“A Capital Market Partner Adding to Customer Value”
The Comprehensive Management Plan for
Algorithmic Trading in the KRX Derivatives
Market
04.29.2013
The Korea Exchange
Announcement
This booklet is published for the briefing held in Seoul in April 29th, 2013 for the
business staff and IT developers who work for the derivatives members of the Korea
Exchange.
* It is scheduled to distribute this document to the participants’ email addresses from the
submitted business cards when the briefing is over. If there are any members excluded from
receiving this document, feel free to contact the department of the Derivatives Development &
Regulations by sending a request to [email protected].
This proposal is not yet to be finalized, therefore subjected to any potential changes to
be made in consideration for members, investors, and the financial authorities. In regard
to any revisions to be made in this proposal, the Korea Exchange will be in contact with
each of its members by notification or briefing.
The Korea Exchange always cares for voices of its members. If there is a member
who likes to leave a comment on the proposal inside, please be sure to submit before the
deadline, May 3rd
, 2013, to the department of the Derivatives Development &
Regulations. Please include the following information along with your comment.
Name
Comment on the proposal
Comment on the enforcement date
Etc.
* Recipient: the department of the Derivatives Development & Regulation
“A Capital Market Partner Adding to Customer Value”
I. In progress
The Korea Exchange (the Derivatives Development & Regulations of the Derivatives
Market Division) is opening this briefing in order to provide its members with the latest
updates regarding the management of algorithmic trading. It is also to avoid negative
market impacts generated by algorithmic trading errors and secure both effectiveness
and safety of the derivatives market with a comprehensive management plan designed
to prevent such abnormalities. Through this briefing as a cornerstone, the Korea
Exchange is expecting to create a meaningful opportunity to listen to members’ opinions.
After the briefing, the Korea Exchange plans to finalize amending the derivatives
market regulation once a review process with the financial authorities has been
completed and to improve the system.
“A Capital Market Partner Adding to Customer Value”
II. Summary of the comprehensive management plan
Assortment Detail Anticipated Outcome
Risk
management
of algorithmic
trading
- Register the algorithmic trading
accounts to KRX
- Minimize the negative market
impacts due to abnormal
transactions by the algorithmic
trading errors
- Set the cumulative order quantity
limit
- Take advantage of ‘the Kill Switch’
- Operate the automated order
cancellation system
Excessive
order
management
- Restrict receiving excessive orders
- Secure the stability of the
exchange derivatives system
- Impose an extra service charge for
excessive orders
Risk
management
of the ex-post
customer
margin
account
- Increase the management level of
the risk exposure amount
- Reduce the risk that institutional
investors fail to fulfill their
settlement obligation to maintain
the ex-post customer margin
- Abolish the duty that requires the
maintenance customer margin in the
ex-post customer margin accounts
※ This booklet is prepared to assist the understanding of members on matters
related to order receipt and submission. It should be kept in mind that the contents
herein can change when the Business Regulations of KRX Markets are amended.
A. Risk management of algorithmic trading
1. Duty to register the algorithmic trading accounts to KRX
a. Current problem: It is nearly impossible for KRX to perform real-time monitoring
on every automated transaction or to detect traces of abnormal transactions in absence
of the information, members’ account information in algorithmic trading.
Currently, it is mandatory to register only the market making accounts of members and
the ex-post customer margin accounts to KRX.
b. Improvement: KRX becomes capable of shielding the market against the negative
market impacts, such as a technical glitch generated by abnormal orders due to the
algorithmic trading errors, by making use of the member-submitted account information
in algorithmic trading.
Definition of ‘algorithmic trade’: ‘algorithmic trade’ is the use of electronic platforms for
entering trading orders with an algorithm which executes pre-programmed trading
instructions whose variables may include timing, price, or quantity of the order, or in
many cases initiating the order without human intervention.
Members are strongly required to register the algorithmic trading accounts of their own
and their customers to KRX before placing an order.
* In regard to investors who trade on algorithms and manually at the same time, they are
also on duty to register their algorithmic trading accounts in advance.
* Members are asked to fill in extra information such as ‘process ID’ and ‘contact
information’ for emergency use in the registration process.
Within the extent of the registered algorithmic trading accounts, KRX is going to monitor
all transaction records to detect signs of abnormal orders through the monitoring system
under development.
