fundo14
04-25 11:02 AM
Just contributed $100 through Paypal.
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nraja
07-11 02:30 PM
Is anyone make PDF about this rally? So, that we can circulate this by mail.
gjoe
01-30 05:05 PM
Let us try to keep the question atleast in the top10 until the poll closes. This is a very good chance to bring our issue to a wide audience.
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pappu
10-27 02:34 PM
Congrats alterego !
You paid 68K for legal and immigration fees... that is steeep man ! I wonder how...
68K is unbelievable. Can you elaborate how.
The pain during the long wait is understandable.
You paid 68K for legal and immigration fees... that is steeep man ! I wonder how...
68K is unbelievable. Can you elaborate how.
The pain during the long wait is understandable.
more...
chanduv23
11-01 07:19 PM
Well reverse brain drain is happening at an entry level where companies are unable to reqruit talented workers straight out from schools.
shishya
06-13 07:51 PM
Anybody got any idea on my situation?
I am an absolute newbie, I unfortunately dont! :(
I am an absolute newbie, I unfortunately dont! :(
more...
gcisadawg
04-09 01:51 PM
We received the RFE for the Td vaccine that was missed somehow by Concentra. But since she is nursing now, we were able to get a blanket Waiver for her.
Sameet,
I know it is a weird question. But I'd still go ahead and ask it.
What documents that USCIS expects for a scenario like this?
My situation: My wife still hasn't weaned off nursing completely.
My child is 1 year 3 months old. My wife got an RFE for TB test.
Plus she is in India currently.
Would sending the birth certificate of child be enough to prove the existence of 1 yr 3 month old child? OR would USCIS requires doctors's input also? OR do they require anything else to prove baby is still being nursed.?
Thansk for your response,
GCisaDawg
Sameet,
I know it is a weird question. But I'd still go ahead and ask it.
What documents that USCIS expects for a scenario like this?
My situation: My wife still hasn't weaned off nursing completely.
My child is 1 year 3 months old. My wife got an RFE for TB test.
Plus she is in India currently.
Would sending the birth certificate of child be enough to prove the existence of 1 yr 3 month old child? OR would USCIS requires doctors's input also? OR do they require anything else to prove baby is still being nursed.?
Thansk for your response,
GCisaDawg
2010 house funny emo quotes
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gcdedo
01-30 09:15 AM
This is good news..But the Damage is already been done..in the past.....
I guess DOL had some 300K cases pending when Backlog center started..It adjudicated some 150K till now.( Rough Estimate) and still 150 K left.
Even if considering 10000 Labors been substituted till now ...Imagine the wait period for rest of us. I wish this law was enacted, when they started Backlog centers..
Anyway..something is better than nothing....Hope for the Best...for new laws regarding SKIL,CIR Etc..atleast filing 485 when Visa numbers are not available..
--gcdedo
I guess DOL had some 300K cases pending when Backlog center started..It adjudicated some 150K till now.( Rough Estimate) and still 150 K left.
Even if considering 10000 Labors been substituted till now ...Imagine the wait period for rest of us. I wish this law was enacted, when they started Backlog centers..
Anyway..something is better than nothing....Hope for the Best...for new laws regarding SKIL,CIR Etc..atleast filing 485 when Visa numbers are not available..
--gcdedo
more...
manjunathrao_sl
07-16 12:22 PM
Signed
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seeking_GC
05-26 05:48 PM
If this is correct then we (all of IV) should support this bill and go all out to get this passed.
more...
DesiGuy
09-17 11:38 AM
she just kicked homeland dept for raising issues last night via FAX while they have been aware since may 8.
seems still for 6020...but Lofgren seem to have strong arguments
seems still for 6020...but Lofgren seem to have strong arguments
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bigboy007
04-27 11:28 PM
For me as i did similar analysis during CIR 2007 the text of the bill looks very much similar. They had the same issues on H1/L1 except now fraud prevention... Not sure where it goes... Any idea Pappu, PPL seem to be still interested in debating H1Vs L1 etc... For sure more offshoring...
