East markets, notably ones in GBPUSD and USDJPY, enough that they warrant their own Wikipedia page. Indeed, the International Swaps and Derivatives Association (‘ISDA’) plus the Securities Industry and Financial Markets Association (‘SIFMA’) in a joint submission came out dead against this with ‘While auto-liquidation may be a useful risk management tool in certain cases, it is not an appropriate solution for derivatives markets.’ 4


. However,


the CCI countered this under a section headlined ‘Real-Time Infrastructure is a Risk Mitigant – Not a Risk-Creator’5


. This last point led nicely onto another by discussing ‘Rather than introduce


new risk, continuous trading infrastructure – when properly designed – can serve as a stabilizing force.’6


discussion…on Operational Issues! These were many & varied…and in no particular order covered staffing issues at customers (one should not just think of oneself as a broker…you have to think of such shortfalls at customers as well), brokers, clearers, exchanges and even at the CFTC (something I kind of bet no-one had thought about) also systems and processing issues plus obligations to broker-dealers.


I also saw discussion over market integrity, specifically how lower weekend liquidity would increase risk, how thin markets would become more liable to fraud & market manipulation, how there could and would be no ‘overnight’ processing, how we might have a skewed marketplace with some firms offering 24/7 whilst others choosing not to. Would extended hours help some products or hinder them, agricultural products for instance…would hedgers be taken away from producing their products by having to watch a market continuously? The issue was also highlighted as to whether 24/7 clearers should pay a higher premium to any guarantee fund held at exchanges & whether capital requirements would need to reflect some potential higher risk from those offering 24/7 services. Finally, there was the BANE of every single broker I have ever known…potential RE-PAPERING of client documentation to reflect these changes. I shudder!


4 SIFMA > Submissions (21st May 2025) 5 www.cryptoforinnovation.org (21st May 2025) 6 www.cryptoforinnovation.org (21st May 2025)


Whilst all these were going on, 2 other features caught my attention. The first was a report published by Eventus and Datos Insights titled ‘The Trade Surveillance Revolution: Compliance Shifts and Cutting-Edge Tech Shake-up Transforming the Surveillance Function’7


…you can see they tried


to make it sound jazzy...but I don’t think they really managed it. However, one piece within it struck me as very relevant to this discussion…and Finance Feeds summed it up thus ‘Among the study’s most striking findings is that over 70% of firms report false positive alert rates above 25%, placing a significant burden on compliance teams. Many respondents cited ‘’alert fatigue’’ as a growing risk that could lead to oversight of critical threats’8


. Can you


imagine how this figure translates into the ‘fatigue alert’ we would see within 24/7/365 trading? A very big question I’m sure, that needs attention! Secondly, and perhaps more relevant to the decision the CFTC may make, was an excellent article in Waters Technology by Nyela Graham titled ‘No, no, no, and no: Overnight trading fails in SIP vote’9


the Securities Information Processors Committees consisting of the Consolidated Tape Association and the Unlisted Trading Privileges Plan recently voted on plans to extend trading on a number of venues… and none of them reached a unanimous consensus. The way the committees apparently work is that a unanimous vote has to be passed to achieve change…and it wasn’t…so it didn’t!


This last piece…and I really recommend reading this article as it is quite insightful. This last piece just brings to my mind this ultimate point. If we as an industry, cannot seem to even manage to work together to agree on something like this…should we really be tampering or even entrusted to tampering, with extending markets 24/7/365? All this…and I didn’t even get to talking about ‘perps’ aka…Perpetual Contracts!


Eddie Tofpik E: eddie.tofpik@admisi.com T: +44(0) 20 7716 8201


7 www.eventus.com 8 www.financefeeds.com (30th May 2025) 9 www.waterstechnology.com (12th March 2025)


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