In regard to members with the unregistered algorithmic trading accounts with over 20,000
daily orders, they are strongly advised to submit a statement to prove their non-
algorithmic trading action by the market closing time of the following day.
<Guideline of registering the algorithmic trading accounts>
Assortment Details
Applicant - Members
Object to
register
- All the derivatives accounts in use for algorithmic trading (Both
members’ and their customers’)
* According to the definition of ‘algorithmic trade’- ‘algorithmic trade’ is
the use of electronic platforms for entering trading orders with an
algorithm which executes pre-programmed trading instructions whose
variables may include timing, price, or quantity of the order, or in many
cases initiating the order without human intervention.
- It is required to report to KRX without delay whenever there is any
When to
report
change on the status of the algorithmic trading accounts as long as those
accounts are registered and valid for use.
* Members should report to KRX especially when they permanently close their
algorithmic trading accounts. By doing so the exchange derivatives system can
reduce burden of unnecessary workload.
How to
register
- It is required to input the information into the exchange derivatives
system using the member derivatives system (API method)
Registration
in details
Item to register Details
Account No. of the
algorithmic
trade accounts
-To provide members with ‘the Kill
Switch*’
Order process ID
in use for
The algorithmic
trading accounts
-To provide the function called ‘Cancel
on Disconnect**’
- Provided only if it is an exclusive
process
Contact Information of
The representative in charge
of algorithmic trading
- To make contact with the
representative without delay in
emergency
* Kill Switch: allocated to the account No. of the registered account
** Cancel on Disconnect: allocated to the registered order process ID
(Introduction of this function is subject to the test result from the Exture+
system under development)
- An additional account code for algorithmic trading will be added to the
current account code types.
Account code * Current account code types
→ Customer: 31, Member: 41,
Market Making: 42, Arbitrage& Hedge: 51
How to process
the code from
unregistered
accounts
- When the algorithmic trading account code appears from the
unregistered accounts while receiving orders, it is necessary to make
confirmation with the corresponding members.
→ It is not to be processed until members confirm the fact.
- When the non-algorithmic trading account code appears from the
registered accounts while receiving orders, it is necessary to make
confirmation with the corresponding members.
→ The registered accounts continuously remain algorithmic to KRX until
they are reported permanently closed to KRX.
Statement
submission
to prove
non-algorithmic
trading action
- KRX gives a notification to members who hold the unregistered
accounts with over 20,000 daily orders (except for “the trade on CME
Globex” and “the negotiated trade”) after the closing of trade.
- Members are required to submit a statement to prove their non-
algorithmic trading action by the market closing time of the following day.
→ Members should check with their customers from the very start to see
if those customers’ intention of opening an account matches with the
requirements of algorithmic trading accounts
2. Introduction of the cumulative order quantity limit
a. Current Problem: There exists the order quantity limit, but no safety net to put a
cap on the heavily accumulated orders caused by irregular duplication of individual
orders which comply with the quantity limit per contract though. (January 7th
, 2013).
* Ex) the order quantity limit for KOSPI 200 futures: 1,000 contracts
b. Improvement: Members should estimate and then input their cumulative order
quantity limit for their own and their customers’ ex-post margin accounts to curb orders
beyond the limit.
* The upfront initial customer margin accounts, quantities of which are already ceiled
due to adoption of the upfront initial customer margin, are exempted from adopting the
cumulative order quantity limit.
* An additional step for verifying the cumulative order quantity limit is newly added to
the existing steps for the verification by members (Regulation 65) and it goes equal for
both members and their customers.
* Members are entitled to set their own cumulative order quantity limit within the scope
of the fixed figures** to the long/short* as KRX stipulates.
* It is not easy to detect irregular repetition of the long/ short orders solely under the net
cumulative limit (Ex: 10,000 contracts of short futures + 10,000 contracts of long futures= 0)
** The cumulative order quantity limit is 7,500 Delta to the long/short for the ex-post customer
margin accounts of the algorithmic trading accounts, whereas it is 15,000 Delta to the long/short
for the ex-post customer margin accounts which are not in the category of the algorithmic trading
accounts.
* Investors, including members, are temporarily allowed to place mass orders beyond
the cumulative order quantity limit if they acquire an authorization from the department
of the risk management of their own to raise the limit for a short time.
* All records relevant to the case above should be kept in a secured storage.