Pappu,
I went through the text of the new bill vis-a-vis current INA and compared the old and the proposed act. Here are the findings -
Section 101 - This spells disaster for all H1Bs in consulting companies (as FT or C2C) -
by striking clause (ii) of sub-paragraph (E) of the section 212(n)(1), and then adding the new clauses under (F), they are PROHIBITING placement of H1B employees on another employer's site, period. This will affect NOT ONLY pure staffing (desi or non-desi) companies who place their W-2 H1B employees at client site, BUT ALSO big consulting companies like IBM/ACCENTURE/DELOITTE et al. No placement/leasing/outsourcing/contracting for services or otherwise at another employer, period - UNLESS a waiver is obtained, which will mean every company will need to obtain a waiver in order to do so, EFFECTIVELY ENDING ANY CONSULTING BY H1B.
Section 102 - This spells disaster for all companies who's H1B+L1 > 50% total employees
by inserting two new clauses (H) and (I) in section 212(n)(1), it prohibits H1B only or H1B preferred advertisements and prevents any company that employees more than 50 employees to submit NEW H1B/L1 application IF the total number of H1B and L1 employees exceeds 50% of its total employees. It also requires ANY company employing even a single H1B employee to submit W-2s of IRS. This affects ALL Indian IT companies like TCS/WIPRO/INFOSYS/COGNIZANT et al.
remaining sections (103 onwards) are more about enforcement and investigations.
Section 201 - This spells disaster for companies that bring in workers on L visas
This also affects ALL Indian IT companies like TCS/WIPRO/INFOSYS/COGNIZANT et al. AS WELL AS some other companies that might bring in workers from their home country.
IN SUMMARY -
In the SHORT RUN, this hurts outsourcing industry, as they need more time, and H1B/L1 resources on site to transition the work offshore, but I agree that in the LONG RUN, it will GREATLY BENEFIT AND INCREASE OUTSOURCING.
That will indeed be a sad day. Grassley and Durbin are trying to cut the branch they are sitting on. :) This will have the exact opposite of their desired effect.
Hope this helps.
Pappu,
I went through the text of the new bill vis-a-vis current INA and compared the old and the proposed act. Here are the findings -
Section 101 - This spells disaster for all H1Bs in consulting companies (as FT or C2C) -
by striking clause (ii) of sub-paragraph (E) of the section 212(n)(1), and then adding the new clauses under (F), they are PROHIBITING placement of H1B employees on another employer's site, period. This will affect NOT ONLY pure staffing (desi or non-desi) companies who place their W-2 H1B employees at client site, BUT ALSO big consulting companies like IBM/ACCENTURE/DELOITTE et al. No placement/leasing/outsourcing/contracting for services or otherwise at another employer, period - UNLESS a waiver is obtained, which will mean every company will need to obtain a waiver in order to do so, EFFECTIVELY ENDING ANY CONSULTING BY H1B.
Section 102 - This spells disaster for all companies who's H1B+L1 > 50% total employees
by inserting two new clauses (H) and (I) in section 212(n)(1), it prohibits H1B only or H1B preferred advertisements and prevents any company that employees more than 50 employees to submit NEW H1B/L1 application IF the total number of H1B and L1 employees exceeds 50% of its total employees. It also requires ANY company employing even a single H1B employee to submit W-2s of IRS. This affects ALL Indian IT companies like TCS/WIPRO/INFOSYS/COGNIZANT et al.
remaining sections (103 onwards) are more about enforcement and investigations.
Section 201 - This spells disaster for companies that bring in workers on L visas
This also affects ALL Indian IT companies like TCS/WIPRO/INFOSYS/COGNIZANT et al. AS WELL AS some other companies that might bring in workers from their home country.
IN SUMMARY -
In the SHORT RUN, this hurts outsourcing industry, as they need more time, and H1B/L1 resources on site to transition the work offshore, but I agree that in the LONG RUN, it will GREATLY BENEFIT AND INCREASE OUTSOURCING.
That will indeed be a sad day. Grassley and Durbin are trying to cut the branch they are sitting on. :) This will have the exact opposite of their desired effect.
Hope this helps.
more...
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anirudh74
05-01 05:02 PM
You guys are doing a good job .Keep the faith, I contributed 25$ , presently thats all I could do, all the best.
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eb3_nepa
03-12 10:33 PM
Thanks for the replies everyone.
