Joint CFTC-SEC Advisory Committee on Emerging Regulatory Issues

1 
 
Statement of Kevin Cronin 
Global Head of Equity Trading, Invesco Ltd. 
Joint CFTC-SEC Advisory Committee on Emerging Regulatory Issues 
August 11, 2010 
 
 
Thank you, Chairman Schapiro, Chairman Gensler and members of the Advisory 
Committee for the opportunity to speak here today.  I am pleased to participate on behalf of 
Invesco at this meeting examining investors’ perspectives of the May 6, 2010 market events.  
Invesco is a leading independent global asset management firm with operations in 20 countries 
and assets under management of approximately $560 billion.   
 
An efficient and effective trading environment is crucial to our funds’ shareholders and to 
investors at large.  We therefore commend the Advisory Committee for its examination of the 
current structure of the U.S. equity markets, particularly the market events of May 6, and its 
continued interest in addressing issues that may impact investor confidence in these markets. 
 
The large and sudden price dislocations experienced on May 6 were, in large measure, 
the result of flaws and inefficiencies in the current U.S. market structure.  Specifically, the May 6 
“flash crash” highlighted the need for: (1) updated market-wide and stock-by-stock circuit 
breakers; (2) effective and transparent procedures for resolving clearly erroneous trades; (3) an 
examination of the use and consequences of market orders; (4) an examination of the 
inconsistent practices used by the exchanges to address major price movements in stocks; (5) an 
assessment of the responsibilities and obligations of registered and unregistered “modern day” 
market makers; and (6) better coordination across all types of markets.  
 
Several of these issues have already been addressed by regulators, including the need for 
stock-by-stock circuit breakers and better procedures for resolving clearly erroneous trades.  In 
addition, discussions are ongoing among regulators and market participants regarding the 
inconsistent practices of exchanges when dealing with major price movements in stocks.  The 
use of market orders and the current responsibilities of market makers are also being investigated 
by regulators and market participants.  Invesco supports all of these efforts.   
 
While the changes to the structure of the securities markets already underway in response 
to the events of May 6 should resolve some of the issues that contributed to the severe price 
declines on that day, it is critical that these changes not be viewed in a vacuum and instead be 
considered as one of several steps necessary to address the current inefficiencies in the markets.  
In its examination of the market events on May 6, the Advisory Committee should not lose sight 
of the broader market structure issues raised by the SEC’s concept release examining the 
structure of the U.S. equity markets, including the adequacy of information provided to investors 
about their orders, the impact of high frequency trading, and undisplayed liquidity.  These issues 
are equally critical to investors’ ability to trade efficiently under the current market structure.   
 

2 
 
Establishing Mechanisms to Address Extreme Price Moves 
 
Removing all instability and volatility from the equity markets is neither possible nor 
appropriate.  However, establishing mechanisms to address extreme price moves in the markets 
and volatility related to inefficient market structure will be critical in preventing a repeat of the 
May 6 market event.  While the SEC and SROs, through the single stock circuit breaker rules 
and clearly erroneous rules, have begun to take steps to address extreme stock price moves and 
uncertainty regarding the breaking of trades due to those price moves, there are other steps that 
need to be considered to address future extreme moves in stock prices. 
 
Circuit Breaker Rules and Clearly Erroneous Rules
 
 
Invesco supported the single stock circuit breaker proposals as a means to mitigate the 
impact of sudden market volatility by implementing a trading pause for individual securities in 
times of market stress.  Similarly, we strongly supported amendments to the rules relating to 
clearly erroneous executions to clarify the process for breaking erroneous trades and to provide 
uniform treatment across the exchanges for clearly erroneous execution reviews.  However, we 
believe the whole notion of taking trades off the tape is generally detrimental to investor 
confidence.  We would propose that the exchanges clearly define and articulate the parameters 
that constitute erroneous trades and then program their systems to detect and reject trades outside 
of those parameters.  We believe uncertainty surrounding the clearly erroneous rules and the 
risks associated with entering orders during the drop in stock prices likely contributed to the 
rapid and dramatic May 6 market decline.  Ensuring that only good trades are reported to the tape 
would provide investors and liquidity providers an increased level of confidence regarding the 
trading data they need to participate in good and bad markets. 
 
