ilikekilo
04-02 11:43 PM
your profile says that your application is pending with NSC? I was asking about TSC. Please clarify. Anyone else??
My bad , mine is from NSC...I just chose your post to quote..sorry for hte mix up..
My bad , mine is from NSC...I just chose your post to quote..sorry for hte mix up..
wallpaper Dakota Fanning is beyond
MetteBB
06-08 09:12 AM
well... since my entry is in there is really no need to wait till the 30th. It will surely win ;) :lol:
On a more serious note... there havent been alot of entries lately. Perhaps give ppl one more week and then end it?
/mette
On a more serious note... there havent been alot of entries lately. Perhaps give ppl one more week and then end it?
/mette
PresidentO
05-14 09:03 PM
Should I say that all of you those who bought homes and are having a life bought a home with 0% down and interest only loan so that you can save your taxes now and if your GC does not come through in 5 years, you will walk out with out any loss as you made hefty deductions and haven't paid single penny towards the mortgage and simply go to Timbuktu or Krakovia. I will not!.
Thanks for calling me a hypocrite with out reading the whole answer. I was just giving a hypothetical example on how one can talk about others life and practices in life sitting before a computer. Thanks for your clarification on whom you considered XYZ because lack of GC has stopped them from buying a home. I will respectfully disagree with your opinion that GC is not a non stopper for every one and there is a significant contingent out there who dont want to buy a home without a GC and consider it risk. Opinions differ and yours is taken. Again, You in the above hypothetical example does not refer to any one in person.
Thanks for calling me a hypocrite with out reading the whole answer. I was just giving a hypothetical example on how one can talk about others life and practices in life sitting before a computer. Thanks for your clarification on whom you considered XYZ because lack of GC has stopped them from buying a home. I will respectfully disagree with your opinion that GC is not a non stopper for every one and there is a significant contingent out there who dont want to buy a home without a GC and consider it risk. Opinions differ and yours is taken. Again, You in the above hypothetical example does not refer to any one in person.
2011 Dakota Fanning
texanguy
06-12 05:09 PM
in year 2007 EB-3 india got 17,000 green cards, still not enough to take care of the high demand. there are just too many people waiting, that's the fact and nobody can do anything about it...except for supporting IV for these three bills...
more...
rajesh_kamisetty
11-02 01:27 PM
I am certainly not the type to participate in rallies. But I like your thinking and your stand on your points, which I think are not as well expressed as you possibly could.
The only way US Govt is going to worry about solving our problem is if they find it a problem for themselves. And they will find it a problem only when people like you and me start leaving USA in hoards!!
For NOW, the only reason I have applied GC is for EAD for my wife. She is on H1 but doesn't like to work in IT field anymore. Without EAD it's difficult for her to pursue other full-time/part-time careers like fashion designer/teacher etc.,
I have come across at least one-colleague in every client place who left U.S.A - after being here for more than 7 years. And they do have children, houses and handsome salaries. And I know of number of people who have plans to eventually go back. But it's just matter of time and money. If property prices were not crazy in India, I am sure more people would have left by now.
As far as competition with young and talented Indians - I think we are good enough to come this far and should be good enough to compete when we go back :D
The day will come when I will proudly say bye-bye to America and go back to Hyderabad or Bangalore and be happy with better family-life and okay-material life. And guess what, I get to work around the world not just U.S.A.
All those who are questioning my profile details please check the public profile of mine. It has more info than most of you (Mr.internet) have in your own. To those who are calling to close this thread - Already someone modified the poll and added two new options, I won't be surprised if it is closed. If it is it will only show how fake some of you are when you talk about a few reasons ( not all) why GC backlogged should be solved fast.
Someone wanted the moderators to ban me. Tell me why I should be banned? Do you say you just want everyone to only listen to what you say and what you want them to do? You can't tolerate others' opinions and thoughts?
I am here in this country on H1B since 2000. I am also one of you waiting in this endless queue for my GC. I am also like one of you trying to get my GC fast. But I don't like to lie or twist facts for my convenience.
Thought for the day "Walk a mile in the shoes of an American before you ask them to beleive what you say"
The only way US Govt is going to worry about solving our problem is if they find it a problem for themselves. And they will find it a problem only when people like you and me start leaving USA in hoards!!
For NOW, the only reason I have applied GC is for EAD for my wife. She is on H1 but doesn't like to work in IT field anymore. Without EAD it's difficult for her to pursue other full-time/part-time careers like fashion designer/teacher etc.,
I have come across at least one-colleague in every client place who left U.S.A - after being here for more than 7 years. And they do have children, houses and handsome salaries. And I know of number of people who have plans to eventually go back. But it's just matter of time and money. If property prices were not crazy in India, I am sure more people would have left by now.
