circular letter direct market access (dma) – new trading … · in view of these purposes, the...

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July 8, 2008 021/2008-DP CIRCULAR LETTER To: The Clearing Members, Brokerage Houses and Other Participants of the Markets Managed by BM&FBOVESPA Re.: Direct Market Access (DMA) – New Trading Model. In May of 2008, BM&FBOVESPA successfully completed the development of the new version of the Global Trading System (GTS), concluding the process of gradual migration of the various contracts to the new environment. The new GTS was developed with the intent to offer not only robustness and efficiency, but also flexibility and a high degree of connectivity between the Exchange and its market participants for the purposes of: Facilitating the access of the various market participants to the electronic trading environment, in order to expand the power of distribution and the degree of capillarity for the products offered by BM&FBOVESPA; and Facilitating the integration between the systems offered by the Exchange and brokerage houses and those offered by independent software vendors (ISVs). In view of these purposes, the new GTS was developed based on the communication protocol called FIX (Financial Information eXchange), version 4.4. As an open communication protocol, FIX is currently the worldwide standard for electronic communication in the international financial markets, particularly in respect to the development of trading and order routing systems. In addition to the new GTS, another highlight is the implementation of side-by-side trading, whereby trading is simultaneously executed on the GTS electronic trading system and the floor for the more liquid derivatives contracts. In November of 2007 and April of 2008, the DI1 futures and the Ibovespa futures contracts, respectively, were authorized to be simultaneously traded. On July 1, 2008, the US Dollar futures contract was authorized for side-by-side trading. The current stage of development of BM&FBOVESPA, brokerage houses and, from a more ample perspective, the domestic financial market has created favorable conditions for the introduction and development of a direct market access (DMA) model, and of international order routing systems for the derivatives markets that were originally managed by BM&F. Such conditions exist mainly due to the following factors: From the technological standpoint, the completion of the development of the new GTS, the implementation of the FIX Protocol, and the degree of maturity and development of the ISV industry, which plays a key role in the process of dissemination and assimilation of new trading technologies;

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Page 1: CIRCULAR LETTER Direct Market Access (DMA) – New Trading … · In view of these purposes, the new GTS was developed based on the communication protocol called FIX (Financial Information

July 8, 2008 021/2008-DP

CIRCULAR LETTER To: The Clearing Members, Brokerage Houses and Other Participants of the Markets Managed by BM&FBOVESPA Re.: Direct Market Access (DMA) – New Trading Model. In May of 2008, BM&FBOVESPA successfully completed the development of the new version of the Global Trading System (GTS), concluding the process of gradual migration of the various contracts to the new environment. The new GTS was developed with the intent to offer not only robustness and efficiency, but also flexibility and a high degree of connectivity between the Exchange and its market participants for the purposes of: Facilitating the access of the various market participants to the electronic trading

environment, in order to expand the power of distribution and the degree of capillarity for the products offered by BM&FBOVESPA; and

Facilitating the integration between the systems offered by the Exchange and brokerage houses and those offered by independent software vendors (ISVs).

In view of these purposes, the new GTS was developed based on the communication protocol called FIX (Financial Information eXchange), version 4.4. As an open communication protocol, FIX is currently the worldwide standard for electronic communication in the international financial markets, particularly in respect to the development of trading and order routing systems. In addition to the new GTS, another highlight is the implementation of side-by-side trading, whereby trading is simultaneously executed on the GTS electronic trading system and the floor for the more liquid derivatives contracts. In November of 2007 and April of 2008, the DI1 futures and the Ibovespa futures contracts, respectively, were authorized to be simultaneously traded. On July 1, 2008, the US Dollar futures contract was authorized for side-by-side trading. The current stage of development of BM&FBOVESPA, brokerage houses and, from a more ample perspective, the domestic financial market has created favorable conditions for the introduction and development of a direct market access (DMA) model, and of international order routing systems for the derivatives markets that were originally managed by BM&F. Such conditions exist mainly due to the following factors: From the technological standpoint, the completion of the development of the new GTS,

the implementation of the FIX Protocol, and the degree of maturity and development of the ISV industry, which plays a key role in the process of dissemination and assimilation of new trading technologies;

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From the standpoint of the domestic market, the process of maturation and professionalization which the brokerage houses continue to pass through—in particular the results derived from the Operational Qualification Program (PQO)—and also the transformation process through which BM&FBOVESPA itself is currently passing; and

From the standpoint of the international market, the growing interest that investors from other countries have shown in the Brazilian market which has been strengthened all the more by Brazil’s investment grade rating, and also by the fact that the DMA model is already widely used by those investors at other exchanges.

