Event Processing blog

The Rat Race to Regulate High Frequency Trading

 

The following is an excerpt from Dr. John Bates’ recent commentary on Huffington Post, whch discusses the current state of high frequency trading regulation.

As Aerosmith famously sang: "Rats in the cellar... losin' money, getting no affection." Lately, HFTs have been compared to everything from rats in a granary to highway robbers intent on stealing Granny's pension. Bashing high frequency trading firms has become the latest sport in the financial services industry. So much so that the Futures Industry Association has publicly taken exception to the "emotive language" being assigned to HFTs.

"For example, many people don't realize that market abuse -- as well as being morally reprehensible -- comes at a hefty price for the market. So principal trading firms such as our members have a very real economic incentive to fight market abuse and back regulatory reform," said FIA European Principal Traders Association chairman Remco Lenterman. He noted that the industry's critics chose to overlook the value that principal trading firms add to the real economy in terms of lower transaction costs and greater liquidity, according to Finextra.

Read the full post from Dr. Bates here. 

 

Automated trading restrictions: are they a presumption of guilt?

Anyone who’s seen the news in recent months will know that High Frequency Trading is facing a sharp increase in the number of regulatory challenges, with some tough measures suggesting that it has been presumed guilty until proven innocent by many. ESMA, implemented in Europe in May 2012, is the latest set of regulatory guidelines around the systems and controls required in an automated trading environment. But are these regulations fair?

It seems clear that, with the ever-increasing volumes of data that firms need to manage and monitor in order to catch abuse, Europe has decided to take a firm stance on automated trading. But is all this a case of, as my colleague Richard Bentley suggests, using a sledgehammer to crack the nut?

Clearly, increasing red tape will place a significant burden on firms and may, if we’re not careful, lead to a situation of regulatory arbitrage, or lock those without deep pockets out of the market. Perhaps a better answer is to adopt a three-layered approach to surveillance where the brokers, trading venue and regulators all have a different role to play will help stamp out abuse without necessarily stubbing innovation?

On a recent visit to London, I met with Phillip Stafford at the Financial Times Trading Room to discuss EU market abuse regulations as can be seen in the video here.

 

Can market surveillance help to keep traders on track?

By Richard Bentley, Vice President, Capital Markets, Progress Software

There’s no doubt that today's high speed capital markets and cross product, cross market trade volumes mean regulation struggles to keep up with changes in the market.  MiFID II is an example of a financial regulatory directive that is seen by many as lacking real detail and remaining open to interpretation - and misinterpretation. In a panel discussion at the TABB Group Trading Surveillance event in London on last Wednesday evening, industry experts agreed that, in Europe at least, few financial services firms are afraid of regulators.

So as many new regulations remain wooly, ignored or have yet to be implemented - or in the case of ESMA (the European Securities and Markets Authority) the regulation is simply statements of clarification – the panel was asked how surveillance and risk is going to be managed moving forward? Questions were also  raised about the regulatory burden in the future and whether those outside of the "Big Five" would be able to resource the demands for growing compliance departments. Will this lead to an uneven playing field?

According to TABB Group new compliance costs are indicated at between 512 and 732 million euro, with ongoing costs between 312 and 586 million euros.  But while regulators are still determining what regulation will look like, the need for market surveillance is undiminished. Traders made about 13.3 billion euros ($18.2 billion) from market manipulation and insider dealing on EU equity markets in 2010, according to an EU commission study.  With some arguing that firms can only do so much to survey markets themselves as trades cross multiple brokers and gateways, the panel discussed the need for fragmented market data to be brought together in a consolidated tape and surveillance performed at an aggregate market-wide level. 

With respect to High Frequency Trading, there was discussion and agreement that pre-trade checks should be built in and regulators should be feared, as in some Asian markets where some market participants adopt a mindset that constantly asks "will I be allowed to trade today". That "Fear Factor" is key and there isn't fear of regulation yet in Europe.

The timeliness of market surveillance was discussed with the panel suggesting that transactions should be monitored retrospectively, but also in real-time as they happen. Clearly, there’s still a role for historic analysis of the market as some abuse takes place over an extended period of time and new abuse scenarios are discovered which can then be applied to historical data. It’s a little like having your DNA stored on file for a time in the future when forensic techniques improve. But there is also no doubt that the need for real-time surveillance to spot manipulation as it happens can be a significant factor for organisations looking to protect themselves and the market, which is one of the reasons it is mandated by Dodd-Frank and MiFID II.