As far as competition with young and talented Indians - I think we are good enough to come this far and should be good enough to compete when we go back :D
The day will come when I will proudly say bye-bye to America and go back to Hyderabad or Bangalore and be happy with better family-life and okay-material life. And guess what, I get to work around the world not just U.S.A.
All those who are questioning my profile details please check the public profile of mine. It has more info than most of you (Mr.internet) have in your own. To those who are calling to close this thread - Already someone modified the poll and added two new options, I won't be surprised if it is closed. If it is it will only show how fake some of you are when you talk about a few reasons ( not all) why GC backlogged should be solved fast.
Someone wanted the moderators to ban me. Tell me why I should be banned? Do you say you just want everyone to only listen to what you say and what you want them to do? You can't tolerate others' opinions and thoughts?
I am here in this country on H1B since 2000. I am also one of you waiting in this endless queue for my GC. I am also like one of you trying to get my GC fast. But I don't like to lie or twist facts for my convenience.
Thought for the day "Walk a mile in the shoes of an American before you ask them to beleive what you say"
jasonalbany
04-29 09:45 PM
Hi,
I just did my second contribution. Hopefully, we can meet the goal by May 1st. Good job!!!
I just did my second contribution. Hopefully, we can meet the goal by May 1st. Good job!!!
more...
logiclife
12-29 11:52 AM
Those who want to practice freedom of speech are free to leave this website and organization and join someone else or start their own website or forum.
If you dont like the moderation or banning or censorship policy, please leave and dont even bother threatening us that you are leaving.
What's the worst that could happen?
Everyone will leave? This organization will be shut down?
Well if that's the case, then so be it.
But we are not going to be spending 5 hours a day reasoning with hecklers and keep deleting and moderating posts that are racist, insulting to certain groups or damaging this organization. I would rather save my time by banning such people completely instead of reasoning with them for the sake of "Freedom of Speech".
As an admin and moderator, if its in the interest of this organization to moderate posts, then it will be a priority over the practice of "Freedom of Speech" or "First amendment rights".
And one more thing: The first amendment protects freedom of speech and expression for the individual AGAINST the GOVERNMENT. Not non-government entities. It says that the Government cannot take away that right from you and congress cannot pass such laws to ban freedom of speech. It applies to public and government domain. Not anywhere else. Immigration Voice is not a Government body. Before preaching constitutional law to everyone and engaging in "Freedom of Speech" grandstanding, please do a little research of how the first amendment works and where it applies.
If you dont like the moderation or banning or censorship policy, please leave and dont even bother threatening us that you are leaving.
What's the worst that could happen?
Everyone will leave? This organization will be shut down?
Well if that's the case, then so be it.
But we are not going to be spending 5 hours a day reasoning with hecklers and keep deleting and moderating posts that are racist, insulting to certain groups or damaging this organization. I would rather save my time by banning such people completely instead of reasoning with them for the sake of "Freedom of Speech".
As an admin and moderator, if its in the interest of this organization to moderate posts, then it will be a priority over the practice of "Freedom of Speech" or "First amendment rights".
And one more thing: The first amendment protects freedom of speech and expression for the individual AGAINST the GOVERNMENT. Not non-government entities. It says that the Government cannot take away that right from you and congress cannot pass such laws to ban freedom of speech. It applies to public and government domain. Not anywhere else. Immigration Voice is not a Government body. Before preaching constitutional law to everyone and engaging in "Freedom of Speech" grandstanding, please do a little research of how the first amendment works and where it applies.
2010 And for good measure,
webm
06-12 01:50 PM
Yes I do agree with you. This is a most affected category these days and even look at the past few yrs data, very slow movement.
-----------------
EB3-India filer
-----------------
EB3-India filer
more...
Leo07
12-03 12:54 PM
I know you are a comitted member...you might even stick to the forum for long.
"How do you know what I care about and not?"...I don't. That was an example to drive the point in general 99% of the flock leave the forum as soon as soon as they get the GC. That 25000 members might also..include them.(I'm gradually digressing from my own post:))
How do you suggest IV 'forum' improves the Signal-to-Noise ratio?
Right now it's too noisy and is driving away determined members (http://immigrationvoice.org/forum/showthread.php?p=199027#post199027)!
How do you know what I care about and not? I can give some famous examples of GC holders working for IV - Aman Kapoor founder member, Tamsen Mitchell (franklin) leader of South California chapter, and many more.