1. General Characteristics of the BM&FBOVESPA DMA Model

The DMA model allows end customers to have direct access to the Exchange’s electronic trading environment. This access is granted by a brokerage house and maintained under its responsibility, allowing end customers to send their own orders to the trading system, as well as receive market data in real time, including the electronic trading system’s order book. In general terms, BM&FBOVESPA’s DMA model can be defined as follows:

Exchange trading model through which the broker, by means of a specific technological solution, offers one or more of its clients the possibility to: (i) Visualize, in real time, the electronic trading system’s order book; and (ii) Send orders, in electronic form, that, when complying with the limits and other

parameters established by the broker and/or the Exchange, are automatically transformed into bids/offers in the electronic trading system’s order book.

As explained below, the above mentioned definition is very general and admits DMA models with different forms and characteristics, provided, however, that a brokerage house be always responsible for the access granted to the client. Trading via the DMA model provides clients with important benefits, among which we highlight the following:

Greater operational autonomy, with increased control over the flow of insertion,

modification, cancellation and confirmation of their orders; Greater speed, thereby increasing the efficiency in trade execution and in capturing

market opportunities; Possibility of development of trading strategies based on computer programs, also

called automated trading systems (ATS) or algorithmic trading, which increase the capacity of investors to simultaneously analyze the price conditions for various contracts and various markets, with positive impact on the liquidity of the markets and on the process of price discovery for the various assets; and

Reduction in the frequency of operational errors (execution errors) and other problems related to orders issued directly to the brokerage house, as those orders will be inserted into the system directly by the customers.

The DMA model also presents important advantages and opportunities for the brokerage houses, among which are the following:

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The expansion in their distribution power, capillarity and customer service channels, with particular emphasis given to the higher degree of internationalization achieved by the Exchange and the great potential for volume growth as a result of order routing arrangements established with international exchanges;

The possibility of full automation of the order execution process, allowing for scale gains, cost reductions and better customer service; and

The possibility of offering clients new services and products, such as trading screens, proprietary networks for market access, program trading, among others, in line with the current international trends in the intermediation market.

In the following sections we present the rules, procedures and technical and operational characteristics to be offered by BM&FBOVESPA for the contracts traded on the GTS system.

2. Authorization for Utilization of the BM&FBOVESPA DMA Model

2.1 Authorization for Brokerage Houses Only the brokerage houses that sign the form entitled Term of Adhesion and Responsibility for the Provision of DMA Services will be authorized to grant direct access to their clients. This form will be disclosed by the Exchange as soon as the model described herein is approved by the Brazilian Securities and Exchange Commission (CVM). The brokerage houses must also provide an amendment to the financial intermediation agreement signed by the clients who will use the DMA model. In addition, the brokerage houses must also register, on the Exchange systems, the information required for the proper identification of their clients and the characterization of their form of access. Such information, which for all purposes will be included in the customer’s register, must be maintained up-to-date by the brokerage houses.

2.2 Authorization for Brokerage House Clients

The direct access to the BM&FBOVESPA derivatives markets may be offered to all investors (individuals, nonfinancial legal entities, financial institutions, investment funds, nonresident investors, etc) by the brokerage houses, which are exclusively responsible for granting or not granting said access. The rules and regulations defined by the Exchange and by the CVM, as well as by the regulatory institutions in the nonresident customers’ countries of origin must always be observed where applicable.

