Fact-checked by Grok 2 weeks ago
References
-
[1]
SEC Adopts New Rule Preventing Unfiltered Market AccessNov 3, 2010 · When the customer is provided with access to an exchange or ATS using the broker-dealer's MPID, the arrangement is known as “direct market ...Missing: definition | Show results with:definition
-
[2]
[PDF] Guidelines for Direct Market Access and Sponsored Access | NasdaqJan 4, 2016 · SA refers to arrangements where a member permits a client to transmit orders electronically in the member's identity directly from the client's ...
-
[3]
Risk Management Controls for Brokers or Dealers With Market AccessJan 26, 2010 · The proposed definition is intentionally broad, so as to include not only direct market ... Under the proposed rule, market access means access to ...
-
[4]
SEC Proposes New Rule to Effectively Prohibit Unfiltered Access ...Jan 13, 2010 · Under this arrangement known as "direct market access" or "sponsored access," the customer can sometimes place an order that flows directly ...Missing: definition | Show results with:definition
-
[5]
17 CFR § 38.607 - Direct access. - Law.Cornell.EduDirect access allows customers to enter orders directly into a contract market's system. It requires systems and controls for FCMs to manage financial risk.Missing: definition | Show results with:definition
-
[6]
17 CFR 240.15c3-5 -- Risk management controls for brokers ... - eCFR(b) A broker or dealer with market access, or that provides a customer or any other person with access to an exchange or alternative trading system through ...Missing: definition | Show results with:definition
-
[7]
Direct Market Access (DMA) - Overview, How It Works, UsersAdvantages of Direct Market Access There are low risks of the investor's confidential information (i.e., name, address, bank account number) getting leaked, as ...
-
[8]
What is Direct Market Access (DMA) Trading Online? - Saxo BankDirect market access (DMA) trading is the process of placing orders directly with an exchange. DMA trading is available for a variety of financial instruments, ...Missing: principles | Show results with:principles
- [9]
-
[10]
[PDF] FR08/10 Principles for Direct Electronic Access to Markets - IOSCO3 Efficient access to the markets is therefore critical to Institute members. To achieve the most efficient access, mutual funds often enter into direct.
-
[11]
[PDF] Risk Management Controls for Brokers or Dealers with Market AccessNov 3, 2010 · customers direct market access or sponsored access, the broker-dealer with market access is legally responsible for all trading activity ...
-
[12]
What is Direct Market Access (DMA) in Trading? - IG | IG InternationalDirect market access (DMA) enables traders to deal directly onto the order books of major exchanges. Learn more about DMA and how you can access it today.
-
[13]
Risk Management Controls for Brokers or Dealers With Market AccessApr 7, 2023 · Rule 15c3-5 will require brokers or dealers with access to trading securities directly on an exchange or alternative trading system (ATS).
-
[14]
Direct-Access Broker: What It Means, How It Works, ExampleA direct-access broker is a stockbroker that concentrates on speed and order execution—unlike a full-service broker focused on research and advice.Missing: models distinction
-
[15]
What is direct market access (DMA)? | Databento Microstructure GuideDirect market access (DMA) enables market participants to send orders directly to a trading venue or counterparty, bypassing broker intermediation.
-
[16]
Direct Market Access vs. Retail Trading - What's the Difference?Oct 24, 2023 · DMA gives direct market access, while retail trades use intermediaries. DMA allows traders to select market makers, unlike retail where brokers ...Missing: traditional | Show results with:traditional
-
[17]
Direct Market Access Vs. Retail Trading – What's the DifferenceOct 11, 2021 · DMA orders go directly to the market, while retail orders go through an intermediary broker. DMA allows choosing the specific exchange for ...Missing: distinction | Show results with:distinction
-
[18]
Direct Market Access Explained: Why Pro Traders Prefer DMAAug 21, 2025 · Direct Market Access gives traders speed, transparency, and control. Discover why pro traders prefer DMA over traditional brokerage ...
-
[19]
Building a DMA Trading Platform: Everything You Should KnowJul 30, 2025 · Key Takeaways · DMA, or Direct Market Access, enables traders to access financial markets directly without interference from the dealing desk.Missing: principles | Show results with:principles
-
[20]
Direct Market Access Trading Fundamentals - MagmioDirect Market Access (DMA) lets traders place orders directly on the exchange. No broker interference, virtually no delays. With DMA, you see the live order ...