I may remain active if I feel the cause is worth spending my time, money and effort. Right now, a crowd of 25,000 tracking receipts and discussing mundane issues doesn't give me the confidence to say so. I have better things in life to fight for than a lost cause where the victims (most of them) wait for others to fight for them !
"How do you know what I care about and not?"...I don't. That was an example to drive the point in general 99% of the flock leave the forum as soon as soon as they get the GC. That 25000 members might also..include them.(I'm gradually digressing from my own post:))
How do you suggest IV 'forum' improves the Signal-to-Noise ratio?
Right now it's too noisy and is driving away determined members (http://immigrationvoice.org/forum/showthread.php?p=199027#post199027)!
How do you know what I care about and not? I can give some famous examples of GC holders working for IV - Aman Kapoor founder member, Tamsen Mitchell (franklin) leader of South California chapter, and many more.
I may remain active if I feel the cause is worth spending my time, money and effort. Right now, a crowd of 25,000 tracking receipts and discussing mundane issues doesn't give me the confidence to say so. I have better things in life to fight for than a lost cause where the victims (most of them) wait for others to fight for them !
hair new moon star Black shirt,
bugsbunny
04-17 08:16 PM
The fact that he's asking whether he qualifies for one, on an online forum,shows his level of skill and education. Enough said :)
wow! you can't even ask your peers for honest feedback without being judged. :(
wow! you can't even ask your peers for honest feedback without being judged. :(
more...
logiclife
06-07 11:31 AM
I dont work for consultant and yet I relocated last year. I admit its less frequent when you work directly for a company. I work longer hours not because I am told to, but it makes me feel more secure in my job by doing so and by making myself more useful than neccesary. WHy? coz I cannot change employer and keep my greencard process intact and continual. Its has to be started from scratch. Not affordable. Hence the longer hours. Is it forced? No. Is it fair. Absolutely not.
Finding a local to marry is not an option. Why? Firstly, many of us are already married. Secondly and more importantly, if you marry a local with the intention of obtaining immigration benefits, you are breaking the law. I dont mean to say that marrying a local is wrong, but it is illegal if you are doing it only for immigration benefits resulting from marrying a citizen and you could lose that greencard if things go haywire. To quote Shushterman, an immigration lawyer and former USCIS employee: If you are caught doing something illegal by USCIS, you are better off robbing a liquor store than marrying a local with intention of greencard. USCIS may pardon you if you robbed a liquor store, and still give your greencard but not if you married a citizen with intention of immigration benefits.
Now, coming to rights and privileges, privileges wouldnt exist unless you had the rights. Privileges granted by Government to public are based on rights. There are some things that the seeker calls rights and the person who grants them calls them privileges. If you want to be forceful, you have to call it a right, not a privileges. We call "Human rights" rights for a reason and not "Human privileges". See, privileges imply a hand-out. Rights imply justice. There is a difference between hand-out and justice.
Finding a local to marry is not an option. Why? Firstly, many of us are already married. Secondly and more importantly, if you marry a local with the intention of obtaining immigration benefits, you are breaking the law. I dont mean to say that marrying a local is wrong, but it is illegal if you are doing it only for immigration benefits resulting from marrying a citizen and you could lose that greencard if things go haywire. To quote Shushterman, an immigration lawyer and former USCIS employee: If you are caught doing something illegal by USCIS, you are better off robbing a liquor store than marrying a local with intention of greencard. USCIS may pardon you if you robbed a liquor store, and still give your greencard but not if you married a citizen with intention of immigration benefits.
Now, coming to rights and privileges, privileges wouldnt exist unless you had the rights. Privileges granted by Government to public are based on rights. There are some things that the seeker calls rights and the person who grants them calls them privileges. If you want to be forceful, you have to call it a right, not a privileges. We call "Human rights" rights for a reason and not "Human privileges". See, privileges imply a hand-out. Rights imply justice. There is a difference between hand-out and justice.
hot Dakota Fanning at the New
gaz
09-17 02:22 PM
Seems like Zoe is loosing patience. She is starting to accept a lot of amendments and is some how trying get it wrapped up.
an amendment to respect religious freedom by King
and agreed to
Be happy Mr King..please be nice to Zoe and us now
an amendment to respect religious freedom by King
and agreed to
Be happy Mr King..please be nice to Zoe and us now
more...