2.3 Market Data

The brokerage houses and the users of DMA services will receive, through these services, the GTS market data (including real-time data on the order book of the contracts traded on GTS). In a general manner and at the Exchange’s own discretion, the market data feed will be free of charge for all the terminals that are used for trading the Exchange contracts. Regarding the other terminals, which are only used for data visualization, the Exchange will establish a monthly market data fee. In this case, should a customer, a trading desk or an institution linked to a client use the terminals for the exclusive purpose of receiving and distributing the

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GTS market data without engaging in the corresponding trading activities, the relevant brokerage house will be required to sign the BM&FBOVESPA Market Data Licensing Agreement. The Exchange may establish mechanisms to identify whether a given terminal is used for the purposes of this Circular Letter or merely for data visualization. The Exchange reserves the right to alter, at any time, its commercial policy for market data feed. The brokerage houses that offer DMA to their clients must provide BM&FBOVESPA, on a monthly basis, with information regarding the number of terminals utilized in trading via direct access, subject to periodic audits by the Exchange.

3. Trading Models

For direct access to the GTS, BM&FBOVESPA will authorize the following DMA models, which may be selected by the participants—brokerage houses and customers—according to their needs and interests. We emphasize that the models are not exclusive, that is, a brokerage house may offer various access models, provided that they are made available by the Exchange. All models will always include a “logical link” between the customer and the brokerage house. A logical link is understood as a relationship whereby the brokerage house maintains (i) the capacity of interference and (ii) the responsibility for the orders and their resulting positions. To this end, through the system’s functionalities, the brokerage house responsible for a customer will be able to:

Authorize and suspend a customer’s access to the trading system; Define the customer’s operational limits, which must be verified before the orders

are accepted; Monitor, in real time, all submitted orders—with the possibility of rejecting them at

any time—and all the trades executed by the customer.

Further details about the technical terms mentioned below may be obtained in Section 8 of this Circular Letter.

3.1 Model 1 – Traditional DMA

This model consists in the routing of orders via the brokerage house’s technological infrastructure (physical), that is, the orders sent by the customer are transmitted through the brokerage house’s technological structure before they reach the GTS trading platform. This access model is illustrated in the figures below.

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Figure 1 – Traditional DMA

Figure 2 – Traditional DMA via a DMA Service Provider

Figure 1 illustrates the situation where the customer connects directly to the technological infrastructure of the brokerage house, which in turn connects to the Exchange. Figure 2 illustrates the situation where the customer connects to the DMA service provider (vendor, ISV, etc), which in turn connects to the brokerage house, which finally connects to the Exchange. This model requires brokerage houses to have their own order management system (OMS) to control the access of their clients. Section 11 of this Circular Letter provides information as to when the brokerage houses will be able to offer this access model to their clients.

3.2 Model 2 – DMA via a Provider

This model consists in the routing of orders via a technological infrastructure furnished by an order routing service provider (DMA provider). The logical link between the customer and the brokerage house is controlled by the systems of the Exchange and the DMA provider—since the messages sent by the customer are transmitted through the technological infrastructure of the DMA provider, and not through the brokerage house technological infrastructure. Figure 3 provides a representation of the access model.

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Figure 3 – DMA via a Provider

As can be seen in Figure 3, the customers connect to the DMA providers while these providers connect to the Exchange system. The DMA providers may have their hardware and software structure located within the Exchange’s data processing facilities, as indicated in the figure. As previously mentioned, through the system functionalities offered by the Exchange and by the DMA providers, the brokerage houses will be able to authorize and suspend the access of their clients, assign them operational limits, which will be verified before the orders are accepted, and provide real time monitoring of their orders and transactions. We emphasize that the order routing system under development by BM&FBOVESPA and by the CME Group represents a particular case of this model. In this case, international clients connect to the CME Group electronic trading system (Globex) and Globex connects directly to the GTS, thereby fulfilling the role of DMA providers. The rules and procedures relative to this order routing system will be disclosed in due time through a specific Circular Letter. Section 11 of this Circular Letter provides information as to when the brokerage houses will be able to offer this access model to their clients.

3.3 Model 3 – DMA via Direct Connection

This model consists in the transmission of customer orders via direct connection to the Exchange, without utilizing the technological infrastructures of brokerage houses or DMA providers. As in Model 2, the logical link is maintained between the customers and their corresponding brokerage houses, which establish operational limits and monitors their transactions. This access model is represented in Figure 4.

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Figure 4 – Direct Connection

Section 11 of this Circular Letter provides information as to when the brokerage houses will be able to offer this access model to their clients.