-
[21]
Electronic communications network - MarketsWikiAug 30, 2024 · The concept of ECNs dates back to the late 1960s with the creation of Instinet, the first ECN. However, it was not until the 1990s, with the ...
-
[22]
Direct market access for exchange-traded derivativesDirect market access grew up out of the equities market in the late 1990s,in particular when the number of electronic marketplaces, or ECNs, for trading stocks ...Missing: origins | Show results with:origins
-
[23]
Special Study: ECNs and After-Hours Trading - SEC.govMar 17, 2006 · Of special note are the recent growth of alternative trading systems known as Electronic Communications Networks ("ECNs") and the increased ...<|separator|>
-
[24]
Direct Market Access in Exchange-Traded FX Derivatives - ExegyThe growth of DMA can be traced back to 1992, when CME launched its Globex electronic trading platform and when the FIX protocol was first established to ...Missing: origins history
-
[25]
Direct market access: Explained | TIOmarketsJul 4, 2024 · With its speed, efficiency, and transparency, DMA has the potential to enhance trading performance and improve market outcomes.
-
[26]
DATs - Direct Access Trading systems - MarketsWikiSep 29, 2025 · The proliferation of direct access was driven by advances in network technology, regulatory changes encouraging market transparency, and the ...
-
[27]
[PDF] Final Rule: Regulation NMS - SEC.govThe Commission is adopting Regulation NMS, a series of initiatives designed to modernize and strengthen the national market system ("NMS") for equity securities ...
-
[28]
The Evolution of Direct Market Access (DMA) Trading Services in the ...Mar 13, 2008 · Through direct connectivity to market venues, DMA allows faster and cheaper trading so that firms can focus on creative strategies to extract ...Missing: origins history
-
[29]
History of Day Trading - QuantifiedStrategies.comSep 25, 2024 · This deregulation resulted in a dramatic drop in commission costs, from over 80 cents per share to about four cents by the early 2000s. The ...
-
[30]
[PDF] Understanding the Impact of MiFID - London EconomicsSince its EU-wide implementation in November 2007, MiFID has had a profound impact on secondary markets for equity, resulting in significant entry into the ...
-
[31]
2000-2009: The decade of electronic trading - The TRADEDec 23, 2009 · The noughties was a decade that revolutionised how the buy-side executed trades in the global equity markets.
-
[32]
[PDF] The Flash Crash: The Impact of High Frequency Trading on an ...May 5, 2014 · ABSTRACT. This study offers an empirical analysis of the events of May 6, 2010, that became known as the Flash Crash. We show that High ...
-
[33]
Equities trading focus : Pre-trade risk controls : Atif ZuberiApr 27, 2015 · After the 2010 DJIA crash, US regulators concluded that the remedy was to mandate controls on use of automated trade execution in a broker- ...
-
[34]
SEC approves rule banning “naked access” to trading centersAug 6, 2025 · ... 15c3‐5, which will require broker‐dealers to adopt and implement risk controls to govern their provision of “direct market access” (DMA).<|separator|>
-
[35]
CFTC shifts sights to DMA rules - The TRADEAug 6, 2013 · The leading US derivatives regulator will push for new direct market access (DMA) rules to meet what it sees as a growing need to control ...
-
[36]
[PDF] Research Briefing: High-frequency tradingMay 24, 2016 · In Europe, the share of HFT in total equity trading surged virtually from zero in 2005 to around 40% in 2010. In the US, already 20% of the ...Missing: DMA | Show results with:DMA<|separator|>
-
[37]
[PDF] MiFID 2 – Algorithmic & High Frequency Trading | AFMEAFME welcomes the attention the European Commission (“the Commission”) has devoted to algorithmic and high frequency trading in its review of MiFID.
-
[38]
[PDF] High-Frequency Trading and Market QualityGreater HFT participation improves market quality, but aggressive trading can negatively affect it. Market-making by HFTs outweighs the negative effects.<|separator|>
- [39]
-
[40]
Direct Market Access (DMA): Understanding Uses and Key BenefitsSep 5, 2025 · Direct Market Access (DMA) allows traders direct electronic access to financial exchanges, bypassing broker intermediaries. Sell-side firms ...