Use of Market Orders
 
 
As was clearly illustrated by the events of May 6 when there is a vacuum of liquidity, 
smaller market orders can have an outsized impact on the prices of securities.  Market orders are 
orders which seek to be immediately executed at the best available price.  On May 6, a vacuum 
of liquidity was created when a massive wave of sell orders hit the markets triggering liquidity 
replenishment points (LRP’s) on the NYSE.  These LRPs or speed bumps resulted in the NYSE 
going into “slow mode.”  Subsequently, NASDAQ and the other exchanges declared “self-help” 
against NYSE Arca.  Self-help is a provision under Regulation NMS which allows one exchange 
to ignore the quotes of another exchange which is experiencing system problems.  In this case 
the declaration of self-help allowed the other exchanges to essentially ignore the quotes on 
NYSE Arca.  Thus as the various exchanges were determining where to route their orders to 
fulfill their Regulation NMS obligations they could do so without consideration to NYSE Arca.  
As this was happening, market makers and liquidity providers were widening their quotes or 
getting out altogether as the quote data they were receiving became less reliable.  Small market 
orders and stop loss orders which were triggered when issues traded below their respective stop 
levels were left to execute against the very limited amounts of liquidity that was posted on other 
exchanges or market centers.  In some cases the only available quotes left were the so-called stub 
quotes of some of the market makers.  This complete lack of liquidity resulted in several well 
publicized $.01 prints in some securities.   

3 
 
.  
As an institution, we have long understood the significant risk of using market orders 
particularly as the market has become more fragmented.  We abandoned their use many years 
ago in favor of marketable limit and limit orders.  In light of the events of May 6 and the 
continuing issues small market orders have had in the market (i.e., electing newly imposed 
single-stock circuit breakers on WPO, CSCO, C, APC), Invesco strongly supports the 
examination of the current practices surrounding the use of market orders, particularly the use of 
“stop loss” orders.  We would recommend at the very least that exchanges or broker dealers who 
continue to use market orders do so using collars on the market orders they submit.  A collared 
market order should only allow execution of the order within a certain percentage of the 
reference price (i.e., 3% from the last sale).  This would give their clients some level of 
protection from the impact market orders can have in the current environment and would likely 
reduce or altogether eliminate the issue of small share amounts triggering circuit breakers.   
 
Other Methods to Address and Prevent Extreme Stock Price Movements
 
 
We believe that the self-help provision under Regulation NMS needs to be reviewed.  
Allowing an exchange to ignore another’s quotes because of system issues unrelated to 
significant market activity is one thing, but the ability to ignore the quotes when there is a May 6 
type of event is quite another.  This provision of Regulation NMS was put in place many years 
ago to prevent manual markets from unnecessarily slowing down trading.  It was also conceived 
at a time when there were very few high frequency trading firms and fast executions were 
defined in seconds not milliseconds.  After all, are there many participants that would disagree 
with the wisdom of slowing things down a bit in times of significant upheaval as we clearly had 
on May 6?   
 
There are other measures which have been adopted by various exchanges, the CME in 
particular, which may have broader appeal to other exchanges.  For example the CME’s Globex 
system uses price banding as an electronic verification process to prevent orders from being 
entered into the system which are substantially above or below current prices.   From all 
indications this has proven to be an effective measure in reducing erroneous trades.  The CME 
also uses price limits which allow a security to trade down to a predetermined percentage before 
triggering a “limit down” which means that the security can only trade at or above that level for 
10 minutes.  If the security is still trading down after 10 minutes, there is a 2 minute halt and then 
the security is free to trade until the next limit down.    
 
Need for Consistent Rules Across All Types of Markets
 
 
The events of May 6 illustrated the interdependency of the equity, options and future 
markets, particularly the connection between price discovery for the broader stock market and 
activity in the futures markets.  Invesco strongly supports a more robust discussion and 
examination of the linkages and interdependency of the equity, options and futures markets and 
whether rules need to be made consistent across all types of markets.  We recognize concerns 
that certain rules are not coordinated across markets, including rules recently implemented to 
address the events of May 6.  We would also view this as an opportune time to implement 
market-wide circuit breakers based on a broader index than the DJIA; the S&P 500 would seem 

4 
 
to be the most sensible.  We recommend that these circuit breakers be set on a percentage basis 
based on the prior closing level of the index.
 
