Under the proposed rules the SEC would require broker-dealers with access to trading securities directly on an exchange or ATS as a result of being a member or subscriber, to establish, document, and maintain a system of risk management controls and supervisory procedures that are reasonably designed to limit the financial exposure that may result from having market access and providing it to others, and to ensure that those with such access, and those to whom it is provided, comply with all with all applicable regulatory requirements. The broker-dealer would be required to apply certain controls on a pre-trade basis, and to retain exclusive control over those controls and not delegate this function to a customer or another third party. The proposal also would require broker-dealers to establish a supervisory system, including an annual CEO certification, to assure the ongoing effectiveness of its controls. The proposal would apply market-wide, whenever a broker-dealer directly accesses any exchange or ATS. Comments on the SEC's proposed rule should be submitted on or before Comments should be submitted on or before March 29, 2010. See also SEC Press Release.