Finally, the panel discussed how turbulent markets and highly publicised breaches of banking controls have demonstrated the importance of protecting market integrity. So while an increase in the complexity of market surveillance inevitably leads to an increase in cost, the panel felt that the punitive and reputational risks associated with surveillance failures justify the business case for improving compliance training, processes and technology.  After all, just as you wouldn’t expect the police to prevent all crime by themselves, it’s clear that investment is needed in surveillance technology to give the regulators a helping hand.

Is Revolution the Path to Transparency?

Revolutions are proliferating.  When you watch a revolution happening elsewhere, political or otherwise, it’s a good time to contemplate the revolution in your own history, or in your future.  There are few among us that can’t point to one or the other.  One of the common drivers is the fear that something is happening where we can’t see it happen, and we want transparency – of process, of government – of whatever seems to be wrong.

The capital markets globally are experiencing a similar revolution now with regulatory change, and the current climate threatens to create a revolt as well.  Market participants may push back on reforms to the point of creating a new state of stress.  Either way, the future presents very real threats to companies that aren’t prepared.  We’re observing a vast expansion of global rulemaking, and a coming deluge of data - especially in the derivatives markets. It’s very expensive and distracting to fix problems after the fact, so we need to act now.  “Hope is not a strategy” – as is often said to have been uttered by famed (American) football coach Vince Lombardi.

In an open letter to Barack Obama published on January 23, 2009, Benjamin Ola Akande advised, "Yet, the fact remains that hope will not reduce housing foreclosures. Hope does not stop a recession. Hope cannot create jobs. Hope will not prevent catastrophic failures of banks. Hope is not a strategy."

Now we have the Dodd-Frank Act in the U.S., MiFID II and EMIR in Europe, all preceded by the de Larosiere Report (EC, 2009), Turner Report (FSA, 2009), Volcker Report (G30, 2009), G20 – Feb 2009 Declarations, Financial Stability Forum Report (FSF, 2009), INF Report (IMF, 2009), Walker Review (UK, 2009), Basel / IOSCO Reviews… the list goes on.  And the rest of the world is watching, waiting, for another revolution.  The intended scope of the most recent reforms seems to almost be panacea, and transparency is the first step.

The next Revolution is happening in Boston, fittingly.  Progress Revolution 2011, from September 19^th through the 22^nd, offers the chance to learn from industry innovators on how they have successfully tackled these challenges within the capital markets.  Customers including PLUS Markets and Morgan Stanley will be there to share success stories.  And Kevin McPartland, Principal at the TABB Group, will be there too.  I’ve included a sneak peek into Kevin’s “Path to Transparency” below.

According to the New York Times, at the Republican Convention in 2008, Rudy Giuliani once said while contemplating Barack Obama’s candidacy, “… ‘change’ is not a destination ... just as ‘hope’ is not a strategy.”  Rudy will be speaking at our Revolution too.  Will you be there?  It will be a lively conference – I hope that you can join us!

-Dan

The Path to Transparency

By Kevin McPartland, Principal, TABB Group

Managing the vast quantities of data born into existence by the Dodd Frank Act and related regulation will present a challenge in the post-DFA environment; but collecting and producing the required data is just the tip of the iceberg. The ability to analyze and act on that data is what will separate the survivors from the winners. This is already true in many other parts of the global financial markets, but the complexities inherent in swaps trading coupled with the speed at which these changes will take place creates unique challenges. Spread this across all five major asset classes and three major geographies, and the complexities become more pronounced.

Margin calculations are proving to be one of the biggest concerns for those revamping their OTC derivatives infrastructure. In a non-cleared world, dealers determine collateral requirements for each client and collect variation margin on a periodic schedule—in some cases once a month, and in other cases once a year. When those swaps are moved to a cleared environment, margin calculations will need to occur at least daily. The result is an upgrade of the current batch process with dozens of inputs to a near-real time process, with hundreds of inputs. Whereas before major dealers could perform margin analysis, client reporting and risk management in a single system, those systems now need to operate independently within an infrastructure that provides the necessary capacity and speed.

