[This message was posted by James Crosson of FIX Flyer LLC <[email protected]> 
to the "US Regulations" discussion forum at http://fixprotocol.org/discuss/48. 
You can reply to it on-line at http://fixprotocol.org/discuss/read/f4329f57 - 
PLEASE DO NOT REPLY BY MAIL.]

K. Manesh,

In most cases your assumption of #5 - "The who bought the application..." is 
correct. Any mature organization will have trade-loss provisions in licensing 
and contract terms, providing indemnity against any system/algorithm that 
result in losses in the marketplace. 

Even in the event a trade-loss provision is not included with a system license, 
the user wouldn't have a leg to stand on when pursuing the vendor for losses. 
The reality is that the provider of the system does not have any exposure to 
the up-side of trading (ie. will not have the ability to increase revenue if 
the software is used to create market gains), and thus cannot plausibly be 
responsible for the down-side of trading. 

In the event of application problems resulting in substantial losses, the user 
of the system could, and likely should, cancel their license/contract for the 
algorithm and/or system used. Any charges of breach-of-contract, however, would 
be limited to the costs of the application and can't be linked to market 
performance. 

Hope this helps,

James Crosson
Vice President, Operations
FIX Flyer, LLC.

> Hi All,
> 
> In the context of an Computer Algorithim placing an Order and receiving its 
> Trades using a FIX session where there is no human action involved in order 
> creation, (humans just watch the status / performance of this Order 
> dynamically), if something goes wrong in the algorithim (software bug) which 
> leads to unwanted market activity in violation of some SEC law, who is held 
> responsible? Is it:-
> 
> 1. The Systems analyst who wrote the requirements specification.
> 
> 2. The Technology architect who designed the application.
> 
> 3. The programmer who wrote the code.
> 
> 4. The tester who failed to find the bug.
> 
> 5. The user who bought this application and connected it to a broker / market.
> 
> Common sense says it must be "5. The user", please share your views.
> 
> I once asked this question in a FIX project meeting, a senior manager said "I 
> dont know what SEC does, we all shall definetly loose our jobs. So don't ask 
> stupid questions to which we may not have answers. All of you make sure you 
> do your respective roles fully and properly".
> 
> Regards,
> K. Mahesh


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