<Guideline of the cumulative order quantity limit>
Assortment Details
Applicant
- Members
* It is way beyond the capability of the exchange derivatives system to estimate
every cumulative order quantity limit for all the derivatives accounts → each
system of members can share the burden
Applicable
product
- KOSPI 200 Futures (incl. spread), KOSPI 200 Options
* Expected to be gradually expanded to all products.
Object
to verify
- Members’ own accounts and the ex-post customer margin accounts
* The upfront initial customer margin accounts, quantities of which are already
ceiled due to adoption of the upfront initial customer margin, are exempted from
adopting the cumulative order quantity limit.
- It intends to verify the order quantities which are set to be placed during the
order receiving hours of the regular session
* “The trade on CME Globex” and “the negotiated trade” are not counted
- It is newly added to the existing verification by members
How to
verify
- Excessive orders over the cumulative order quantity limit will be
automatically dropped
- Members are entitled to set their own cumulative order quantity limit within
the scope of the fixed figures to the long/short as KRX stipulates.
- The cumulative order quantity limit is 7,500 Delta to the long/short for the
ex-post customer margin accounts of the algorithmic trading accounts
- The cumulative order quantity limit is 15,000 Delta to the long/short for the
ex-post customer margin accounts which are not in the category of the
algorithmic trading accounts.
- Investors, including members, are temporarily allowed to place mass orders
beyond the cumulative order quantity limit if they acquire an authorization
from the department of the risk management of their own to raise the limit for
a short time.
<Formula to calculate the cumulative order quantities>
Assortment Remarks
Long
∑(Order quantities from buying futures contracts +
Quantities of unmatched orders from buying futures
contracts)+
∑(Order quantities from futures SP + Quantities of
unmatched orders from futures SP)+
∑|(Order quantities of orders from buying call option +
Quantities of unmatched orders from buying call option)*
delta * the multiplier ratio|+
∑|(Order quantities from selling put option + Quantities of
unmatched orders from selling put option)* delta * the
multiplier ratio|
Short
∑(Order quantities from selling futures contracts +
Quantities of unmatched orders from selling futures
contracts)+
∑(Order quantities from futures SP + Quantities of
unmatched orders from futures SP)+
∑|(Order quantities from selling call option + Quantities of
unmatched orders from selling call option)* delta * the
multiplier ratio|+
∑|(Order quantities from buying put option + Quantities of
unmatched orders from buying put option)* delta * the
multiplier ratio|
* KRX provides “Delta” from the previous day for use of managing the open interest
limit
* The multiplier ratio= option trade multiplier/ futures trade multiplier
→ 1 for KOSPI 200 Products
3. Introduction of the Kill Switch
a. Current problem: The existing Exchange derivatives system does not allow
members to cancel a batch of unmatched orders or to shut down receiving orders per
account by one click. As a consequence, the system is potentially exposed to the huge
risk of failure to fulfill settlement because there is no fence to stay away from
algorithmic and systematic errors.
Assortment Current situation Problem
Order
cancellation
- Inconvenience to cancel* each
order in a separate way, not
allowing to cancel a batch of orders
at once
* The individual order No. is
required to cancel each order.
- The existing cancellation method
takes too long to cancel entire
unmatched orders if algorithmic traders
hold a multiple number of them.
Order
shut down
- The exchange is not capable of
shutting down receiving orders
from a particular account
* Yet, there is a way to block
receiving orders from a particular
member
- Unless abnormal orders are
immediately detected and taken care of,
it is unavoidable to skyrocket the size
of the loss due to the algorithmic
trading errors.
b. Improvement: ‘The Kill Switch’ is set out for use to enable members to cancel a
batch of orders by one-click and to shut down additional orders afterwards.
* Taking advantage of ‘the Kill Switch,’ members can make a quick response to an unintended,
abnormal order by the algorithmic trading errors and prepare not to repeat the unfortunate
accident that recently happened in January 7th, 2013.
<Guideline of the Kill Switch>
Assortment Details
Applicant
- Members should pass through the user-authentication process to access to the
application section for the Kill Switch
- KRX cannot initiate the Kill Switch without a request from its members
* It is very unlikely to discover irregular orders only with the partial information
about orders/ transactions
Applicable
object
- The algorithmic trading accounts in which an irregular activity, such as a
technical glitch or an error, arises.