3.4 Model 4 – DMA via Direct Connection – Co-location

This model does not really represent an order routing process, since customer orders are generated through a software (ATS) installed in a computer/equipment that is hosted in a physical space made available by the Exchange. As in Models 2 and 3, the logical link between the customers and brokerage houses is maintained. Customers, on whose behalf the orders are transmitted, have remote access to their corresponding equipment, and are allowed to configure parameters and perform monitoring/management/maintenance functions. The access model is represented in Figure 5 below.

Figure 5 – DMA via Direct Connection – Co-location

Remote access for monitoring

and maintenance

GTS

BELLRCCF

BELL

FIXGateway

Application for Exchange hosting

BELLFIX

FIX FIX

DMA CLIENT

BROKERAGE HOUSE

BM&FBOVESPA

Network

Section 11 of this Circular Letter provides information as to when the brokerage houses will be able to offer this access model to their clients.

3.5 Other DMA Models

Due to the rapid evolution of technology and the increased number of functionalities relating to telecommunication networks, the international market provides many examples as to how to structure different types of DMA models. Besides the four models described in this Circular Letter, other DMA models may be structured according to: The telecommunication structure utilized for interlinking clients, brokers,

DMA providers, vendors and exchanges;

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The installation and utilization of OMS; and The installation and utilization of ATS.

Whenever necessary, BM&FBOVESPA will analyze other DMA models.

4. Responsibilities of Brokerage Houses and Clearing Members The adoption of a DMA model will not alter the current responsibilities attributed to the brokerage houses and clearing members by current legislation. Thus, the brokerage houses are responsible for the access of their clients to the trading system for all the orders sent by them directly or indirectly, as well as for all the trades originated from those orders. The responsibility of the brokerage houses for the orders sent by their customers is not dependent upon the means utilized for transmitting them (proprietary network, third-party network, ISV solution, etc.). As the parties responsible for the orders sent via DMA, the brokerage houses may modify or reject them, as well as prohibit the direct access of their customers to the trading system. The Exchange may also, for prudential reasons, prohibit the direct access of one or more brokerage house clients. As will be further detailed, BM&FBOVESPA will require those brokerage houses that offer their clients access via a DMA model to adopt pre-trade risk management practices. The trading rules currently applicable to the orders and trades originated in the electronic trading system will equally apply to the orders transmitted by means of a DMA model.

5. Risk Management by the Brokerage Houses

The brokerage houses must adopt pre-trade risk management practices to properly control the risk resulting from the transactions executed by their customers who use DMA services. To this end, the brokerage houses may (i) utilize the operational limit control tool GTS-LiNe developed and offered by BM&FBOVESPA; or (ii) utilize another tool, at their own discretion, that fulfills a similar role, always subject to the criteria, terms and conditions established by BM&FBOVESPA. The GTS-LiNe tool is a GTS module and its methodology is based on quantitative limits, or trading limits, attributed by a brokerage house to each client and master account. Thus, all orders sent directly by the customer to the GTS will be submitted to the exposure control mechanism based on the brokerage house pre-defined limits. This submission precedes the insertion of orders in the book and allows their rejection in the event of a violation to the existing limits. The brokerage houses will be responsible for attributing adequate credit limits for all of their clients, and BM&FBOVESPA may establish additional limits. Additional information about the GTS-LiNe will be disclosed in due time through a specific communication letter. The tool referred to in item (ii) must allow brokerage houses to establish, for each customer or master account, at least the following parameters:

The maximum risks for bids and offers per instrument; The maximum risks for long and short positions per instrument; and

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The maximum risks for long and short positions per instrument group.

The above-mentioned maximum risks may be measured in alternative forms: Quantity of contracts, financial exposure, financial risk, etc. Operationally, the tool must allow brokerage houses to: Establish trading parameters directly from the brokerage house application; Monitor, in real time, the utilization of the trading parameters; and Alter, in real time, the trading parameters.

Without prejudice to the aspects related to control, pre-trade and operational limits, the brokerage houses must also develop, at their own discretion, post-trade risk management models.

