
they ask me for monthly contributions and I ask them to hold something big, a rally or something first, as I was not July2007 filer. That's why I am stopping to come here now. To ask for contributions, IV must hold something big,
more...
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Brightsider
07-24 11:48 AM
Having seen numerous threads in which the exchanges became rude/sarcastic/rude or even outright abusive and vulgar, I was hoping that this would not become one.
Ron, while you may have a point in what you say, sarcasm and taunts will get you no where. As you said, the 'antis' are gearing up, suggesting (I presume) that the effort of all of us should be more concerted and determined. But you are not doing yourself any favor by saying the things that you do.
Raji had a point of view, and has not been rude or offensive in expressing it. In fact, her/his first post was out why it is not good to use the AILA template. Well, PASKAL did try to address. Raji's tone or tenor of posts did not merit a peremptory reply, much less a rude one.
Be that as it may, I do believe fervently that even if someone insists/demands an answer, you can always ignore it instead of being rude or aggressive.
That way there will be more people on IV'S side.
Ron, while you may have a point in what you say, sarcasm and taunts will get you no where. As you said, the 'antis' are gearing up, suggesting (I presume) that the effort of all of us should be more concerted and determined. But you are not doing yourself any favor by saying the things that you do.
Raji had a point of view, and has not been rude or offensive in expressing it. In fact, her/his first post was out why it is not good to use the AILA template. Well, PASKAL did try to address. Raji's tone or tenor of posts did not merit a peremptory reply, much less a rude one.
Be that as it may, I do believe fervently that even if someone insists/demands an answer, you can always ignore it instead of being rude or aggressive.
That way there will be more people on IV'S side.
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mariner5555
05-23 02:02 PM
I agree too with the original post by pointlesswait !! ..digital signature is good ..or if there is a site which allows people to show their support (I guess there are sites like these) .. also, in the document we should include these points (small and precise document) ..
- why legals are suffering
- advantages that legal immigration brings to US
- the effect of few senior professionals leaving the country etc .
..for e.g. ..if a senior programmer or lead gets frustrated and goes back then all this happens ..he / she takes the job away with him ..and in turn trains 10 other people (so more jobs go away). also along with a skilled person - all the investment and taxes are lost ..(for eg ..house + prop tax + living expenses etc etc) .. and the fact that US is turning older (i.e average age ..) etc etc
and a related point ..each IV member should try to contact 5 other immigrants and tell them about IV ..and they in turn should atleast show some sort of support
- why legals are suffering
- advantages that legal immigration brings to US
- the effect of few senior professionals leaving the country etc .
..for e.g. ..if a senior programmer or lead gets frustrated and goes back then all this happens ..he / she takes the job away with him ..and in turn trains 10 other people (so more jobs go away). also along with a skilled person - all the investment and taxes are lost ..(for eg ..house + prop tax + living expenses etc etc) .. and the fact that US is turning older (i.e average age ..) etc etc
and a related point ..each IV member should try to contact 5 other immigrants and tell them about IV ..and they in turn should atleast show some sort of support
more...
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chanduv23
12-17 10:18 AM
Hi Chanduv,
Possible to post a format on IV...with information pertaining to visa recapture etc.
Regards
Vsach
Sure, anyone can come up with a template. It is members who drive this thread. IV is all of us, you and me and all
Possible to post a format on IV...with information pertaining to visa recapture etc.
Regards
Vsach
Sure, anyone can come up with a template. It is members who drive this thread. IV is all of us, you and me and all
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kshitijnt
07-17 09:53 PM
Recapturing lost numbers is not a permanent solution. Per country limit 7% is ridiculous. We need to make sure we are not discriminated against by the per country limit. Its not my fault that someone from Europe doesnt want to come here and not so many from Africa or south america qualify for the EB visas.
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raj3078
08-26 04:18 PM
Lots of people use SBI for transfer but nobody answered my earlier question? DOES SBI allows electronic transfer to NON SBI accounts?
smisachu
08-01 05:34 PM
Hi smisachu,
Could you explain what you mean by this? Are you referring to "Flash Trading"
or the whole of HFT?
Yes Flash trading, ELP (enhanced liquidity program), direct access trading and even other program trading. The programs seek out discreet blocks that are being routed into the market and front run them. The main culprit according to many is GS. And to acheive a significant alpha the size and leverage are huge. Some program with a bug will dump a lot of shares on the market some day and before any one can react. Here is an article on some info that was made available only to bloomberg users.
"Lime Brokerage: "The Next 'Long Term Capital' Meltdown Will Happen In
A Five-Minute Time Period."
Posted by Tyler Durden at 11:25 AM
A recent Bloomberg piece that for some reason was made available only
to terminal subscribers, provides a very interesting discussion on the
dangers of sponsored access, how the associated pre-trade vs post-
trade monitoring deliberations by "regulators" will influence short
selling curbs, and not surprisingly, the desire by Goldman to not only
dominate this yet another aspect of high-frequency trading, but to
dictate market policy at will.
