Timothy Massad, Chairman of the Commodity Futures Trading Commission, warned attendees at the annual P.R.I.M.E Financial conference in Amsterdam that trading firms should likely seek legal assistance if they purposely had a very high ratio of unfilled to filled orders. According to Mr. Massad, “[i[n a recent case, a defendant entered over 460,000 orders, but consummated only 371 trades. … [I]f your trading firm is entering a lot of orders without the intention to consummate, you should probably go talk to your lawyers.” In a wide ranging speech to members of this organization – whose stated purpose is to “resolve, and to assist judicial systems in the resolution of, disputes concerning complex financial transactions” – Mr. Massad also addressed initiatives by the CFTC to help ensure clearinghouses’ resiliency, the supplemental leverage ratio (“SLR”) and improving swap data reporting. As he has before, Mr. Massad supported banking regulators’ steps to increase financial institutions’ limits on liabilities compared to assets through the SLR. However, he objected that, in connection with derivatives, banking regulators to date have not permitted banks to offset banks’ potential exposure to clearinghouses by collateral they post in computing their SLR. According to Mr. Massad, “the way the SLR measures potential future exposure could have a significant, detrimental effect on clearing, and in turn, on clearinghouse resiliency. A large banking institution will look at the costs of regulation on each aspect of its business. And if some clearing members choose to limit customers, or get out of the clearing business altogether, that may make it harder to deal with the next time a clearing member defaults.”