 
Responsibilities of Market Makers
 
 
The role of traditional liquidity providers such as market makers has taken on more 
significance since the events of May 6, as the sudden absence of liquidity in the markets played a 
critical role in the severe decline in stock prices.  Several ideas have been put forth to improve 
the operation of market makers that are worthy of further examination, including increasing 
obligations surrounding best price, depth of markets, and the maximum quoted spread obligation.  
To address concerns regarding the absence of liquidity in times of market stress, we recommend 
that the Advisory Committee examine these and other ideas that have been put forth including 
whether more stringent obligations are necessary for traditional market makers in times of 
market stress.   
 
In addition to traditional market makers, an examination of other liquidity providers, 
particularly high frequency traders, is warranted.  It is no surprise that high frequency traders and 
issues connected to high frequency trading have garnered the attention of regulators, Congress, 
and market participants in general.  Given the significant market volume that high frequency 
trading now represents, high frequency trading impacts almost every aspect of the securities 
markets in one way or another.  This was clearly exemplified on May 6 when many high 
frequency traders withdrew their liquidity after prices declined rapidly.  As the SEC noted, these 
firms may have acted appropriately under current rules.  Nevertheless, this raises the need to 
examine on an expedited basis whether new obligations should apply to liquidity providers such 
as high frequency traders. 
 
No matter what side of the high frequency trading issue one may take, it is clear that the 
issues surrounding high frequency trading are ripe for further examination.  While Invesco 
believes there are many beneficial high frequency trading strategies and participants which 
provide valuable liquidity and efficiencies to the markets, we also believe there are some 
strategies that could be considered as improper or manipulative activity.  Therefore, we believe 
there is an immediate need for more information about high frequency traders and the practices 
of high frequency trading firms.  Additionally, regulators should act to address the increasing 
number of order cancellations in the securities markets.  It has been theorized that as many as 
95% of all orders entered by high frequency traders are subsequently cancelled.  Incentives that 
currently exist for market participants to route orders to particular venues, such as liquidity 
rebates, and any related conflicts of interest that may arise due to these incentives also need to be 
examined.   
 
Addressing Inconsistent Trading and Market Structure Rules Across Markets
 
 
Fragmented trading markets and the differing rules and practices governing those markets 
were a significant factor in the price declines experienced on May 6.  Specifically, there is a need 
for an examination of the use by exchanges of mechanisms to pause trading in a security and the 
impact such action may have on other exchanges which may not have similar mechanisms in 
place.   

5 
 
 
As we previously stated and the SEC has recognized, the combination of the NYSE going 
slow and other exchanges declaring self help against NYSE Arca severely limited liquidity on 
those exchanges that continued to execute orders in an automated fashion.  While it is important 
for the Advisory Committee to study the impact of LRPs on trading on May 6, the declaration of 
self-help by the exchanges also raises a broader market structure issue that should be considered 
in examining the events of May 6 and market structure in general.  Specifically, we believe an 
examination is warranted as to whether the current market structure has become too focused on 
the speed of execution over all other factors.  At some point we believe that speed and price 
discovery have an inverse relationship and this dynamic needs to be understood. 
 
Other Market Structure Issues Impacting Investors 
 
As I mentioned, in its examination of the market events on May 6, the Advisory 
Committee also should not lose sight of the broader market structure issues raised by the SEC’s 
concept release examining the structure of the U.S. equity markets.  These issues are equally 
critical to investors’ ability to trade efficiently under the current market structure.   
 
Investors, both retail and institutional, are better off now than they were just a few years 
ago.  Trading costs have been reduced, more trading tools are available to investors with which 
to execute trades, and technology has increased the overall efficiency of trading.  Nevertheless, 
long-time challenges for funds remain.  Posted liquidity and average execution size is lower 
while the difficulty of trading large blocks of stock has increased.  New challenges also have 
been created by recent market structure developments, for example there is still virtually no 
incentive for institutions to publically post limit orders.  This point was clearly on display on 
May 6. 
 
In addition to the high frequency trading issues noted above, one of the areas in which 
action will be critical is the need for increased information to investors about the order routing 
and execution practices of broker-dealers and other trading venues.  Improved information would 
allow investors to make better informed investment decisions, as well as assist regulators and 
public commentators in assessing current market performance.  
 
Invesco looks forward to working with the Advisory Committee as it continues to 
examine the impact on investors of the May 6 market events.  I thank the Advisory Committee, 
again, for organizing this panel.  I look forward to answering your questions. 

