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Comment Letters

February 11, 2014: FIF CAT WG: Preliminary Large Trader Rule (Rule 13h-1) - CAT (Rule 613) Gap Analysis

Posted Feb 12, 2014

January 15, 2014: Large Trader Options Calculations Discussion

Posted Jan 16, 2014

August 29, 2013: FIF Large Trader FAQs Request

Posted Aug 29, 2013

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FIF Feb 28 Large Trader Reporting Event - Panelist Bios

James A Brigagliano is a partner in the Securities and Futures Regulatory Practice of Sidley Austin LLP. He advises a wide array of financial services firms including investment and commercial banks, broker-dealers and hedge funds – on a broad variety of regulatory, enforcement, compliance, and transactional matters. Mr. Brigagliano focuses his practice in particular on SEC and SRO rules governing trading by broker-dealers and hedge funds, broker-dealer registration and conduct rules, and recent Dodd-Frank initiatives.

Prior to joining Sidley, Mr. Brigagliano served as the Deputy Director of the Division of Trading and Markets at the Securities and Exchange Commission, where he held senior policymaking and management responsibilities. He had oversight over the regulation of broker-dealers, securities markets and trading practices and advised on enforcement matters. Mr. Brigagliano also served as Co-Acting Director of the Division. Before joining Trading and Markets, Mr. Brigagliano was Assistant General Counsel for Litigation at the SEC.

Mr. Brigagliano was honored with numerous awards during his tenure at the SEC. He has been a frequent speaker at seminars and conferences attended by in-house lawyers and business people each year.

Mr. Brigagliano obtained his law degree from Georgetown University and his undergraduate degree from Amherst College.

David Emero is a Vice President at Goldman Sachs, and is a manager in the Americas Regulatory and Tax Operations Group. David’s group focuses on regulatory reporting and monitoring of securities orders, trades, transactions and positions under US securities regulations. David graduated from the Massachusetts Institute of Technology in 1990, with a Bachelor's Degree in Materials Engineering, and Fordham University in 1997 with a Master’s of Business Administration, and served as a US Navy Officer from 1990 to 1997. He also worked as a technology manager at JP Morgan from 1997-2003 in the Futures and Options Technology Infrastructure and Electronic Trading Application Development teams. He joined Goldman Sachs in 2004.

Gary Grey is a Director, Business Solutions Group at FINRA.  Gary is currently heading up the Intermarket Surveillance Group (ISG) Electronic Blue Sheet Sub Group, and was previously the Chairman and Deputy Chairman of the Intermarket Surveillance Group Technology Sub Group.  He also worked on the Large Options Position Report migration from SIAC to OCC.  Gary has 29 years of Wall Street experience serving in various positions in Market Surveillance at the American Stock Exchange in Options and Derivatives Surveillance and Regulation Technology at NASD and FINRA.  Gary has a BS from Cook College Rutgers University.

Richard Holley III
serves as an Assistant Director at the U.S. Securities and Exchange Commission in the Division of Trading & Markets’ Office of Market Supervision, where he focuses on national securities exchanges. Prior to the Commission, Mr. Holley was an associate attorney in the Financial Services Group at Dechert LLP, where he focused on investment company regulation. Prior to that, Mr. Holley
was a Senior Project Executive at a market research agency in Prague, Czech Republic. Mr. Holley graduated magna cum laude from Bates College and received his J.D., with honors, from the University of North Carolina Chapel Hill School of Law.

Thomas J. Jordan
is President and CEO of Jordan & Jordan and is also the Advisory Committee Chair of the Financial Information Forum. FIF Program Office support is provided by Jordan & Jordan, which provides business, regulatory and technology solutions to the securities industry. Previously Mr. Jordan was the Managing Director of Knight-Ridder Financial/Americas and Chairman of Monchik-Weber, a consulting and product development firm. Mr. Jordan also held various management positions at IBM both on the technical and the marketing side of the business. Tom holds a BS degree in Mathematics from Saint Peter's College and a MS in Industrial Administration from Union College.

Manisha Kimmel is the Executive Director of the Financial Information Forum (FIF). She leads the Financial Information Forum, working with FIF member firms to drive industry issues to successful resolution. She moderates FIF's Large Trader Working Group which is actively working with the SEC to resolve open issues and address member concerns.  Prior to this role, Manisha worked on numerous engagements assisting firms in strategic and technology decisions in her capacity as Senior Industry Consultant for Jordan & Jordan. She also held positions at ADP in their Strategic Investments group within their brokerage division. In addition to completing coursework at Stanford University’s Learning, Design and Technology program, Manisha has a BS in Finance and Information Systems from the Wharton School and a BS in Systems Engineering with a focus in Telecommunications from the University of Pennsylvania.

Howard Meyerson is General Counsel and Chief Compliance Officer at Liquidnet. Howard has served as Liquidnet’s General Counsel since July 2000. Prior to joining Liquidnet, Howard worked in the broker-dealer practice group at the law firm of Morgan, Lewis & Bockius LLP, where he represented broker-dealers, alternative trading systems, derivatives dealers and other companies in the financial services industry on a variety of transactional, regulatory and compliance matters.

Howard received his B.A. from Columbia College, his J.D. from Harvard Law School, and is a graduate of Columbia University's Computer and Technology Applications Program with a Certificate in Analysis and Design of Information Systems.

Howard is a member of the SIFMA Technology and Regulation Committee. He has previously served as a member of the FINRA E-brokerage Committee.