What is sponsored access:
In sponsored access, a broker-dealer lends its market participation
identification (MPID) number to clients for them to trade on exchanges
without going through the broker's trading system, to avoid slowing
down the execution. That places responsibility on the broker-dealer to
make sure the participant abides by securities regulations, and that
its trading, which can involve hundreds or thousands of orders a
second, does not run amok.
Is it thus surprising, that none other than Goldman Sachs is muscling
its way into providing not only a sponsored access platform to its
clients, but a new form of sponsored access that needs the blessing of
regulators:
Wall Street heavyweight Goldman Sachs, now launching its own sponsored-
access service to lend clients its identification to access securities
exchanges directly, said last week it favors monitoring client orders
prior to execution.
"Our view is that there is a real need for pre-trade checks in the use
of sponsored access to fulfill [broker-dealers'] regulatory
responsibilities," said Greg Tusar, managing director at Goldman.
Goldman's stand in favor of pre-trade instead of post-trade monitoring
of sponsored clients' activity is one side of a debate in which
regulators may choose a middle ground. The regulators' decision on how
to monitor sponsored access may also influence their deliberations on
restricting short sales.
What is the difference between pre-trade and post-trade monitoring? In
brief:
Pre-trade
Compliant with Reg SHO
Nip problems before they happen
View activity across exchanges
Post-trade
Faster order executions
Pre-trade systems still fallible
And another tidbit:
In traditional sponsored-access arrangements, a broker-dealer
determines a client's suitability to access market centers directly
and then allows the client to trade without monitoring its individual
orders prior to execution.
In other words, the Goldman endorsed pre-trade approach will allow
"monitoring of individual orders prior to execution." Whether or not
pre-trade checks provide the capacity to observe not just wholesale
exchange activity in the context of sponsored access but from a much
broader market angle is a discussion for another time, although this
could be one place where Sergey Aleynikov could shed an infinite
amount of light, especially as pertains to Goldman's sponsored-access
service. Conveniently, his gag order will prevent him from saying much
if anything until such time as there is an appetizing settlement to
keep him gagged in perpetuity. The bottom line is that with a pre-
trade environment, the sponsored access providers will be able to have
the potential to front run all those who use their platforms. The
residual question of how far they go to comply with regulations to
prevent this from happening, and remain true to their ethics standards
is also a topic for another day.
Going back to the topic at hand. Here is why sponsored access could
easily be quite a bother to capital markets sooner rather than later:
Unchecked errors or unintended repeat orders could deplete broker-
dealers' capital, and potentially wreak havoc in the broader market.
Concerns have arisen, however, about whether all broker-dealers are
able to fulfill that duty in today's electronic trading environment,
and according to which standards.
And here Goldman chimes in to not only promote their proposed
architecture but to expound on the virtues of pre-trade checking.
"In the case of high-frequency trading, in particular guarding against
technology failures, oversized orders and other situations where
there's potentially systemic market impact, we believe strongly that
pre-trade checks are a prerequisite," Tusar says.
Nasdaq's proposal as well as Securities and Exchange Commission
officials' speeches a few months ago appeared to lean toward
bolstering the traditional approach.
"We don't believe that's strong enough or what the regulators want
now, because of the potentially dire consequences, and because we-as
broker-dealers-bear much of that risk," Tusar says.
Now the reason why this is very relevant in the context of not just
potential front running, but also market structure is that Regulation
SHO, which is the primary regulatory framework for short selling (and
the purvey of potential Uptick Rule reinstatement, which will happen
once the market is allowed to hit a bid) is a post-trade
architecture.
Wedbush [Morgan] routinely tests clients' systems to ensure they are
compliant with Reg SHO. In addition, he says, the brokerage sets
limits on clients available locates-as well as credit and trading
limits--before the start of each trading day that its system tracks,
prohibiting shorts without locates and providing a type of pre-trade
check.
Or as has recently become the case, seeing rolling buy ins in the
middle of the day as borrowable shares in even the most liquid stocks
mysteriously disappear (look at today's market action for yet another
blatant example of this practice).
Anticipating the regulators' likely response, one should not be
surprised to see them siding with Goldman and against shorters:
As the SEC also seeks to appease investor concerns over rampant short
selling, especially naked short selling, new sponsored-access
standards may provide part of the solution. Given that day-traders may
be the last remaining culprits of such activity,, increasing and
standardizing scrutiny over their trading may reduce uncovered (and
illegal) shorts even further.
How about appeasing concerns over rampant, unjustified buying? When
will the downtick buy rule be implemented? But we jest.
