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A Disruptive Environment: Sidley Austin’s Lisa Dunsky Offers Practical Compliance Tips for Firms and Traders

In May 2013, the Commodity Futures Trading Commission finalized its interpretive guidance on disruptive trading practices, as mandated by the Dodd-Frank Act, which defined disruptive trading as any trading activity that: violates bids or offers; demonstrates intentional or reckless disregard for orderly execution; or is of the character of, or is commonly known to the trade as, “spoofing” (bidding or offering with the intent to cancel the bid or offer before execution). In August 2014, … 

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