The Securities and Exchange Commission (“SEC” or “Commission”) has proposed a new rule under the Securities Exchange Act of 1934, Rule 15 c3-5 (“Rule”), that would require brokers or dealers (hereinafter “broker-dealers”) with access to trading directly on an exchange or alternative trading system (“ATS”), including those providing direct or sponsored market access to customers or other persons, to establish, develop and maintain risk management controls and supervisory procedures reasonably designed to manage the financial, regulatory, and other risks of this business activity