-
[41]
Quantifying Ultra Low Latency DMA (ULLDMA) and Low ... - OnixSJul 14, 2020 · We discuss the differences between Ultra Low Latency DMA (ULLDMA) and Low Latency DMA (LLDMA) in quantifiable terms.Missing: variants | Show results with:variants
-
[42]
Achieving Ultra-Low Latency in Trading Infrastructure - ExegyThis article outlines common technology, networking, and trading strategy decisions firms need to achieve ultra-low latency.Missing: variants | Show results with:variants
-
[43]
Reaching Ultra Low Latency in Trading InfrastructureLatency-dependent firms can reduce tick-to-trade latency through co-location, connect with direct exchange feeds, reduce network switches, and implement FPGA- ...
-
[44]
What Is Ultra-Low Latency in Trading? - BSO-NetworkApr 25, 2024 · Achieving ultra-low latency requires a combination of optimised infrastructure, efficient data transmission, and proximity to exchanges.<|separator|>
-
[45]
Regulatory Notice 13-38 | FINRA.orgNov 1, 2013 · A sponsored access arrangement is defined as one "where a broker-dealer permits a customer to enter orders into a trading center without using ...
-
[46]
Sponsored Access Comes of Age sec nasdaq - Traders MagazineSponsored access refers generally to a broker-dealer member of an exchange providing other market participants with access to that market center. This type of ...
-
[47]
[PDF] MIT 701 – Guide to Sponsored Access - London Stock ExchangeJun 14, 2023 · Sponsored Access is defined as a direct technical connection that enables a non-Member Firm (the Sponsored. User) to access London Stock ...
-
[48]
[PDF] Direct Market Access, Sponsored Access and Automated Order ...10.3 Orders placed through Sponsored Access shall be identified with one specific trader ID, that is used solely for each Sponsored Access client and ...
-
[49]
Market Access | FINRA.orgAccess to trading in securities on an exchange or alternative trading system as a result of being a member or subscriber of the exchange or alternative trading ...
-
[50]
MiFID II – the new regime for direct electronic access | PerspectivesNov 1, 2016 · There are two types of DEA: direct market access (DMA) and sponsored access (SA). DMA is an arrangement where a member of a trading venue ...
-
[51]
4.2 Direct Market Access and Sponsored Access - SGX RuleBooksA Trading Member that authorises Direct Market Access (including Sponsored Access) for a customer must enter into a legally binding agreement with the customer.
-
[52]
[PDF] Regulatory Notice 13-38 - finraNov 1, 2013 · A sponsored access arrangement is defined as one “where a broker-dealer permits a customer to enter orders into a trading center without using ...<|separator|>
-
[53]
What is DMA (Direct Market Access) Trading? - B2BrokerMay 20, 2025 · DMA(Direct Market Access) represents an electronic trading architecture that empowers investors, particularly institutions and trading professionals.<|separator|>
-
[54]
Alpaca Launches Direct Market Access Gateway and Advanced ...Aug 21, 2025 · With DMA Gateway, you gain the flexibility to control and specify the execution exchange for your orders (NASDAQ, ARCA, NYSE). This means ...
-
[55]
Direct Market Access | London Stock ExchangeA service called Direct Market Access (DMA), which allows you to place your orders directly on our order books in the same way that institutional investors do.
-
[56]
Trading & Markets Frequently Asked Questions - SEC.govApr 15, 2014 · Broker-dealers with market access are obligated under this Rule to establish, document, and maintain a system of risk management controls and supervisory ...
-
[57]
[PDF] UNDERSTANDING THE SEC MARKET ACCESS RULESecurities Exchange Act Release No. 40354 (August 24, 1998), 63 FR 46264 (August 31, 1998) (NASD NTM- 98–66). The Commission notes that brokers- dealers ...
-
[58]
FINRA focusing on Direct Market Access in 2024 — Are you?Mar 4, 2024 · Most broker-dealers utilize multiple systems and platforms for direct market access. Such systems' records and data should be aggregated and ...
-
[59]
Best DMA Brokers [Direct Market Access] With 2025 UpdateSep 30, 2025 · Direct Market Access (DMA) offers traders direct access to the order books of central market exchanges. Forex brokers with DMA have greater ...
