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Update (9th Dec 2021)
Dear Sebi,Thank you for publishing the Consultation Paper on Algorithmic Trading by Retail Investors.I don't think adding a process of algo approval is scalable and will work in the long run. This is not an efficient solution to solve the 'Pump & Dump' problem.Instead of penalizing the start-up developers you can enforce precautionary rules. Here are some suggestions;warning messages and workflow on the broker side for the applicant of the API access and trading. Take consent from the trader with SMS Verification.Display statutory warning messages on the website or Mobile Apps It is literally impossible and unethical to impose stringent rules on small developers and retail traders who want to benefit from the new age Internet Technology to benefit the wealthy FII and High Frequency traders. Thanks,
"Brokers shall also deploy suitable technological tools to ensure that appropriate checks are in place to prevent unauthorized altering/tweaking of algos." (6.3)