6. Risk Management by the Derivatives Clearinghouse

The adoption of the DMA model will not imply an alteration to current Derivatives Clearinghouse risk management procedures, criteria and rules. Therefore, there will be no differentiation, for the purposes of calculating the participant’s portfolio risk, the margin requirements and the control of operational limits, between trades originated from orders transmitted via DMA and via another form of access. Similarly, the Derivatives Clearinghouse intraday risk management will not be altered. The risk attributed to each brokerage house will be calculated in accordance with current risk calculation criteria for allocated and non-allocated trades.

7. Other Procedures Related to Trading, Registration and Settlement Subsections 7.1, 7.2 and 7.3 below describe the inclusion of certain information in the electronic message. The inclusion must be done in accordance with the specification available in the document entitled BELL – BM&FBOVESPA Electronic Link – FIX Rules of Engagement.

7.1 Information about Direct Access and ATS Utilization All the orders transmitted via DMA must include in the corresponding message

the form of access. Program trading must also be marked as such in the message for all the orders

transmitted via ATS. We emphasize that the utilization of ATS, in any event, will be conditioned upon certification by the Exchange.

7.2 Customer Allocation The trades originated from orders transmitted via DMA must be allocated upon

their execution. To this end, the orders transmitted via DMA must mandatorily include:

A customer or PLD account code; or A master account code, in the case of funds, equity pools, managed portfolios

and nonresident investors whose accounts are linked to a master account, pursuant to Circular Letter Circular 016/2008-DP, of June 30, 2008.

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We would also like to emphasize that: The trades resulting from a DMA-submitted order whose account

identification is later proved to be invalid will be blocked on the system and assigned to the executing brokerage house. In this case, only the Derivatives Clearinghouse will be able to allocate the trade, provided a request is submitted by the brokerage house, including the corresponding justification; and

The other procedures and rules related to trade allocation will remain unchanged.

Trades resulting from orders transmitted via DMA by customers whose accounts are linked to a master account will be subject to the procedures, criteria and rules currently in force for master accounts, pursuant to Circular Letter 016/2008-DP.

7.3 Give-up and PLD Assignment

Give-up For give-up trades originated from orders transmitted directly by the customer, the Exchange will require the registration of the customer by both institutions (executing brokerage house and carrying brokerage house), the formalization of the corresponding contractual arrangements, and the registration of the customer at the Exchange as a customer of both brokerage houses. The client may adopt a single instrument that incorporates the three parties involved. The FIX specification utilized by GTS allows for the indication of a “give-up link” in the order message itself. Therefore, the customers using a DMA model provided by an executing brokerage house must include, in the order itself, the give-up link number giving up the trade to a carrying brokerage house, thereby automating the above-mentioned procedure. In this case, the following will apply: (i) The give-up link number in the message must be connected to a customer

account (and/or a master account) at the carrying broker, as described in Circular Letter Circular 016/2008-DP, observing that the order belongs to the DMA client that is sending it;

(ii) The give-up link number provided in the message replaces the account at the executing broker (customer account, PLD/master account link), as referred to in Subsection 7.2; and

(iii) If both the account information and the give-up link information are included in the message, the latter will prevail.

If the give-up link number included in the message is invalid or the give-up is rejected, the trade will remain non-allocated, assigned to the executing brokerage house and not subject to any intervention. In this situation, pursuant to the corresponding timetable restrictions, the executing brokerage house must request the Derivatives Clearinghouse to: (a) Allocate the trade to an account held by the same customer who sent the

order; or

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(b) Repeat the give-up by using the valid link that was originally indicated in the message.

The full responsibility for the registration of the account to be used for a trade allocation on the BM&FBOVESPA systems, under the situation described in item (a) above, belongs to the executing brokerage house, which must take all the necessary actions to effect said allocation within the established time frame. PLD Assignment To assign a PLD, the account at the executing brokerage house with a PLD link must be provided in the message. This link must be registered under the auto-allocation type or have a master account as its destination. If the PLD link is rejected, the trade will remain non-specified, assigned to the executing brokerage house and not subject to any intervention. In this case, pursuant to the corresponding time frame restrictions, the executing brokerage house must request the Derivatives Clearinghouse to: (a) Allocate the trade to an account held by the same customer who holds the

PLD account; or (b) Repeat the PLD assignment by using the valid link that was originally

indicated in the message.