1 
 

Statement of Kevin Cronin 
Global Head of Equity Trading, Invesco Ltd. 

Joint CFTC-SEC Advisory Committee on Emerging Regulatory Issues 
August 11, 2010 

 
 

Thank you, Chairman Schapiro, Chairman Gensler and members of the Advisory 
Committee for the opportunity to speak here today.  I am pleased to participate on behalf of 
Invesco at this meeting examining investors’ perspectives of the May 6, 2010 market events.  
Invesco is a leading independent global asset management firm with operations in 20 countries 
and assets under management of approximately $560 billion.   

 
An efficient and effective trading environment is crucial to our funds’ shareholders and to 

investors at large.  We therefore commend the Advisory Committee for its examination of the 
current structure of the U.S. equity markets, particularly the market events of May 6, and its 
continued interest in addressing issues that may impact investor confidence in these markets. 

 
The large and sudden price dislocations experienced on May 6 were, in large measure, 

the result of flaws and inefficiencies in the current U.S. market structure.  Specifically, the May 6 
“flash crash” highlighted the need for: (1) updated market-wide and stock-by-stock circuit 
breakers; (2) effective and transparent procedures for resolving clearly erroneous trades; (3) an 
examination of the use and consequences of market orders; (4) an examination of the 
inconsistent practices used by the exchanges to address major price movements in stocks; (5) an 
assessment of the responsibilities and obligations of registered and unregistered “modern day” 
market makers; and (6) better coordination across all types of markets.  

 
Several of these issues have already been addressed by regulators, including the need for 

stock-by-stock circuit breakers and better procedures for resolving clearly erroneous trades.  In 
addition, discussions are ongoing among regulators and market participants regarding the 
inconsistent practices of exchanges when dealing with major price movements in stocks.  The 
use of market orders and the current responsibilities of market makers are also being investigated 
by regulators and market participants.  Invesco supports all of these efforts.   
 

While the changes to the structure of the securities markets already underway in response 
to the events of May 6 should resolve some of the issues that contributed to the severe price 
declines on that day, it is critical that these changes not be viewed in a vacuum and instead be 
considered as one of several steps necessary to address the current inefficiencies in the markets.  
In its examination of the market events on May 6, the Advisory Committee should not lose sight 
of the broader market structure issues raised by the SEC’s concept release examining the 
structure of the U.S. equity markets, including the adequacy of information provided to investors 
about their orders, the impact of high frequency trading, and undisplayed liquidity.  These issues 
are equally critical to investors’ ability to trade efficiently under the current market structure.   
 



2 
 

Establishing Mechanisms to Address Extreme Price Moves 
 

Removing all instability and volatility from the equity markets is neither possible nor 
appropriate.  However, establishing mechanisms to address extreme price moves in the markets 
and volatility related to inefficient market structure will be critical in preventing a repeat of the 
May 6 market event.  While the SEC and SROs, through the single stock circuit breaker rules 
and clearly erroneous rules, have begun to take steps to address extreme stock price moves and 
uncertainty regarding the breaking of trades due to those price moves, there are other steps that 
need to be considered to address future extreme moves in stock prices. 

 
Circuit Breaker Rules and Clearly Erroneous Rules 
 

Invesco supported the single stock circuit breaker proposals as a means to mitigate the 
impact of sudden market volatility by implementing a trading pause for individual securities in 
times of market stress.  Similarly, we strongly supported amendments to the rules relating to 
clearly erroneous executions to clarify the process for breaking erroneous trades and to provide 
uniform treatment across the exchanges for clearly erroneous execution reviews.  However, we 
believe the whole notion of taking trades off the tape is generally detrimental to investor 
confidence.  We would propose that the exchanges clearly define and articulate the parameters 
that constitute erroneous trades and then program their systems to detect and reject trades outside 
of those parameters.  We believe uncertainty surrounding the clearly erroneous rules and the 
risks associated with entering orders during the drop in stock prices likely contributed to the 
rapid and dramatic May 6 market decline.  Ensuring that only good trades are reported to the tape 
would provide investors and liquidity providers an increased level of confidence regarding the 
trading data they need to participate in good and bad markets. 