In response to some responses, i am not "overly concerned" I was just wondering what their status was.
If the older core members who have received their GCs are indeed enjoying the fruits of their hard work, God bless them and there is absolutely nothing wrong with that. My intent was never to start a hot debate. God knows we have tons of drama on the forums daily!! ;). (Soon the April VB will be released and more drama)
In response to some responses, i am not "overly concerned" I was just wondering what their status was.
If the older core members who have received their GCs are indeed enjoying the fruits of their hard work, God bless them and there is absolutely nothing wrong with that. My intent was never to start a hot debate. God knows we have tons of drama on the forums daily!! ;). (Soon the April VB will be released and more drama)
more...
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nycguy30
07-19 08:58 AM
Amanbhai,
Thank you so much, you got the leadeship skill, man go for it......
Thank you so much, you got the leadeship skill, man go for it......
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laborchic
06-05 09:18 PM
Come on folks. This is the time to be active.
Dont give up now....lets try and help ourselves...
Dont give up now....lets try and help ourselves...
more...
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cooldude0807
09-17 11:46 AM
Hope they get to HR 5882 before the lunch break!!!
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kubmilegaGC
09-15 10:54 PM
Recd the CPO E mail today @ 7 PM EDT - 9/15 from TSC
EB2- June 04
Attorney Sent a Letter to AILA liason on 8/20
Called TSC on 8/27/ - Opened a SR
Called TSC again on 9/3 - CSR told me that they sent a reply for the SR opened on 8/27
Recd the SR - reply on 9/4/09 stating that " your Application processing is pending/delayed"
Called Senator office on 9/9/09 and sent fax
Called Senator office on 9/14/09 - Liason officer told me that it will take 30 to 60 days to get the response.
Called other Senator office on 9/14/09 , Sent the fax
Called again to II Senator office on 9/15/09, I was told to call back after 15 days to get the respose
Called TSC again on 9/15/09 around 4.45 PM EDT, Talked CSR , So nice , she eve discussed about the weather , summer time events etc, I told her about the letter I have recd for my SR ( 8/29), she asked if it mentioned any time frame, And i told her "No", then she said it is very unusaul and tranferred my call to the officer,
1st he told me the current processing time is 9/07/07 and my ND is 9/28/07 so my application has a 21 days lag, Then I told him that my application has mailed on 8/7/09, I also mentioned about the letter i received for SR, then he started asking questions about the receipt # and case details
The the officer verified following details
My first name,
Last name,
Address, Zip code, Door #,
fathers first name
mothers first name,
4 Digit SSN
and then told me that your case is under review with an officer from 8/29/08( Then I realized both of us had a Soft LUD on our application on 8/29/08) , I told him about that, the he said yes it is , it is related to the interal process. Then I asked him that What can i do now, He said, Keep your faith and finger crossed asked to me keep on calling USCIS TSC office every week to check about my case.
I really don't know whether he is playing with me or what.
what ever it is I got the CPO e mail @ 7 PM EDT
10 Yr wait is over.
Thank you all, I am not going away, Tristate leadership knows me very well, and I will be involved all the effort of the IV
@natraj - YOU ARE THERE. I remember my afternoon emails and our exchange ...How life can change in few hours :) GREAT NEWS - Congratulations on getting GREEN ...so there is still hope for June 04...:)
Back to counting hours for my ongoing torture...:) USCIS willing!
EB2- June 04
Attorney Sent a Letter to AILA liason on 8/20
Called TSC on 8/27/ - Opened a SR
Called TSC again on 9/3 - CSR told me that they sent a reply for the SR opened on 8/27
Recd the SR - reply on 9/4/09 stating that " your Application processing is pending/delayed"
Called Senator office on 9/9/09 and sent fax
Called Senator office on 9/14/09 - Liason officer told me that it will take 30 to 60 days to get the response.