The full responsibility for the registration of the account to be used for a PLD assignment on the BM&FBOVESPA systems, under the situation described in item (a) above, belongs to the executing brokerage house, which must take all the necessary actions to effect said assignment within the established time frame. The orders transmitted via DMA not containing at least one of the requirements that are necessary to identify the trade holder, as described in Subsections 7.2 and 7.3—namely, customer or master account, and PLD or give-up link—will be automatically rejected by the GTS.

7.4 GTS Licensing Model for DMA

GTS access via DMA will follow a specific licensing model which is different from the licensing model currently in force for access via brokerage house trading desk. The licensing model for DMA is based on the FIX session, sender location, entering firm and entering trader IDs, which must be mandatorily informed in all messages transmitted via DMA. The FIX session and sender location IDs are registered by BM&FBOVESPA when the FIX connection is established between the brokerage house and the GTS for trading via DMA. The entering firm code corresponds to the brokerage house number registered at the Exchange. The entering trader code identifies the executing trader, that is, the GTS user that inserts orders into the system. This code, which is not informed to the Exchange, must be registered by the brokerage house, on the OMS designated by it for trading via DMA, for each customer to whom it grants direct access. The

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brokerage house has full responsibility for the registration of the entering trader codes, as well as for controlling their utilization. The utilization of codes for entering firm, sender location ID and entering trader must abide by the rules described in sections “order management” and “DMA identification” in the document BELL – BM&FBOVESPA Electronic Link – FIX Rules of Engagement.

7.5 Trading on Behalf

In the case of participants operating under the subaccount structure—“intermediaries trading on behalf” and their customers—the brokerage houses may grant direct access to these intermediaries trading on behalf, but the latter cannot extend this right to the clients on whose behalf they trade. The adoption of a DMA model by the intermediaries trading on behalf does not alter the current responsibilities attributed to them.

8. Technology and Connectivity

The solution offered by the Exchange to connect to the new GTS for the purposes of trading, routing orders and feeding market data is called BELL – BM&FBOVESPA Electronic Link. According to Circular Letter 020/2008-DP, of July 8, 2008, in order to utilize the BELL – BM&FBOVESPA Electronic Link and have full access to the functionalities of the new GTS, the technological solutions for connectivity between the users’ platforms and the Exchange must be developed in strict compliance with the rules described in the document BELL – BM&FBOVESPA Electronic Link – FIX Rules of Engagement, and must be certified by the Exchange. The list of certified solutions is available on the Exchange Website at www.bmf.com.br/novogts, under the certification section. The Exchange certification applies to the technological solution, not to the participant that intends to utilize it. Thus, a solution offered by an ISV and certified by the Exchange may be utilized by market participants without the need to obtain an additional certification for each participant. It is important to note that all brokerage houses offering DMA to their clients must have an adequate infrastructure (hardware, software, network and support) to support the selected application.

9. Messaging Policy

In order to stimulate trading participants to follow an appropriate conduct in relation to the volume of orders sent to the trading system, BM&FBOVESPA will define a messaging policy for the flow of orders submitted to the GTS. An excessive volume of messages submitted to the trading platform may hamper the system’s performance and, consequently, affect the market participants in general. Aiming to prevent the abusive submission of an excessive volume of messages, the messaging policy establishes not only limits for the quantity of order messages, but also fees for the participants that fail to comply with the policy requirements. The messaging policy will be further explained in the future through a specific Circular Letter.

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10. BM&FBOVESPA Control Center (CCB) In view of the growing electronification of the BM&FBOVESPA derivatives markets, the adoption of the DMA model and the implementation of international order routing arrangements, and with the purpose of enhancing the services provided to GTS users, the Exchange created the BM&FBOVESPA Control Center (CCB), whose main function is to provide support and monitoring services to the electronic trading environment. CCB will provide direct services to the brokerage houses and, upon their authorization, to the clients using the DMA model. Therefore, CCB’s main activities will be to:

Provide immediate services to the GTS users when trading electronically, including

status, cancellation and traceability of orders, as well as trade flow monitoring; Clarify users’ questions about the GTS, the support tools related to electronic

trading and the BM&FBOVESPA markets in general; Monitor the technological environment related to electronic trading, which includes

the network monitoring, match engine, international order routing systems connected to the Exchange, processing capacity, message flow, ATS clients, etc;

Inform the GTS users about exceptional working situations/conditions; Manage the GTS messaging policy; and Suspend for prudential reasons the direct access of one or more participants.