- It cannot be initiated to the unregistered algorithmic trading accounts
* Due to the way the Kill Switch operates in the exchange system, it is strongly
required to register to KRX in advance.
- If the Kill Switch is in operation for every account, there arises risk to burden
the exchange system, in forms of system overload or system lag. For that
reason, only the registered algorithmic trading accounts to KRX are
covered for operation of the Kill Switch.
* Total No. of the algorithmic trading accounts: approx. 50 to 100
Total No. of the entire trade accounts: approx. 30,000 to 40,000
Operating
hour
During the order receiving hours of the regular session(08:00-15:15)
How to
apply
- Apply through the Member Derivatives System (API method) or the member
derivatives terminal
- When members input the account no. of their algorithmic trading accounts on
Application
process
details
the system, the registration process for the Kill Switch is completed.
- It is irrevocable once the application process has been completed.
* Members are responsible for initiating the kill switch, therefore should be careful
enough not to freeze the well-functioning accounts by mistake
Operation
process of
the Kill
Switch
- One stop process(①+②)
① Cancel a batch of unmatched orders from the account by one click
② Automatically shut down receiving orders from the account
* It saves the unnecessary inconvenience to cancel each unmatched order separately.
- It might look quite identical with the existing process to cancel an order when
it comes down to the entity who decides and proceeds the operation, but the
newly devised Kill Switch distinguishes itself from the existing as it cancels a
batch of orders at one time, not each order in a separate way.
Release of
the Kill
Switch
Operation
- It is possible to stop* the Kill Switch operation in 10 minutes from the
initiation.
* ‘Stop’ means to release an action of blocking receiving orders from the
corresponding account, getting the account back to the normal state.
- Initiating the Kill Switch should not be abused for the purpose of investment
strategies. To avoid such kind of abusive usage, it continues to stay active at
least 10 minutes for each time.
- The Kill Switch operation continues to be valid unless there is an official
request from members.(It goes on the following day and after if not)
4. The duty to operate the automated order cancellation system
a. Current Problem: According to the regulations of the Korea Exchange, there
exists no clause about mandating to operate the automated order cancellation system* in
the requirements** for the member derivatives system.
* The system serves to cancel each unmatched order automatically.
→ It is not yet mandatory to serve for the purpose above although there are some members,
the systems of whom are set to operate for that purpose above.
** Requirements of the member derivatives system
(Enforcement rule 117-3, Regulation 65, in the guidelines related to connection to
member derivatives system)
: It should serve to process the user authentication, protect customer’s information from
abuse, and confirm order details without delay, review order/transaction details, record
order history, reject to receive orders if necessary, verify suitability of an order, use a
separate and exclusive security device, and manage the member system directly, and so
on.
It becomes the first priority to come up with a contingency plan to cope with abnormal
orders for the time being until the next generation system ‘Exture+’ debuts.
* It is on schedule to introduce ‘Exture+’ in Feb, 2014
b. Improvement: KRX mandates each member to operate the automated order
cancellation system*.
* It is planned to be included in the requirements for the member derivatives system
(Enforcement Rules 117-3)
It is anticipated that it becomes possible to take care of any abnormal orders from
members’ accounts promptly by activating the Kill Switch* in cooperation with the
automated order cancellation system
* It will be provided around the time when the next generation system ‘Exture+’ comes out in
Feb, 2014
※ Comparison between the two systems
Assortment The automated order cancellation system The Kill Switch
From
member to
KRX
- Automate the existing process
- Input the order No. for cancellation
- Initiate the Kill Switch on a
particular account
- Input the account No.
Out of the
exchange
- Process each cancellation separately
(the current method to cancel an order)
- Process order cancellation in
a batch by one click
B. Excessive Order Management
1. Restriction on receiving excessive orders
a. Current problem: There exists no safety net to restrict on receiving excessive
orders, undermining the potential risk that the exchange derivatives system goes
through a critical technical glitch due to excessive orders accidentally submitted by
the algorithmic trading errors.