 
Use of Market Orders 
 

As was clearly illustrated by the events of May 6 when there is a vacuum of liquidity, 
smaller market orders can have an outsized impact on the prices of securities.  Market orders are 
orders which seek to be immediately executed at the best available price.  On May 6, a vacuum 
of liquidity was created when a massive wave of sell orders hit the markets triggering liquidity 
replenishment points (LRP’s) on the NYSE.  These LRPs or speed bumps resulted in the NYSE 
going into “slow mode.”  Subsequently, NASDAQ and the other exchanges declared “self-help” 
against NYSE Arca.  Self-help is a provision under Regulation NMS which allows one exchange 
to ignore the quotes of another exchange which is experiencing system problems.  In this case 
the declaration of self-help allowed the other exchanges to essentially ignore the quotes on 
NYSE Arca.  Thus as the various exchanges were determining where to route their orders to 
fulfill their Regulation NMS obligations they could do so without consideration to NYSE Arca.  
As this was happening, market makers and liquidity providers were widening their quotes or 
getting out altogether as the quote data they were receiving became less reliable.  Small market 
orders and stop loss orders which were triggered when issues traded below their respective stop 
levels were left to execute against the very limited amounts of liquidity that was posted on other 
exchanges or market centers.  In some cases the only available quotes left were the so-called stub 
quotes of some of the market makers.  This complete lack of liquidity resulted in several well 
publicized $.01 prints in some securities.   



3 
 

.  
As an institution, we have long understood the significant risk of using market orders 

particularly as the market has become more fragmented.  We abandoned their use many years 
ago in favor of marketable limit and limit orders.  In light of the events of May 6 and the 
continuing issues small market orders have had in the market (i.e., electing newly imposed 
single-stock circuit breakers on WPO, CSCO, C, APC), Invesco strongly supports the 
examination of the current practices surrounding the use of market orders, particularly the use of 
“stop loss” orders.  We would recommend at the very least that exchanges or broker dealers who 
continue to use market orders do so using collars on the market orders they submit.  A collared 
market order should only allow execution of the order within a certain percentage of the 
reference price (i.e., 3% from the last sale).  This would give their clients some level of 
protection from the impact market orders can have in the current environment and would likely 
reduce or altogether eliminate the issue of small share amounts triggering circuit breakers.   
 
Other Methods to Address and Prevent Extreme Stock Price Movements 
 

We believe that the self-help provision under Regulation NMS needs to be reviewed.  
Allowing an exchange to ignore another’s quotes because of system issues unrelated to 
significant market activity is one thing, but the ability to ignore the quotes when there is a May 6 
type of event is quite another.  This provision of Regulation NMS was put in place many years 
ago to prevent manual markets from unnecessarily slowing down trading.  It was also conceived 
at a time when there were very few high frequency trading firms and fast executions were 
defined in seconds not milliseconds.  After all, are there many participants that would disagree 
with the wisdom of slowing things down a bit in times of significant upheaval as we clearly had 
on May 6?   

 
There are other measures which have been adopted by various exchanges, the CME in 

particular, which may have broader appeal to other exchanges.  For example the CME’s Globex 
system uses price banding as an electronic verification process to prevent orders from being 
entered into the system which are substantially above or below current prices.   From all 
indications this has proven to be an effective measure in reducing erroneous trades.  The CME 
also uses price limits which allow a security to trade down to a predetermined percentage before 
triggering a “limit down” which means that the security can only trade at or above that level for 
10 minutes.  If the security is still trading down after 10 minutes, there is a 2 minute halt and then 
the security is free to trade until the next limit down.    

 
Need for Consistent Rules Across All Types of Markets 
 

The events of May 6 illustrated the interdependency of the equity, options and future 
markets, particularly the connection between price discovery for the broader stock market and 
activity in the futures markets.  Invesco strongly supports a more robust discussion and 
examination of the linkages and interdependency of the equity, options and futures markets and 
whether rules need to be made consistent across all types of markets.  We recognize concerns 
that certain rules are not coordinated across markets, including rules recently implemented to 
address the events of May 6.  We would also view this as an opportune time to implement 
market-wide circuit breakers based on a broader index than the DJIA; the S&P 500 would seem 



4 
 

to be the most sensible.  We recommend that these circuit breakers be set on a percentage basis 
based on the prior closing level of the index.