Deborah Mittelman is the Global Head of Product Management for the Direct Execution business at UBS Investment Bank. Direct Execution is the firm’s electronic trading business for institutional equities, which offers clients algorithmic trading, direct market access, low-latency trading, the UBS Pinpoint execution management system, and the UBS Fusion web-based analytics platform.

Deborah is responsible for the strategy and implementation of the Direct Execution trading products including Client Connectivity, UBS Pinpoint, UBS Fusion, and Market Connectivity. Her career spans more than 25 years in the securities industry and over that time, she has held various positions in business development, compliance and technology.

Prior to joining UBS, Deborah was the Director of Products for US Equities at Lime Brokerage, where she managed products specializing in automated and high-volume electronic trading strategies. Earlier, she held senior product management and technology roles at RealTick, SunGard, Instinet and Goldman Sachs.

She holds a B.S.E. from Wharton and an MBA from Columbia University. Deborah is a frequent guest speaker at industry conferences and events and has served on several industry committees, such as the SIA Trading Committee, and various other working groups.

Walter Roesch is the Director and head of US Clearing Services. He oversees all domestic trade clearance of US Equities, Fixed Income and Options. In addition, Walter has responsibility for the Floor Support on the Chicago Board of Options Exchange (CBOE) and the support group for Broadcort Execution Services.

Walter has 33 years of Wall Street experience with a background that includes all aspects of Securities Operations, encompassing equity, corporate and municipal bonds, options, money market instruments, medium term notes and government securities.

Walter began his Wall Street career in 1978 at Loeb Rhodes in the operations area and moved on to Drexel Burnham Lambert operations in 1979.  Walter held a number of supervisory positions before becoming Vice President of the Settlement support area.

In 1990 Walter took a similar position with Herzog Heine Geduld which merged with Merrill Lynch in 2000. Six years later Walter was appointed Director of Clearing Services in the Americas Transaction Services group.
Walter is currently a member of the Data Management & Securities Operations divisions of the SIA. He is also a member of the Options Clearing Corp Roundtable and a member of the Fixed Income Clearing Corporations’ Real Time Trade Matching Working Group. He is a past president of the Cashiers Association of Wall Street and a former member of the NASD Uniform Practice subcommittee.

David Shillman is an Associate Director in the SEC’s Division of Trading and Markets, where he is responsible for oversight of the U.S. equity and debt markets. Prior to that time, he served in a variety of positions in the Division, including Counsel to the Director and International Counsel. Mr. Shillman was in private practice in New York and Washington, D.C. before joining the SEC in 1995. He is a graduate of Northwestern University and the University Of Michigan Law School.

Ronald Veith, CFA, is a Vice President, Equities Supervision at Barclays Capital. Prior to moving to Barclays, Ron ran the Options Trading Analysis and Equity Surveillance Groups at the International Securities Exchange. As a member of the Intermarket Surveillance Group, Ron led the ISG Bluesheet Sub Group and was instrumental in the rewrite of the Large Options Position Report. Ron has a BA from Florida Atlantic University and an MA from Pace University.

Large Trader Reporting WG

Financial Information Forum
Large Trade Reporting (Rule 13H1) at a Glance
(Excerpted from Approved Filing)
  • Commission is adopting new Rule 13h‐1 and Form 13H under Section 13(h) to assist in both identifying, and obtaining trading information on, market participants that conduct a substantial amount of trading activity, as measured by volume or market value, in the U.S. securities markets.
  • Rule 13h‐1 will require a “large trader,” defined as a person whose transactions in NMS securities equal or exceed 2 million shares or $20 million during any calendar day, or 20 million shares or $200 million during any calendar month, to identify itself to the Commission and make certain disclosures to the Commission on Form 13H. Form 13H will be filed via Edgar.
  • Upon receipt of Form 13H, the Commission will assign to each large trader an identification number that will uniquely and uniformly identify the trader, which the large trader must then provide to its registered broker‐dealers.
  • Registered broker‐dealers will then be required to maintain records of two additional data elements in connection with transactions effected through accounts of such large traders (the large trader identification number, and the time transactions in the account are executed.
  • Broker‐dealers will need to report large trader transaction information to the Commission upon request through the Electronic Blue Sheets systems currently used by broker‐dealers for reporting trade information.
  • Registered broker‐dealers subject to the Rule will be required to perform limited monitoring of their customers’ accounts for activity that may trigger the large trader identification requirements of Rule 13h‐1. These BDs will require policies and procedures reasonably designed to inform persons of their obligations to file Form 13H and disclose their large trader status.

Key Dates:

  • July 27, 2011: Large Trader Reporting Approved
  • Aug 3, 2011: Large Trader Reporting approved filing published in the Federal Register.
  • October 3, 2011: Effective Date of Rule.
  • December 1, 2011: Compliance Date for the requirement on large traders to identify to the Commission pursuant to Rule 13h‐1(b).
  • April 30, 2012: Compliance Date for broker‐dealers to maintain records, report, and monitor large trader activity pursuant to Rule 13h‐1(d), (e), and (f).
  • Aug 31, 2012: Effective date for ISG enhancements to Electronic Blue Sheets (EBS) submissions.

Relevant Links:


For information on work of the Large Trader Working Group of the FIF Front Office Committee and the FIF Large Trader Reporting Portal, please contact Manisha Kimmel, Executive Director of the Financial Information Forum, at or +1 312 953 9228. FIF Members: Access the FIF Large Trader Implementation Tracking Document here.

Large Trader Reporting Relevant Links