* It is currently applied to the night session of the KOSPI 200 futures
“Regulation 156-2, enforcement rules 164-2”: In case where the exchange derivatives
system has failed or is expected to fail due to influx of excessive order or it is necessary
for the market management, the Exchange may not accept a part or all orders placed by
the concerned member
AVG No. of orders for the previous 3 seconds > 750 orders
- Refuse to receive orders except those for cancellation
AVG No. of orders for the previous 3 seconds > 1,000 orders
- Refuse to receive all orders without exception
* It raises a concern about the system break-down due to influx of excessive orders under the
asynchronous Exture+ system which processes the higher volume of orders than the
current system does.
b. Improvement: It becomes possible to refuse acceptance of excessive orders in
case of the system break-down or the errors due to influx of excessive orders.
< Guideline for refusing to receive excessive orders>
Step Details
1
In case where it seems to go beyond the excessive order quantity limit
→ Members are obliged to control the interval of order submission immediately after
the exchange notifies them.
2 In case where it exceeds the excessive order quantity limit
→ The exchange refuse to receive orders from the corresponding account
3
In case where it seems to exceed the maximum order receipt limit of the entire exchange
derivatives system
→ The exchange immediately shuts down the whole trade operation for a particular
product for which excessive orders are submitted. (Ex: Index option)
→ Operation designed for the trading safety of members is scheduled to be in enforcement by the time
the development of the ‘Exture+’ system is completed.
2. Impose an extra service charge for excessive orders
a. Current Problem: Due to a large number of orders by algorithmic trading, it
simultaneously burdens the exchange derivatives system, consequently generating an
increasing number of the unmatched orders. Therefore, It is essential to avoid such
ineffectiveness and to impose* an extra service charge on excessive orders.
* It seems more reasonable that the member, who trades on a frequent basis within the
exchange derivatives system, pays more for maintenance of the system.
b. Improvement: KRX imposes an extra service charge on the accounts where appear
to put out excessive orders for the KOSPI 200 futures/ option products depending
on a degree of contribution to the exchange derivatives system.
<Brief guideline of imposing the service charge for excessive orders>
Assortment Details
Object
KOSPI 200 futures (incl. futures spread)/ option product
* except for “the trade on CME Globex” and “the negotiated trade”
The market making accounts are exempted if they belong to the market
making products
* It is not applicable for the KOSPI 200 futures/ option product since it is not in
the category of the market making products.
All accounts meeting the standards in both quantity and quality
① Quantity Standard: Total No. of orders per day≥ 20,000
② Quality Standard: The ratio, No. of orders: Trading Volume of orders, is
higher than 20:1 or 10:1 depending on the No. of orders
◆The accounts with No. of orders < 20,000 – Not Applied
◆The accounts with No. of orders ≥ 20,000
Imposing
standard
< 100,000
→ The ratio of the accounts ≥ 20:1 – Applied
◆The account with orders ≥ 100,000
→ The ratio of the accounts ≥ 10:1 – Applied
Assortment
No. of orders
Trading Volume of orders (Quality)
<10:1 10:1-20:1 ≥ 20:1 ∞
No. of
Orders
(Quantity)
<20,000 N/A N/A N/A N/A
20,000-
100,000
N/A N/A Applied Applied
≥100,000 N/A Applied Applied Applied
F
E
E
Amount The fixed cost, KRW 1,000,000 per month
For use Only for improvement of the exchange derivatives system
Payment A member, who receives a bill from the exchange on the transaction date (T-
day), should make payment within 2days (T+2) from the day.
C. Risk Management of the ex-post customer margin account
1. Increase the management level for the risk exposure amount
a. Current problem: It is urgent to raise the management level for the risk exposure
amount of the ex-post customer margin accounts, not to repeat committing the
very same accident caused by the algorithmic trading errors in January 7th
, 2013
* Originally, management for the risk exposure amount of the ex-post customer margin
account was first introduced in March 28th, 2011 to protect members from the risk of
failure to fulfill the settlement obligation after the option shock (November 11th, 2010)
arose.
Assortment Status Problem
Limit on the
risk exposure
amount
- Members are required to set the
risk exposure limit lower than 10
times of the total depository.
- The current level of the limit is too
high and broad to prevent the risk of
failure to fulfill the settlement
obligation when the algorithmic
trading errors arise.
Measurement
Over the limit
- Within an hour members should
request their customers to lower the
risk exposure amount voluntarily.
- If it is not settled yet, members
should balance the exceeding
amount by either applying the
upfront initial margin or performing
- It is currently given a certain
duration of time to resolve a problem
on their own for convenience of the
qualified institutional investors.