And I digress again. Why should all this be concerning to advocates of
stability of high-frequency trading:
The mother of all concerns is a sponsored firm's algorithm going awry
and executing thousands of problematic trades across a range of
securities and market centers.
Well, this is not really a problem when it happens to the upside as
has been the case for months now - it is only a threat when Joe
Sixpack's 401(k) may be impacted, i.e., to the downside.
And here is where a SEC Comment submitted by broker Lime Brokerage is
a very troubling must read by all who naively claim that High-
frequency trading is a boon to an efficient market (which doesn't
provide . Well, yes and no - it is, until such moment that it causes
the market to, literally, break. I will post a critical excerpt from
the Lime submission, and leave the rest to our readers' independent
analysis:
Lime's familiarity with high speed trading allows us to benchmark some
of the fastest computer traders on the planet, and we have seen CDT
(Computerized Day Trading) order placement rates easily exceed 1,000
orders per second. Should a CDT algorithm go awry, where a large
amount of orders are placed erroneously or where the orders should not
have passed order validation, the Sponsor will incur a substantial
timelag in addressing the issue. From the moment the Sponsor�s
representative detects the problem until the time the problematic
orders can be addressed by the Sponsor, at least two mintues will have
passed. The Sponsor�s only tools to control Sponsored Access flow are
to log into the Trading Center�s website (if available), place a phone
call to the Trading Center, or call the Sponsee to disable trading and
cancel these erroneous orders � all sub-optimal processes which
require human intervention. With a two minute delay to cancel these
erroneous orders, 120,000 orders could have gone into the market and
been executed, even though an order validation problem was detected
previously. At 1,000 shares per order and an average price of $20 per
share, $2.4 billion of improper trades could be executed in this short
timeframe. The sheer volume of activity in a concentrated period of
time is extremely disruptive to the process of maintaining a �fair and
orderly� market. This shortcoming needs to be addressed if the
practice of Naked Access is going to be permitted to continue;
otherwise, the next �Long Term Capital� meltdown will happen in a five-
minute time period.
Could you explain what you mean by this? Are you referring to "Flash Trading"
or the whole of HFT?
Yes Flash trading, ELP (enhanced liquidity program), direct access trading and even other program trading. The programs seek out discreet blocks that are being routed into the market and front run them. The main culprit according to many is GS. And to acheive a significant alpha the size and leverage are huge. Some program with a bug will dump a lot of shares on the market some day and before any one can react. Here is an article on some info that was made available only to bloomberg users.
"Lime Brokerage: "The Next 'Long Term Capital' Meltdown Will Happen In
A Five-Minute Time Period."
Posted by Tyler Durden at 11:25 AM
A recent Bloomberg piece that for some reason was made available only
to terminal subscribers, provides a very interesting discussion on the
dangers of sponsored access, how the associated pre-trade vs post-
trade monitoring deliberations by "regulators" will influence short
selling curbs, and not surprisingly, the desire by Goldman to not only
dominate this yet another aspect of high-frequency trading, but to
dictate market policy at will.
What is sponsored access:
In sponsored access, a broker-dealer lends its market participation
identification (MPID) number to clients for them to trade on exchanges
without going through the broker's trading system, to avoid slowing
down the execution. That places responsibility on the broker-dealer to
make sure the participant abides by securities regulations, and that
its trading, which can involve hundreds or thousands of orders a
second, does not run amok.
Is it thus surprising, that none other than Goldman Sachs is muscling
its way into providing not only a sponsored access platform to its
clients, but a new form of sponsored access that needs the blessing of
regulators:
Wall Street heavyweight Goldman Sachs, now launching its own sponsored-
access service to lend clients its identification to access securities
exchanges directly, said last week it favors monitoring client orders
prior to execution.
"Our view is that there is a real need for pre-trade checks in the use
of sponsored access to fulfill [broker-dealers'] regulatory
responsibilities," said Greg Tusar, managing director at Goldman.
Goldman's stand in favor of pre-trade instead of post-trade monitoring
of sponsored clients' activity is one side of a debate in which
regulators may choose a middle ground. The regulators' decision on how
to monitor sponsored access may also influence their deliberations on
restricting short sales.
What is the difference between pre-trade and post-trade monitoring? In
brief:
Pre-trade
Compliant with Reg SHO
Nip problems before they happen
View activity across exchanges
Post-trade
Faster order executions
Pre-trade systems still fallible
And another tidbit:
In traditional sponsored-access arrangements, a broker-dealer
determines a client's suitability to access market centers directly
and then allows the client to trade without monitoring its individual
orders prior to execution.
