Hi, James:
Let me answer the questions that I can, and try to gracefully punt on the rest. Answers follow, in order of increasing complexity:
- How are orders executed within the C2 system? E.g., which accounts get to execute first and which ones last, and how is that determined?
The sequence in which account/orders are submitted to the exchange are newly randomized with each and every order. No one account always goes first or last. Always random.
- Do limit orders avoid issues related to CBOT Rule 575.D?
Orders that are entered as limit orders by the strategy will be sent initially to the exchange as limit orders (and thus will not be delayed by C2). However, if the limit orders are not entirely filled by the exchange, but are only partially filled, they will be converted to market and thus will be subject to CME regulations. Conversions to market are necessary to keep accounts in sync with Strategy Model Account intentions.
- Is C2 still in touch with CME regarding its footprint? What are the thresholds for CBOT Rule 575.D in terms of market impact? Is the impact based on all systems collectively through C2 or individual strategies?
I’m not able to discuss Collective2’s conversations or relationship with the CME in these forums, or interpretations of any particular regulation. I can say only that Collective2 does its best to fulfill market regulations imposed by the CME on market participants.
I wish I could provide more information, but hopefully the answers to the other questions will be helpful.
Matthew