-
[60]
What is Direct Market Access (DMA)? - OnixSMay 26, 2022 · DMA refers to electronic trading where the investors can directly execute the trading activity by interacting through an electronic order book.Missing: history | Show results with:history
-
[61]
Forex DMA | Forex Direct Market Access | IG InternationalForex Direct provides DMA execution with full market transparency. Direct market access forex trading offers high liquidity, fast execution, better pricing.
-
[62]
[PDF] Federal Register: Regulation Automated TradingNov 27, 2015 · Release, the Commission defined DMA as a connection method that enables a market participant to transmit orders to a trading platform ...
-
[63]
What is CME Direct? | Databento Microstructure GuideCME Direct is an interface for trading futures, options, and OTC-cleared products, with direct market access to CME Globex.
-
[64]
CME DirectAccess the only liquid Weekly options market for Crude Oil. Easily see all listed options for an underlying futures contract with the Quick Options Grid.
-
[65]
Direct Market Access - DMA Platform - ExegyExegy's Direct Market Access (DMA) Platform, an order routing network, offers low-latency DMA trading for major futures and options markets.
-
[66]
[PDF] The Futures and Options Association Guidance on Managing the ...(b) Sponsored access whereby an intermediary, who is a market member, may permit its clients to use its market member ID to send orders directly to the market ...
-
[67]
[PDF] Guidance Note - Direct Market Access (NSE Derivatives Market)DMA benefits investors by allowing for faster trade execution and a greater degree of control over trading. The investor is also able to mitigate risks ...
-
[68]
[PDF] Low latency trading and the comovement of order flow, prices, and ...Apr 4, 2014 · We examine the impact of algorithmic trading (AT) in equities on the comovement of order flow, returns, liquidity, and volatility to assess ...<|control11|><|separator|>
-
[69]
[PDF] Algorithmic Trading and Market Quality: International Evidence12 Other possible instruments include the introduction of direct market access for traders, DMA, or other updates to the trading protocol that imply a ...Missing: explanation | Show results with:explanation
-
[70]
NoneError: Could not load webpage.<|separator|>
-
[71]
[PDF] Wedbush Securities - NYSE ArcaDec 1, 2015 · Respondent failed to take reasonable steps to avoid submission of direct market access and sponsored access orders that resulted in locked and.
-
[72]
Six Exchanges Collectively Fine Merrill Lynch $3 Million for Violating ...Sep 26, 2016 · The firm failed to establish a capital threshold for two of its trading desks by the November 30, 2011 compliance date, and failed to fully ...Missing: failures | Show results with:failures
-
[73]
Credit Suisse to Pay $6.5 Mln for Direct Market-Access ViolationsDec 23, 2019 · Finra and several exchanges say the Swiss bank failed to adequately review potentially manipulative activity by broker-dealers and other ...Missing: examples | Show results with:examples
-
[74]
Market Watch 73 | FCAApr 26, 2023 · These include order-based manipulation where clients have direct market access (DMA), indirect manipulation through firms' hedging activities ...
-
[75]
High-Frequency Trading and Systemic Risk: A Structured Review of Findings and PoliciesSummary of each segment:
-
[76]
[PDF] Risk and Return in High Frequency Trading*As shown earlier, HFT risk is low, both in terms of systematic risk (as evidenced by the high alphas) and total risk (as evidenced by Sharpe ratios).
-
[77]
[PDF] Low-latency trading - NYU SternWe define low-latency activity as strategies that respond to market events in the millisecond environment, the hallmark of proprietary trading by ...
-
[78]
High Frequency Market Making to Large Institutional TradesFeb 28, 2015 · Our evidence indicates that high-frequency trading is associated with lower transaction costs for small, uninformed trades and higher ...Missing: DMA reducing
-
[79]
[PDF] FI report - Investigation into high frequency and algorithmic tradingExisting research also indicates that the impact of high frequency trad- ing on financial stability is still limited. The higher degree of complexity and the ...
-
[80]
[PDF] Findings Regarding the Market Events of May 6, 2010 - SEC.govMay 6, 2010 · This is a report of the findings by the staffs of the U.S. Commodity Futures Trading. Commission and the U.S. Securities and Exchange Commission ...
