In his May 5 post, available here, Stanislav Dolgopolov states that the Securities and Exchange Commission’s recent settlement with Citadel “undermines the so-called ‘Berkeley Study’ which concluded that off-exchange market makers can neither profitably engage in data feed arbitrage by ‘filling marketable orders at (or within) the SIP-generated NBBO [National Best Bid and Offer] . . . at stale prices to the disadvantage of retail investors’ nor ‘choose as their pricing benchmark the slower SIP-generated NBBO to boost their performance metrics.’” Mr. Dolgopolov further states that our study “skirted the fact that relevant strategies do not rely on choosing … Read more
The following post reproduces the text of a letter written by a group of corporate law professors at the University of California, Berkeley, School of Law in response to the U.S. Department of Health & Human Services’ request for comments on the definition of “eligible organization” in light of Burwell v. Hobby Lobby.
Dear Sir or Madam:
We are all professors of law at the University of California, Berkeley, School of Law, as well as specialists in the study and teaching of corporate law. This letter responds to the request published in the Federal Register on August 27, 2014 (the … Read more