In other words, the Goldman endorsed pre-trade approach will allow
"monitoring of individual orders prior to execution." Whether or not
pre-trade checks provide the capacity to observe not just wholesale
exchange activity in the context of sponsored access but from a much
broader market angle is a discussion for another time, although this
could be one place where Sergey Aleynikov could shed an infinite
amount of light, especially as pertains to Goldman's sponsored-access
service. Conveniently, his gag order will prevent him from saying much
if anything until such time as there is an appetizing settlement to
keep him gagged in perpetuity. The bottom line is that with a pre-
trade environment, the sponsored access providers will be able to have
the potential to front run all those who use their platforms. The
residual question of how far they go to comply with regulations to
prevent this from happening, and remain true to their ethics standards
is also a topic for another day.
Going back to the topic at hand. Here is why sponsored access could
easily be quite a bother to capital markets sooner rather than later:
Unchecked errors or unintended repeat orders could deplete broker-
dealers' capital, and potentially wreak havoc in the broader market.
Concerns have arisen, however, about whether all broker-dealers are
able to fulfill that duty in today's electronic trading environment,
and according to which standards.
And here Goldman chimes in to not only promote their proposed
architecture but to expound on the virtues of pre-trade checking.
"In the case of high-frequency trading, in particular guarding against
technology failures, oversized orders and other situations where
there's potentially systemic market impact, we believe strongly that
pre-trade checks are a prerequisite," Tusar says.
Nasdaq's proposal as well as Securities and Exchange Commission
officials' speeches a few months ago appeared to lean toward
bolstering the traditional approach.
"We don't believe that's strong enough or what the regulators want
now, because of the potentially dire consequences, and because we-as
broker-dealers-bear much of that risk," Tusar says.
Now the reason why this is very relevant in the context of not just
potential front running, but also market structure is that Regulation
SHO, which is the primary regulatory framework for short selling (and
the purvey of potential Uptick Rule reinstatement, which will happen
once the market is allowed to hit a bid) is a post-trade
architecture.
Wedbush [Morgan] routinely tests clients' systems to ensure they are
compliant with Reg SHO. In addition, he says, the brokerage sets
limits on clients available locates-as well as credit and trading
limits--before the start of each trading day that its system tracks,
prohibiting shorts without locates and providing a type of pre-trade
check.
Or as has recently become the case, seeing rolling buy ins in the
middle of the day as borrowable shares in even the most liquid stocks
mysteriously disappear (look at today's market action for yet another
blatant example of this practice).
Anticipating the regulators' likely response, one should not be
surprised to see them siding with Goldman and against shorters:
As the SEC also seeks to appease investor concerns over rampant short
selling, especially naked short selling, new sponsored-access
standards may provide part of the solution. Given that day-traders may
be the last remaining culprits of such activity,, increasing and
standardizing scrutiny over their trading may reduce uncovered (and
illegal) shorts even further.
How about appeasing concerns over rampant, unjustified buying? When
will the downtick buy rule be implemented? But we jest.
And I digress again. Why should all this be concerning to advocates of
stability of high-frequency trading:
The mother of all concerns is a sponsored firm's algorithm going awry
and executing thousands of problematic trades across a range of
securities and market centers.
Well, this is not really a problem when it happens to the upside as
has been the case for months now - it is only a threat when Joe
Sixpack's 401(k) may be impacted, i.e., to the downside.
And here is where a SEC Comment submitted by broker Lime Brokerage is
a very troubling must read by all who naively claim that High-
frequency trading is a boon to an efficient market (which doesn't
provide . Well, yes and no - it is, until such moment that it causes
the market to, literally, break. I will post a critical excerpt from
the Lime submission, and leave the rest to our readers' independent
analysis:
Lime's familiarity with high speed trading allows us to benchmark some
of the fastest computer traders on the planet, and we have seen CDT
(Computerized Day Trading) order placement rates easily exceed 1,000
orders per second. Should a CDT algorithm go awry, where a large
amount of orders are placed erroneously or where the orders should not
have passed order validation, the Sponsor will incur a substantial
timelag in addressing the issue. From the moment the Sponsor�s
representative detects the problem until the time the problematic
orders can be addressed by the Sponsor, at least two mintues will have
passed. The Sponsor�s only tools to control Sponsored Access flow are
to log into the Trading Center�s website (if available), place a phone
call to the Trading Center, or call the Sponsee to disable trading and
cancel these erroneous orders � all sub-optimal processes which
require human intervention. With a two minute delay to cancel these
erroneous orders, 120,000 orders could have gone into the market and
been executed, even though an order validation problem was detected
previously. At 1,000 shares per order and an average price of $20 per
share, $2.4 billion of improper trades could be executed in this short
timeframe. The sheer volume of activity in a concentrated period of
time is extremely disruptive to the process of maintaining a �fair and
orderly� market. This shortcoming needs to be addressed if the
practice of Naked Access is going to be permitted to continue;
otherwise, the next �Long Term Capital� meltdown will happen in a five-
minute time period.
inskrish
01-30 05:23 PM
Voted.