The trading desk will require a similar seismic shift, as flow businesses will provide liquidity across multiple trading venues to an expanding client base. Most major dealers are at some stage of developing liquidity aggregation technology intended to provide a single view of liquidity across multiple swap execution venues. Creating this type of virtual order book requires receiving multiple real-time data feeds and aggregating the bids and offers in real time.

Furthermore, rather than comparing model-derived prices to the last trade price to produce quotes, inputs from SEFs, CCPs, SDRs, internal models, third-party models and market data providers will be required inputs to real-time trading algorithms once reserved for exchange-traded derivatives.

Providing clients with execution services presents other challenges. Executing on multiple platforms also means tracking and applying commission rates per client per venue in real time. Trade allocations also complicate the execution process.  In the bilateral world a big asset manager can do a $100 million interest rate swap and spread that exposure across multiple funds as it sees fit. Under the DFA, the executing broker must know which funds are getting how much exposure. Account allocation in and of itself is not new, but cost averaging multiple swap trades and allocating the right exposure at the right price to the proper account presents complex challenges, especially in a near-real time environment.

Risk management, compliance and back-testing data will also require huge increases in processing power, often at lower latencies. Risk models and stress tests, for example, are much more robust than they were before the financial crisis, requiring a considerably higher amount of historical data.

Compliance departments now must store the requisite seven years of data so they can reconstruct any trade at any moment in the past. This is complicated enough in listed markets, when every market data tick must be stored, but for fixed-income securities and other swaps, storing the needed curves means that billions of records must not only be filed away but retrievable on demand. Similar concerns exist for quants back-testing their latest trading strategies: It is not only the new data being generated that must be dealt with. Existing data, too, is about to see a huge uptick in requirements.

In the end these changes should achieve some of the goals set forth by Congress as they enacted Dodd Frank – increased transparency and reduced systemic risk.  The road there will be bumpy and expensive, but the opportunities created by both the journey and the destination will outweigh any short term pain.

This perspective was taken from the recent TABB Group study Technology and Financial Reform: Data, Derivatives and Decision Making.

Progress Revolution Session Sneak Peek: Transforming Your Bank to Become Operationally Responsive

Within the banking industry today, we’re observing a significant expansion of choices available to customers, and subsequently loyalty to the primary bank is eroding. What specifically is driving attrition? 

Results from a 2011 customer survey conducted by Capgemini show that “quality of service” and “ease of doing business” are the factors that most strongly influence a customer to both initially select AND leave a bank.

What does this mean for a bank conducting business in the current competitive landscape? It means that connecting with your customer at the right time and right place is critically important. The question that remains is exactly how this seamless connection between the organization and the customer is achieved in the real world.

Immediacy is the critical overlay, and immediacy is achieved through real-time data capture and reporting translated into highly targeted, more relevant offers. Real-time data capture and responsiveness put you in a position to move fluidly with your customer base.  There’s no lag time where a lucrative window of opportunity closes before you have the opportunity to act.

It’s all about connecting with customers on their terms, and this is best achieved through automating the process.  For instance, if you have a customer that has deposited a large check outside the parameters of their typical deposit cycles, you can present an offer for a high yield savings account. This type of offer works well when you connect with your customer immediately because the large deposit is still top of mind, and other choices for investment have likely not yet been identified.

Essentially you’re able to capitalize on your preemptive knowledge that this customer is likely in the market for a savings account product BEFORE the customer is able to research competitive options. 

By anticipating your customers’ needs you’re delivering on the most important factor in retention – ease of doing business.

When you have the tools in place to serve up the right offering to the right customer at the right time, everyone wins.  You don’t want your customer to jump ship because they think you don’t have what they need.  And your customer really doesn’t want to spend their valuable time and energy searching for a solution that they could quickly and easily secure from you.

The beauty of Responsive Customer Engagement is that it evolves operational efficiency into operational agility.  It’s not enough to streamline processes and collect data – it’s about how quickly and effectively you can translate data capture and analysis into real-time, relevant communication with your customers. Believe me, if you’re not focused on real-time customer engagement, it’s highly likely that your competitors are.

I hope that you can join me in Boston on September 21^st at Progress Revolution Boston 2011 to discuss how to leverage software solutions to not only improve operational efficiency but also increase customer engagement and loyalty.  I’m going to be covering cross-sell and up-sell marketing, payment management, and customer on-boarding and other timely topics, and look forward to a lively exchange of ideas!