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Valuing Market Knowledge

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By Carl James, Global Head of Fixed Income Trading, Pictet Asset Management

Applying equities methodology to measure transaction costs is unsuitable for diverse fixed income markets, and instead the focus should be on process and dealer expertise.

The launch of Markets in Financial Instruments Directive (MiFID) II will herald wholesale, revolutionary changes for fixed income trading. Yet, few dealing desks and even fewer portfolio managers realise the extent of the tectonic shift that will soon re-shape their familiar landscape.

An important tenet of MifID II is the unbundling of research and dealing commissions: fund managers will pay directly for the data and analysis they receive from the sell-side, rather than indirectly through channelling orders to brokerage as a reward for their service. Achieving provable best execution will become a key responsibility for the buy-side dealer. The problem is that there is not a clear convention for valuing sell-side fixed income research or how to measure the best transaction price at any given time, which means it is difficult to verify that unbundling has occurred. And it is naïve to think that practices in equities markets can simply be replicated by bond fund managers.

Yet, most transaction cost analysis (TCA) service providers are offering systems that attempt to do just that, and hence they fall into a classic error. Generally, they apply variations of an equity metric such as volume weighted average price or implementation shortfall. They are simply supplanting an equity methodology to fixed income trade analysis. Instead of obsessing about price, TCA should focus on the process to demonstrate that a best execution methodology has been achieved. This is exactly what MiFID II describes as best execution. Checks should be made on the steps taken by the dealer from when they receive an order from the portfolio manager to when they complete it in the marketplace. The process requires judgment based on data analysis and skill derived from experience, not on simply ticking boxes to satisfy a simplistic and narrow view that equity TCA delivers, for example, obsessing about price to the detriment of all other decisions.

The fixed income process also follows a logical sequence: a dealer determines whether to trade principal or agency depending on broker axes available; a request for a multiple or single price quote might be conditional on the liquidity of a particular bond issue and the risk that information leakage could disturb the market and distort the price; and a dealer must decide how to incorporate best “hit-and-miss ratios” in counterparty selection.

Fixed income is in fact multiple asset classes, whereas equity is a single asset class. Of all bonds a tiny minority trade more than once a day. Therefore, a different style of trade analysis is required, as it is impossible to be certain that a trade was transacted at the best possible price at a specific time. (This is true in any market in the world). There are many different price-reference benchmarks, but none are perfect or universally used.

Instead, validating each stage of the trade order and execution process will provide better analysis for dealers to adapt their trading strategy, and clients can be shown substantive evidence of best execution.

Dealers embedded in portfolio process
The fixed income dealer’s role is changing and, after implementation of MiFID II will become even more central to the investment process. In pre-trade, they provide metrics such as axes, hit and miss ratios and market understanding to help with decision-making. In post-trade, they have a monitoring duty, ensuring that execution is successfully completed, and shining a diagnostic warning light if something goes wrong.

Crucially, the dealer also acts as a liquidity consultant, in constant dialogue with the portfolio managers using data analysis to identify liquidity, which brokers have good hit ratios or close miss-ratios and how to transact an order appropriate to an individual portfolio manager’s investment style. In fact, increasingly the dealing desk is integrated with portfolio managers’ strategies: it is embedded rather than reactive.

Moreover, the buy-side should become a price-maker as well as a price-taker. It can post its interests or axes on one of several dealing platforms, improving the opportunities to meet a broker or another buy-side participant and hence find alternative sources of liquidity.

The financial industry in general and fixed income, in particular, is developing at a rapid pace, and is currently going through a classic maturing phase: increased automation; more regulation; lower margins; less people; and potentially a better product or outcome.

The equity markets evolved many years ago and do offer a map or set of guidelines, but not a blueprint for bond trading. The fixed income market is diverse in types of instruments and how they trade. Therefore, participants can learn from the mistakes and inadequacies of the equity markets and deliver their own specific solutions, such as a best execution methodology. Yet whatever way the landscape shifts, the effectiveness of the dealer will be critical over the next few years.

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The Achilles Heel Of The Trading World

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By Brian Ross, CEO, FIX Flyer.