Called other Senator office on 9/14/09 , Sent the fax
Called again to II Senator office on 9/15/09, I was told to call back after 15 days to get the respose
Called TSC again on 9/15/09 around 4.45 PM EDT, Talked CSR , So nice , she eve discussed about the weather , summer time events etc, I told her about the letter I have recd for my SR ( 8/29), she asked if it mentioned any time frame, And i told her "No", then she said it is very unusaul and tranferred my call to the officer,
1st he told me the current processing time is 9/07/07 and my ND is 9/28/07 so my application has a 21 days lag, Then I told him that my application has mailed on 8/7/09, I also mentioned about the letter i received for SR, then he started asking questions about the receipt # and case details
The the officer verified following details
My first name,
Last name,
Address, Zip code, Door #,
fathers first name
mothers first name,
4 Digit SSN
and then told me that your case is under review with an officer from 8/29/08( Then I realized both of us had a Soft LUD on our application on 8/29/08) , I told him about that, the he said yes it is , it is related to the interal process. Then I asked him that What can i do now, He said, Keep your faith and finger crossed asked to me keep on calling USCIS TSC office every week to check about my case.
I really don't know whether he is playing with me or what.
what ever it is I got the CPO e mail @ 7 PM EDT
10 Yr wait is over.
Thank you all, I am not going away, Tristate leadership knows me very well, and I will be involved all the effort of the IV
@natraj - YOU ARE THERE. I remember my afternoon emails and our exchange ...How life can change in few hours :) GREAT NEWS - Congratulations on getting GREEN ...so there is still hope for June 04...:)
Back to counting hours for my ongoing torture...:) USCIS willing!
hairstyles Tags: funny quotes and sayings
sc3
09-24 12:42 PM
Well, you did not give your easy example, nothing about affirmative action, nothing about representation or overwhelmed by Indian and Chinese thing, and absolutely nothing about preferential treatment. So in-effect, you totally skipped the entire debate, I guess my trick played well, you are now overwhelmed by Frank Caliendo, just as you are overwhelmed by Indian or Chinese.
And while you "hinted" that we are all equals, you did not say - if we are all equals, then why should there be PREFERENTIAL TREATMENT for one group of people over others, unless someone is still practicing APARTHEID. Last time I checked, practicing apartheid is a crime in US and it can land you in jail, not sure if you knew that.
And while you continue to apply for your green card, you are still charging "India" for that because as per you, your country of charge-ability is India, right? If you are actually from India, have you ever heard of Ron Hira. If not, check it out, you will know who he is. You are Ron Hira of country limits, if you know what that means.
Hope you liked the stand-up comedy this time. Oh Frank is just too good. I mean this guy could make you laugh when actually you should be crying, you know what I mean.
Sanju, I did not promise to give you any more examples - easy or otherwise. People have made up their minds, and arguments against the stand devolves into character assassination. While I myself dont care about the dots, and seeing that the discussion started off, at least in part, about unscrupulous distribution of dots, I find it very ironic that I am getting insulting words thrown at me. Either these people cant understand irony, or they really are just learned "angootha-chap", or they are addicted to red-doting people (pretty much bringing the prophecy of the original poster true).
Ron Hira? I dont know much about him, just saw that he wrote a book about outsourcing, am I Ron Hira of per country limits? maybe I am. But, you assumed that I like the per country limits. I hate a lot of things but I live with it. There are lot of things that we hate but are there to help regulate the environment (among others).
The point I am trying to make is that such an action will not be "fair" to people who are in queue (who rely on the 7% cutoff to get their GCs). If the congress makes changes to the rule, then people will have to live with it (fair or otherwise)... by the way, most rules are not made to be fair to everyone. But the thing is such action will have a negative impact on ROW, and it is a pity that many ROW dont realize it. They seem to blindly following IVs call of action. There is some saying about blind faith that escapes me at the moment, but the bottom line is that blind faith is a dangerous thing.
So am I escaping form expounding on my thoughts. Yes, and No. I think I have made succinct argument (based on the laws) as to why things are as such, so I dont see the need to argue further.
And while you "hinted" that we are all equals, you did not say - if we are all equals, then why should there be PREFERENTIAL TREATMENT for one group of people over others, unless someone is still practicing APARTHEID. Last time I checked, practicing apartheid is a crime in US and it can land you in jail, not sure if you knew that.
And while you continue to apply for your green card, you are still charging "India" for that because as per you, your country of charge-ability is India, right? If you are actually from India, have you ever heard of Ron Hira. If not, check it out, you will know who he is. You are Ron Hira of country limits, if you know what that means.