11. Implementation Timetable for the DMA Models

The table below provides information about the implementation timetable for the four DMA models discussed in Section 3 of this Circular Letter.

Model Estimated Timetable

Model 1 – Traditional DMA

The technical conditions for the implementation of Model 1 have been concluded. Several brokerage houses and ISVs have successfully completed the certification of their technological solutions in relation to the GTS FIX (BELL – BM&FBOVESPA Electronic Link). The launch is contingent exclusively on the approval by CVM, which is reviewing the request submitted by BM&FBOVESPA. We estimate that the launch will take place between July and August of 2008.

Model 2 – DMA via a Provider

The technical conditions for the implementation of Model 2 have been concluded. BM&FBOVESPA is negotiating with several international DMA providers with the purpose of connecting their systems to the GTS. The launch of Model 2 is contingent on CVM approval and also on the time frame required by the DMA providers for the connection of their systems to the GTS. We estimate that at least two providers will initiate their activities in the second semester of 2008.

Model 2 – DMA via a Provider (CME Globex)

The connection of the CME Globex system to the GTS system is under development. We estimate that the new system will be launched in September 2008.

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Model Estimated Timetable /Model 3 – DMA via Direct Connection

Launch estimated for 2009.

Model 4 – DMA via Direct Connection – Co-location

Launch estimated for 2009.

12. Checklist for DMA Model Implementation by the Brokerage Houses

The brokerage houses that wish to obtain authorization for the implementation of DMA Model 1 (Traditional DMA) must follow the checklist below. Although the checklist involves several BM&FBOVESPA areas, the implementation process, which will be available as of the publication date of this Circular Letter, must be initiated through the Business Development Office and follow the steps below:

(i) Delivery of a letter to BM&FBOVESPA (Business Development Office at Praça

Antonio Prado, 48, 6th floor, ZIP Code 01010-901, São Paulo, SP) to request authorization for the development of DMA Model 1, including a description of the technological solution to be utilized, particularly a description of the network environment, the trading screens, the OMS and the pre-trade risk management);

(ii) Upon the delivery of the aforementioned letter, a meeting must be scheduled, through the Business Development Office, between the representatives of both the brokerage house and BM&FBOVESPA. At the meeting, the brokerage house must present its proposed DMA model. The meeting should be used to answer any questions about the DMA implementation process, the rules established by the Exchange, and the elaboration of a detailed implementation checklist;

(iii) Certification of the technological solution to be used by the brokerage house for order routing, pursuant to Circular Letter 020/2008-DP (applicable only if the aforementioned solution is not yet certified);

(iv) Submission of the Term of Adhesion and Responsibility for the Provision of DMA Services to the BM&FBOVESPA Participant Registration Center;

(v) Amendment to the financial intermediation agreements for the clients that will use the DMA services;

(vi) Delivery of the BM&FBOVESPA Market Data Licensing Agreement to the Exchange, when applicable;

(vii) If the brokerage house decides to utilize a proprietary solution for pre-trade risk control, it must schedule a meeting with the BM&FBOVESPA Audit Office for assessment of the solution;

(viii) Registration, on the Exchange systems, of the customers using the DMA model and the FIX session IDs used by those clients and the DMA clients who also use ATS; and

(ix) Upon completion of the process, BM&FBOVESPA may disclose to the market, through a Circular Letter, the Internet or another media, the authorization granted to the brokerage house for development of the DMA Model 1.

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Page 15: CIRCULAR LETTER Direct Market Access (DMA) – New Trading … · In view of these purposes, the new GTS was developed based on the communication protocol called FIX (Financial Information

Further information may be obtained from the Business Development Office by the following e-mail: [email protected]. Renato Mercadante Mortari Cícero Augusto Vieira Neto Acting Chief Executive Office Executive Officer

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