-
[81]
Knight Capital posts $389.9 million loss on trading glitch - ReutersOct 17, 2012 · Knight Capital Group reported a third-quarter net loss due to a glitch on August 1 that forced the electronic trader to take on additional investors to avoid ...Missing: DMA | Show results with:DMA
-
[82]
Knight Capital Says Trading Glitch Cost It $440 Million - DealBookAug 2, 2012 · Knight Capital Says Trading Glitch Cost It $440 Million · Runaway Trades Spread Turmoil Across Wall St. · Related Links.Missing: DMA | Show results with:DMA
-
[83]
Rule 15c3-5 - Risk Management Controls for Brokers or Dealers ...Jan 6, 2011 · Rule 15c3-5 requires broker-dealers with market access to establish, document, and maintain a system for regularly reviewing the effectiveness ...
-
[84]
17 CFR § 240.15c3-5 - Risk management controls for brokers or ...Brokers/dealers must establish risk management controls, including financial and regulatory controls, to manage risks from market access. These controls must ...
-
[85]
Market Access Rule | FINRA.orgThe Market Access Rule applies generally to securities traded on an exchange or alternative trading system, including equities, equity options, exchange-traded ...
-
[86]
[PDF] MiFID II Review Report - | European Securities and Markets AuthoritySep 28, 2021 · Notification of DEA users to NCAs. Background. 98. Under Article 17(5) of MiFID II, an investment firm that provides direct electronic access.
-
[87]
Direct electronic access - AFMUnder MiFID II, proprietary traders who have direct electronic access to a trading venue are in principle required to have a licence and must satisfy ongoing ...
-
[88]
MAR 7A.4 Requirements when providing direct electronic accessJan 1, 2021 · (1). A firm must monitor the transactions made by clients using the service to identify: (a). infringements of the rules of the trading venue; ...
-
[89]
Market Access Rule | FINRA.orgThe Market Access Rule applies generally to securities traded on an exchange or alternative trading system, including equities, equity options, ETFs, debt ...Missing: core | Show results with:core
-
[90]
[PDF] 33-11351.pdf - SEC.govJan 10, 2025 · Liquidnet violated Rule 15c3-5(b) by failing to establish, document, and maintain a system of risk management controls and supervisory ...
-
[91]
Market Access Rule | FINRA.orgThe Market Access Rule applies generally to securities traded on an exchange or alternative trading system, including equities, equity options, ETFs, debt ...Missing: 2020-2025 | Show results with:2020-2025
-
[92]
[PDF] 2025 FINRA Annual Regulatory Oversight ReportJan 1, 2025 · The Report reflects FINRA's commitment to providing transparency to firms and the public about our regulatory observations and activities.
-
[93]
Morgan Stanley Reaches Settlement with FINRA over Market ...Nov 5, 2024 · Morgan Stanley agreed to a settlement for alleged rule violations related to market access controls—an agreement that, if accepted, would shield ...
-
[94]
FINRA fines broker $165K for lack of supervisory controls ... - InfoBytesAug 23, 2024 · FINRA fines broker $165K for lack of supervisory controls and market access rule violations ... The broker also allegedly violated Section 15(c)3- ...Missing: enforcement | Show results with:enforcement
- [95]
-
[96]
ESMA concludes CSA on pre-trade controls under MIFID IIJul 3, 2025 · On 2 July 2025, the European Securities and Markets Authority (ESMA) issued a press release stating that it had recently concluded a common supervisory action ...Missing: DMA | Show results with:DMA
-
[97]
Effects of Algorithmic Trading on Liquidity in Futures MarketsAug 10, 2025 · This study breaks new ground to provide empirical evidence for the positive effects of AT on liquidity in the US. futures markets. To analyze ...Missing: benefits | Show results with:benefits
-
[98]
Fast traders make a quick buck: The role of speed in liquidity provisionOne shift that has engendered this heterogeneity is direct market access, which allows traders to have very fine control over their limit orders, effectively ...
-
[99]
[PDF] High Frequency Trading and Ghost Liquidity* - HALIn a world of fragmented trading, the replication of orders across venues leads measured liquidity to overstate true liquidity. ... Direct Market Access. (DMA).
-
[100]
[PDF] Evidence from the SEC naked access banAug 4, 2015 · In spite of the reduction in market activity, there is no adverse effect on liquidity. In fact, liquidity improves, with quoted spreads.
-
[101]
Attention: How high-frequency trading improves price efficiency ...Our first event study examines the SEC's 2011 enforcement of a ban on Direct Market Access (DMA), which previously allowed the fastest traders to connect ...
