The Commodity Futures Trading Commission (“CFTC”) has proposed a new rule — so-called Regulation AT — to regulate the use of automated, or algorithmic, trading systems that trade commodity interests (e.g., futures and swaps). The CFTC’s proposal comes at the end of a year that saw a noticeable increase of enforcement actions arising from disruptive trading practices, including spoofing and market manipulation, and which included the first criminal conviction for spoofing in U.S. v. Michael Coscia. In this Client Alert, we highlight the most significant aspects of Regulation AT. 1. A New Registration Mandate. Under Reg. AT, registration will…