 

 
Responsibilities of Market Makers 
 

The role of traditional liquidity providers such as market makers has taken on more 
significance since the events of May 6, as the sudden absence of liquidity in the markets played a 
critical role in the severe decline in stock prices.  Several ideas have been put forth to improve 
the operation of market makers that are worthy of further examination, including increasing 
obligations surrounding best price, depth of markets, and the maximum quoted spread obligation.  
To address concerns regarding the absence of liquidity in times of market stress, we recommend 
that the Advisory Committee examine these and other ideas that have been put forth including 
whether more stringent obligations are necessary for traditional market makers in times of 
market stress.   

 
In addition to traditional market makers, an examination of other liquidity providers, 

particularly high frequency traders, is warranted.  It is no surprise that high frequency traders and 
issues connected to high frequency trading have garnered the attention of regulators, Congress, 
and market participants in general.  Given the significant market volume that high frequency 
trading now represents, high frequency trading impacts almost every aspect of the securities 
markets in one way or another.  This was clearly exemplified on May 6 when many high 
frequency traders withdrew their liquidity after prices declined rapidly.  As the SEC noted, these 
firms may have acted appropriately under current rules.  Nevertheless, this raises the need to 
examine on an expedited basis whether new obligations should apply to liquidity providers such 
as high frequency traders. 
 

No matter what side of the high frequency trading issue one may take, it is clear that the 
issues surrounding high frequency trading are ripe for further examination.  While Invesco 
believes there are many beneficial high frequency trading strategies and participants which 
provide valuable liquidity and efficiencies to the markets, we also believe there are some 
strategies that could be considered as improper or manipulative activity.  Therefore, we believe 
there is an immediate need for more information about high frequency traders and the practices 
of high frequency trading firms.  Additionally, regulators should act to address the increasing 
number of order cancellations in the securities markets.  It has been theorized that as many as 
95% of all orders entered by high frequency traders are subsequently cancelled.  Incentives that 
currently exist for market participants to route orders to particular venues, such as liquidity 
rebates, and any related conflicts of interest that may arise due to these incentives also need to be 
examined.   
 
Addressing Inconsistent Trading and Market Structure Rules Across Markets 
 

Fragmented trading markets and the differing rules and practices governing those markets 
were a significant factor in the price declines experienced on May 6.  Specifically, there is a need 
for an examination of the use by exchanges of mechanisms to pause trading in a security and the 
impact such action may have on other exchanges which may not have similar mechanisms in 
place.   



5 
 

 
As we previously stated and the SEC has recognized, the combination of the NYSE going 

slow and other exchanges declaring self help against NYSE Arca severely limited liquidity on 
those exchanges that continued to execute orders in an automated fashion.  While it is important 
for the Advisory Committee to study the impact of LRPs on trading on May 6, the declaration of 
self-help by the exchanges also raises a broader market structure issue that should be considered 
in examining the events of May 6 and market structure in general.  Specifically, we believe an 
examination is warranted as to whether the current market structure has become too focused on 
the speed of execution over all other factors.  At some point we believe that speed and price 
discovery have an inverse relationship and this dynamic needs to be understood. 

 
Other Market Structure Issues Impacting Investors 

 
As I mentioned, in its examination of the market events on May 6, the Advisory 

Committee also should not lose sight of the broader market structure issues raised by the SEC’s 
concept release examining the structure of the U.S. equity markets.  These issues are equally 
critical to investors’ ability to trade efficiently under the current market structure.   

 
Investors, both retail and institutional, are better off now than they were just a few years 

ago.  Trading costs have been reduced, more trading tools are available to investors with which 
to execute trades, and technology has increased the overall efficiency of trading.  Nevertheless, 
long-time challenges for funds remain.  Posted liquidity and average execution size is lower 
while the difficulty of trading large blocks of stock has increased.  New challenges also have 
been created by recent market structure developments, for example there is still virtually no 
incentive for institutions to publically post limit orders.  This point was clearly on display on 
May 6. 
 

In addition to the high frequency trading issues noted above, one of the areas in which 
action will be critical is the need for increased information to investors about the order routing 
and execution practices of broker-dealers and other trading venues.  Improved information would 
allow investors to make better informed investment decisions, as well as assist regulators and 
public commentators in assessing current market performance.  

 
Invesco looks forward to working with the Advisory Committee as it continues to 

examine the impact on investors of the May 6 market events.  I thank the Advisory Committee, 
again, for organizing this panel.  I look forward to answering your questions.