- However, it turns out ineffective in
deal with emergency quickly because
there exist the risks of delay and
an opposite transaction. abusive usage by some institutional
investors
b. Improvement: It is meant to increase the management level of the risk exposure
amount in the ex-post customer margin accounts by lowering and narrowing its
risk exposure limit and stopping receiving orders without delay.
Lower the risk exposure limit below 5 times of the total depository.
In case of the excess over the limit, it immediately blocks receiving orders from
customers without offering a time to settle down a problem on their own
- But, It is exceptionally allowed to receive orders to lower the risk exposure amount.
2. Abolish the duty that requires the maintenance customer margin in the
ex-post customer margin accounts
a. Current Problem: It needs to trim the way to find the customer margin of the ex-
post customer margin account so as not to provoke investors’ misunderstanding
because of its highly complicated method.
<Current method to find the customer margin of the ex-post customer margin accounts>
Object
The customer
margin
Deposit
Deadline
The domestic
qualified
institutional
investors
The foreign
qualified
institutional
investors
The account
with a new
trade on the
day*
Calculate and
apply the ex-post
customer
margin
Until 10 AM*** Open for trade Open for trade
From 10 AM Closed Closed unless it
is the public
holiday of
overseas banks
or submitted
with a copy of
the payment
instruction
The account
without a trade
or only with an
Calculate and
apply the
additional
Until 12 PM
Closed until the additional customer
margin is paid or the position is
From 12 PM
offsetting
trade**
customer margin closed out by reverse dealing
* Enforcement rules 146(Deposit of Ex-post Customer Margin), 148(-post Cash Deposit
Requirement)
** Enforcement rules 150(in Total Deposit), 151(Shortfall in Cash Deposit)
*** Anytime as members select prior to 10AM of the day or the following day
Status problem
Assortment by
characteristics of a
trade
- It is not clear enough to realize the benefit of dividing into the ex-
post/maintenance customer margin according to the types of orders
- It is not considered rational to adapt the ex-post customer margin to a
new trade from the investors holding a multiple number of the open
interests.
Level of
understanding
about the duty
- There arises a frequent dispute between members and institutional
investors because an order is not to be processed when the maintenance
customer margin is not enough. Most institutional investors
misunderstand that only the ex-post customer margin is adapted to the
ex-post customer margin accounts. But in fact, the maintenance
customer margin is adapted to it as well.
b. Improvement: For the ex-post customer margin accounts, only the ex-post
customer margin is applied, which means keeping the maintenance customer margin is
not required anymore.
The qualified institutional investors are only asked to pay the ex-post customer margin
by 10AM of the following day, minimizing confusion among members and investors.
It should be hardly burdensome since most of the qualified institutional investors retain
enough amounts of substitute securities more than the required margin.
< Modified way to find the customer margin of the ex-post customer margin accounts>
Object
The
Customer
margin
Deadline
The domestic
qualified
institutional
investors
The foreign qualified
institutional investors
All the ex-
post
customer
margin
accounts
Calculate
and apply
the ex-post
customer
margin
Until
10AM*
Open for trade Open for trade
From
10AM*
Closed Closed unless it is the public
holiday of overseas banks or
submitted with a copy of the
payment instruction
* Anytime as members select prior to 10AM of the day or the following day
“A Capital Market Partner Adding to Customer Value”
III. Future Plans
There will be an opportunity to share opinions in May, 2013
→ In May, 2013
<The scheduled enforcement dates of the management plan for algorithmic trading>
Assortment Detail The scheduled date
Risk
management
of
algorithmic
trading
- Register the algorithmic trading accounts to KRX Sep. 30th, 2013
- Set the cumulative order quantity limit Sep. 30th, 2013
- Take advantage of ‘the Kill Switch’
Feb. 3rd
, 2014
(The estimated
operational date of
‘Exture+’)
- Operate the automated order cancellation system Sep.30th, 2013
Excessive
order
management
- Restrict receiving excessive orders
Feb. 3rd
, 2014
(The estimated
operational date of
‘Exture+’)
- Impose an extra service charge for excessive orders Sep.30th, 2013
Risk
management
of the ex-
post
customer
margin
account
- Increase the management level of the risk exposure
amount
June. 24th, 2013
- Abolish the duty that requires the maintenance
customer margin in the ex-post customer margin
accounts
June. 24th, 2013
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