house Dakota Fanning At Twilight New Moon Premiere Video Pictures
WillIBLucky
11-16 02:24 PM
Check out -
http://weblog.infoworld.com/techwatch/archives/008912.html
http://weblog.infoworld.com/techwatch/archives/008912.html
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rtarar
07-18 01:03 PM
Pd: Aug 2004
Reached Nsc: 7/2 7:55 am
Rejected: Don Know
Ck Cashed: Not Yet
Reached Nsc: 7/2 7:55 am
Rejected: Don Know
Ck Cashed: Not Yet
more...
pictures Dakota Fanning
nik.patelc
04-08 03:59 PM
Nik,
Did it say anything on your online account about RFE when you received the email, or you just got the email i.e. when you click on the receipt number it shows status of the case which usually shows a generic message that the case was received and is pending, so did that message change?
If not, then did anybody else who got the RFE had that message changed?
Thanks
Yes status has been changed to : Current Status: Request for Additional Evidence Sent.
There is no information about RFE.
Did it say anything on your online account about RFE when you received the email, or you just got the email i.e. when you click on the receipt number it shows status of the case which usually shows a generic message that the case was received and is pending, so did that message change?
If not, then did anybody else who got the RFE had that message changed?
Thanks
Yes status has been changed to : Current Status: Request for Additional Evidence Sent.
There is no information about RFE.
dresses Dakota Fanning looked all
NNReddy
04-18 07:04 PM
I am happy about OP's Green card. I want to get some answers for some questions, been in this country for 16 years, wan't to get my Green card man(june 2003)
more...
makeup Dakota Fanning stole her
GotGC??
01-30 01:16 PM
I remember the interim rule saying that:
- the process of labor substitution itself will be eliminated
- I-140 applications based on approved LCs (now, only in your name only) need to be applied within 45-days of LC's approval.
Does someone have the (official) link to this news that DOL has submitted this rule to OMB.
No, 45 days condition is not for "to file 140 within 45 days of labor approval"
But it is for the company to substitute the LC for some other employee within 45 days.
There is no time limit set to file I-140 for the employee for whom the LC was issued.
- the process of labor substitution itself will be eliminated
- I-140 applications based on approved LCs (now, only in your name only) need to be applied within 45-days of LC's approval.
Does someone have the (official) link to this news that DOL has submitted this rule to OMB.
No, 45 days condition is not for "to file 140 within 45 days of labor approval"
But it is for the company to substitute the LC for some other employee within 45 days.
There is no time limit set to file I-140 for the employee for whom the LC was issued.
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karthiknv143
02-07 06:11 PM
:confused: 02/07/2007: Details of DOL Backlog Cases Processing Statistics
(http://www.immigration-law.com)
Yesterday, we reported that the Backlog Elimination Centers had completed 67% of cases as of 01/27/2007. According to the "unconfirmed sources", the details appear to be as follows:
Total Number of Cases: over 300,000
Processing status by the Two Backlog Elimination Centers:
Total 100% Dallas (152,000+) Phily (169,000+)
Pending 33% 33% 36%
Completed 67% (1) Certified 33% 33%
" (2) Closed 21% 20%
" (3) Withdrawn 11% 08%
" (4) Denied 01% 02%
The good news is that there were very small number of denials. Bad news is a large number cases did not make it through becuase they were either withdrawn or closed. There are a very small fraction of cases which are not reflected in the table.
(http://www.immigration-law.com)
Yesterday, we reported that the Backlog Elimination Centers had completed 67% of cases as of 01/27/2007. According to the "unconfirmed sources", the details appear to be as follows:
Total Number of Cases: over 300,000
Processing status by the Two Backlog Elimination Centers:
Total 100% Dallas (152,000+) Phily (169,000+)
Pending 33% 33% 36%
Completed 67% (1) Certified 33% 33%
" (2) Closed 21% 20%
" (3) Withdrawn 11% 08%
" (4) Denied 01% 02%
The good news is that there were very small number of denials. Bad news is a large number cases did not make it through becuase they were either withdrawn or closed. There are a very small fraction of cases which are not reflected in the table.
hairstyles Dakota Fanning scares me.
leoindiano
06-02 02:07 PM
Go to their website and look for consitutent services. Utilize their services ONLY if your's is a genuine problem and follow their instructions - write clearly what your problem is and what kind of help you are expecting. Spome of them are very helpful - they stay on top of the case till they get you a written decision
Nevermind, i found you worked in these 6 weeks and result of MTR is retroactive.
Nevermind, i found you worked in these 6 weeks and result of MTR is retroactive.
Vysh
01-05 04:27 PM
Hi, My husband and I both sent an email at change.gov
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.