Lime Brokerage Applauds the SEC for Passing Rule 15c3-5 Banning 'Naked' Sponsored Access

By Lime Brokerage, PRNE
Tuesday, November 2, 2010

LimeInside customers already benefit from full pre-trade controls with added latency < 10 microseconds

NEW YORK, November 3, 2010 - Lime Brokerage LLC (www.limebrokerage.com), an independent
high-volume agency broker and leading provider of high-throughput,
low-latency technologies to the professional trading community, congratulates
the SEC for its decision today to ban the practice of unfiltered or 'naked'
sponsored access in the U.S. markets.

    (Logo: photos.prnewswire.com/prnh/20100324/NY75754 )
    (Logo: www.newscom.com/cgi-bin/prnh/20100324/NY75754 )

Lime has been an outspoken proponent of such a rule, which is needed to
limit the systemic risk that unchecked orders introduce into an increasingly
high-speed marketplace. Throughout its 10 year history, Lime has never
allowed naked sponsored access trading by its customers.

"LimeInside," Lime's exchange co-location solution, released in March
2010
and in active use by customers today, has been designed and implemented
to meet the outlined regulatory criteria, including pre-trade risk validation
requirements.

LimeInside's trading server adds less than 10 microseconds of latency to
an order while the total latency experienced by a trader from the moment they
send an order to when it is received by an exchange gateway is less than 20
microseconds. This demonstrates that pre-trade risk controls can be
implemented without compromising the strategies of even the most
latency-sensitive traders, while still complying with the requirements of
Rule 15c3-5.

Lime strongly supports the Commission's decision which clarifies that
monitoring risk solely through post-trade risk analysis via FIX drop-copies,
espoused by some market participants, is not sufficient to avert the
potential for systemic risk.

LimeInside's architecture is designed to reside on a separate and
distinct server from that of client systems, without an observable latency
impact, thus complying with the Commission's provision that risk controls be
under the "exclusive and direct control" of the regulated broker. Solutions
which combine client systems and broker risk controls onto one shared
hardware platform will have difficulty complying with this standard, as the
broker would lose "exclusive and direct control" of the server, compromising
the Commission's intent.

"The Commission's decision today clearly demonstrates its thoroughness,
leadership and vision on this critical issue and we're excited to see that it
validates the solution that we have already implemented which is consistent
with the regulatory mandates without sacrificing performance," states John
Jacobs
, Director of Operations at Lime Brokerage.

About Lime Brokerage

Providing customers with performance-engineered trading solutions that
deliver speed, scale and reliability is the hallmark of Lime Brokerage. Lime
integrates world-class advanced execution technology with clearing and
reporting services for seamless support of the most complex, automated and
high-volume electronic trading strategies. Our technology and trading
platform allows our customers to access an independent, agency-only system to
trade quickly, reliably and anonymously on multiple exchanges, ECNs and
trading venues. Clients include professional traders, hedge funds, asset
managers and broker-dealers. For more information about Lime Brokerage,
please visit www.limebrokerage.com or email info@limebrokerage.com.

    Media Contact:
    Mike Felix
    Lime Brokerage
    +1-212-824-5544
    mfelix@limebrokerage.com

Mike Felix, Lime Brokerage, +1-212-824-5544, mfelix at limebrokerage.com

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