904-NMS-1220-15-F4.DOC
generated and booked. The same can also operate in reverse to
minimise a potential loss. Of course, these are utterly basic
examples. I imagine the actual models are far more sophisticated
and complicated, for use in complex scenarios for highly evolved
financial and security transactions. The point is, however, that
these trades are automatic and computer-generated, and they
happen at very high speed and in high volumes.
8.
The anonymous letter sent to SEBI and Ms. Dalal is a
lengthy dissertation on not only the evolution of online trading at
the NSE but also the very many pitfalls encountered in the last five
years or so. It points to the initial deployment of relatively lowbandwidth leased lines to multicast price streams and this is said to
have been done using a technology by then already deprecated so
that the information dissemination was sequential, thus allowing
the person or persons who first received the data to act on it well
before others downstream received the data. In the intial days,
traders were allowed to deploy the NSE’s application programming
interfaces or APIs to write their own programs. The system, so the
anonymous letter seems to say, was not designed for high traffic
volumes; and, given the sequential (as opposed to simultaneous)
dissemination of data (as might be achieved using the User
Datagram Protocol or UDP, for instance, as other exchanges even
then did), often meant that the last in line to be connected to the
data stream was often well behind the person who connected first.
The NSE then apparently had limited servers with unbalanced
loads, and this in turn generated what is called a latency (the time
required for transmission of data packets) for the last user. At the
time, this gave the first mover (or connector), who accessed a
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