- [102]
-
[103]
Algorithmic trading and market quality: Evidence from the Taiwan ...Jul 6, 2022 · ... direct market access (DMA) service as our instrument.15 The TAIFEX adopted the DMA service on July 17, 2007. According to its definition of ...
-
[104]
[PDF] Competition among high-frequency traders, and market qualityliquidity provision. In Budish et al. (2015), any ... from high-frequency trading firms that use direct market access arrangements with registered dealers.
-
[105]
Research on the impact of algorithmic trading on market volatilityAug 17, 2025 · Based on previous studies, we believe that AT influences investor sentiment mainly in the following two ways. First, in some cases, AT directly ...
-
[106]
[PDF] High-Frequency Trading and Market Quality: Evidence from Account ...Jul 7, 2022 · Greater HFT participation is associated with improved market quality, but aggressive trading can have an adverse effect. Market-making HFTs' ...
-
[107]
The Impact of High-Frequency Trading on Modern Securities MarketsSep 23, 2022 · Since empirical studies partially come ... If HFT activity is interrupted, price volatility increases more than trading activity decreases.
-
[108]
[PDF] Informational Inequality: How High Frequency Traders Use Premier ...High-frequency traders use superior access to information to front-run trades, taking a favorable position before a trade is executed.
-
[109]
How are FPGAs used in trading? - IMC TradingFPGAs are used in trading for high-speed processing of market data, enabling quick decisions and efficient pricing by market makers.
-
[110]
Why More Trading Firms Are Moving to FPGA for Low-Latency GainsJul 1, 2025 · A growing number of trading firms are adopting FPGAs, customizable chips that can process market data and execute orders with speed.
-
[111]
[PDF] High Frequency Trading Acceleration using FPGAsThis paper presents hardware using FPGAs to accelerate high-frequency trading by reducing latency for interpreting market data and executing trades.
-
[112]
Demystifying FIX and Direct Market Access for modern trading - OnixSApr 10, 2024 · Direct Market Access, on the other hand, allows traders direct access to exchanges and financial markets, reducing the time and cost associated ...Missing: equity | Show results with:equity
-
[113]
The Democratization of Direct Market Access - ExegyThe convenience and control of direct market access added to Software-as-a-Service (SaaS) efficiency opens DMA to a larger group of firms.
-
[114]
Fidessa Unveils New Low-latency DMA Platform - DerivsourceJun 30, 2015 · Fidessa's new low-latency DMA platform has been built in response to demand from brokers for consistent access to global markets based on a ...<|separator|>
-
[115]
The Rising Threat of Algorithmic Trading Exploits - CodeHunterOct 8, 2024 · Cybercriminals can manipulate market data, execute fraudulent trades, and exploit AI vulnerabilities to cause market instability.
-
[116]
Direct Market Access Controls | FINRA.orgOct 16, 2019 · Direct market access controls require firms to mitigate risks, including pre-trade order limits, capital thresholds, and adequate financial ...
-
[117]
High Frequency Trading Algorithms: Ultimate Guide 2024What are the risks associated with HFT? Key risks include system failures (occurring in 3% of trading sessions), network latency issues, cybersecurity threats, ...
-
[118]
High-frequency traders' evolving role as market makersWe show that HFT trading strategies have moved away from passive market-making over time. We explore the role of regulatory hurdles in this regard.Missing: DMA | Show results with:DMA
-
[119]
High-Frequency Trading: The Technological Revolution Reshaping ...Jun 20, 2025 · The HFT market is expected to grow significantly, with projections suggesting a compound annual growth rate of around 7% from 2025 to 2030.
-
[120]
Are firms that provide sponsored access/direct market access ...Sep 25, 2025 · An Industry Member providing sponsored access or direct market access must populate the deptType on its New Order or Order Accept event with SA (sponsored ...
-
[121]
[PDF] Regulatory Guide RG 241 Electronic trading - ASICThis regulatory guide gives guidance on a trading participant's obligations under the Securities Markets Rules when it uses an AOP system, including using an ...
-
[122]
The Evolution of High-Frequency Trading (HFT) in 2025 - LinkedInMar 13, 2025 · In 2025, HFT continues to evolve with innovations in AI, quantum computing, and blockchain technology. This article explores the latest trends, challenges, and ...