I don't see that as a problem. The circuit breaker size is 10% (5% in some markets, I believe) for 5 minutes. It would take less than 2 hours to completely obli

I don't see that as a problem. The circuit breaker size is 10% (5% in some markets, I believe) for 5 minutes. It would take less than 2 hours to completely obliterate a single ticker, and each market participant gets the "same" amount of play time as before. It might slightly favor HFTs if things do change across those 5 minute downtimes. Otherwise, your orders should be just as valid before the freeze as after, no?