  On market integrity and competition: Many of the “predatory” or “unfair” practices attributed to HFT, in light of their technology-driven ability to detect orders and take advantage of latencies, are in fact not new. HFT is but the latest high-tech, highspeed manifestation of them.   Turning to regulation, HFT in FX is subject to three levels of self-regulation.
In addition to HFT firms’ own risk controls, there is also monitoring by prime brokers. One significant concern we document in the report is whether the prime brokers are technologically capable of keeping up with their HFT clients or have the financial incentives to do so appropriately.