Hope you liked the stand-up comedy this time. Oh Frank is just too good. I mean this guy could make you laugh when actually you should be crying, you know what I mean.
Sanju, I did not promise to give you any more examples - easy or otherwise. People have made up their minds, and arguments against the stand devolves into character assassination. While I myself dont care about the dots, and seeing that the discussion started off, at least in part, about unscrupulous distribution of dots, I find it very ironic that I am getting insulting words thrown at me. Either these people cant understand irony, or they really are just learned "angootha-chap", or they are addicted to red-doting people (pretty much bringing the prophecy of the original poster true).
Ron Hira? I dont know much about him, just saw that he wrote a book about outsourcing, am I Ron Hira of per country limits? maybe I am. But, you assumed that I like the per country limits. I hate a lot of things but I live with it. There are lot of things that we hate but are there to help regulate the environment (among others).
The point I am trying to make is that such an action will not be "fair" to people who are in queue (who rely on the 7% cutoff to get their GCs). If the congress makes changes to the rule, then people will have to live with it (fair or otherwise)... by the way, most rules are not made to be fair to everyone. But the thing is such action will have a negative impact on ROW, and it is a pity that many ROW dont realize it. They seem to blindly following IVs call of action. There is some saying about blind faith that escapes me at the moment, but the bottom line is that blind faith is a dangerous thing.
So am I escaping form expounding on my thoughts. Yes, and No. I think I have made succinct argument (based on the laws) as to why things are as such, so I dont see the need to argue further.
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.
logiclife
02-01 01:04 PM
I'm not working in the IT industry and this is the first time I have some idea about what the desi companies are doing in US. Yes, I think these desi companies and people who conducted those fraudulent behaviors are partly responsible for our situation here. I believe most H1B holders are decent people while some like those mentioned in the article are nuts. Bad purges good. Now all H1b holders have to pay the price.
Besides, I think those who conducted these fraudulent behavior do not deserve to be called "high-skilled workers".
H1B problems have nothing to do with retrogression.
If H1B employees are being mistreated by a certain class of employers, then what does that have to do with shortage of visa numbers?
Nothing.
Misuse and abuse of H1B program did not cause retrogression. And if the abuse ends, its not going to end retrogression. The H1B program does provide ammunition to anti-immigrants to use that paint-brush and paint the entire program of H1B and Employment based GC as bad. Fortune 500 companies dont engage in unethical behavior. The TCS, Wipro etc maybe do that. Small bodyshops certainly do that. I am yet to see a small body-shop, operated by a citizen of foriegn origin, working by the book and treating employees well.
But all said and done, these things make our life more difficult and exacerbate the situation that arose from retrogression. However, these things didnt cause retrogression.
At the most, these issues of H1B abuse may have provided support to some groups in keeping the H1B quota down. However, it has nothing to do with EB quota. In fact, IEEE-USA advocates bringing down H1B quota and RAISING the employment based GC quota, in order to remove factors that encourage employer abuse.
Besides, I think those who conducted these fraudulent behavior do not deserve to be called "high-skilled workers".
H1B problems have nothing to do with retrogression.
If H1B employees are being mistreated by a certain class of employers, then what does that have to do with shortage of visa numbers?
Nothing.
Misuse and abuse of H1B program did not cause retrogression. And if the abuse ends, its not going to end retrogression. The H1B program does provide ammunition to anti-immigrants to use that paint-brush and paint the entire program of H1B and Employment based GC as bad. Fortune 500 companies dont engage in unethical behavior. The TCS, Wipro etc maybe do that. Small bodyshops certainly do that. I am yet to see a small body-shop, operated by a citizen of foriegn origin, working by the book and treating employees well.
But all said and done, these things make our life more difficult and exacerbate the situation that arose from retrogression. However, these things didnt cause retrogression.
At the most, these issues of H1B abuse may have provided support to some groups in keeping the H1B quota down. However, it has nothing to do with EB quota. In fact, IEEE-USA advocates bringing down H1B quota and RAISING the employment based GC quota, in order to remove factors that encourage employer abuse.
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