There are key measures you can take to protect against cyber-attack and ensure that you are not the weakest link.
The legend of Achilles has it that he was dipped into the River Styx by his mother Thetis in order to make him invulnerable. His heel wasn’t covered by the water and he was later killed by an arrow wound to his heel.  Although the legend is ancient, the meaning is germane today.  Our networks, firewalls and institutions continue to harden, but the world’s most famous hacker knows the truth of cybersecurity.

“Companies spend millions of dollars on firewalls, encryption and secure access devices, and it’s money wasted; none of these measures address the weakest link in the security chain,” says Kevin Mitnick, a once notorious hacker and now a computer security consultant.

Attackers are smart. They don’t target walls.  They hammer against the weakest points of entry. Your trading network is a point of entry and it needs a complete chain of security.

Cybercrime is arguably the top systemic threat facing the global financial markets and associated trading infrastructure.  Predictions abound of major bank failures as a result of cyber-attack.   Finance has long relied on a small number of security measures, mostly focused on heavy security at the edges of the network.  But you must find your Achilles heel, if you want to avoid being a big headline in 2017.

Links in your chain
Understanding how to secure your trading network means understanding how each link in the chain connects. If your local network is secure, an attacker will attempt entry through your clients. The path of least resistance sees the most aggressive attack. There are eight core components of a strong chain of security:

• Attack Vector
• Trading Networks
• Authentication
• Verification
• Encryption
• Integrity
• Air Gap
• Incident Response

Attack vector
Your “attack vector” is the exposed “area of attack” for your FIX network. Minimize your attack vectors as much as possible without impacting your ability to do business. Expose only necessary ports to necessary networks, employ strict firewalls, and implicitly distrust any networks you don’t control.  If it’s not your network, it had might as well be public.

This is probably the strongest area in trading networks today. Financial institutions rely heavily on security at the network edge. It is important to restrict your exposure to trusted extranets. In the words of Ronald Reagan: “Trust, but verify.”

Trading networks
Be it VPNs, extranets, leased lines, FIX networks, or cross-connects, your trading network has to reach your clients. The most important thing is to understand the security ramifications of each connection.  Does your connectivity provider perform penetration tests? Is the traffic encrypted?  Is the connection secured? Encryption is best placed directly on the host and source ends but rarely is this implemented in trading extranets.

Audit and document your connectivity vendors just as you would your own network. They are an active part of your overall security posture.

Authentication
The FIX protocol is notoriously weak in authentication. Most FIX connections rely primarily and sometimes solely on cleartext FIX tags 49 and 56: SenderCompID and TargetCompID.
Since changing the protocol, or even the software, is often not an option, a solid approach is to use multiple authentication factors. CompIDs, FIX passwords, and source IP/port aren’t perfect, but in combination they are far more effective than clear text CompIDs alone. VPN credentials, SSL certificates, or other more secure means are an improvement.

Verification
Where authentication is difficult with FIX, good verification can mitigate the danger to a significant degree. Even if a client authenticates with valid credentials, are you sure they’re who they say they are? Proving who is on the other side of a connection is an important and often neglected aspect of trading network security.

The question you must ask yourself is: “how easy would it be for a rogue application to mimic this credential?” A FIX tag is easily discovered (or even guessed) and trivially duplicated. A valid SSL certificate is much more difficult to spoof, with the added benefit of preventing “man-in-the-middle” attacks. Extranets verify that the network you’re talking to is owned by who they say it’s owned by, but they don’t verify what’s inside that network. FIX secured with TLS/SSL can verify the application itself.

Encryption
Much of the traffic in trading networks is via FIX, which by default is “in the clear.” Anyone with access to any hop of the network can see the data.  Perimeter encryption (VPNs) or security (leased lines, extranets) only protect the data over that connection: not in the full path.

Wherever possible, leverage protocol encryption. TLS/ SSL is supported directly by modern FIX engines. Even when it isn’t a native option, tools such as stunnel can provide TLS encryption for existing applications. This becomes especially important with sensitive data like pending trades or personally identifiable information (PII).

Integrity
Every part of the network you control must be monitored to maintain trust and integrity. This includes your servers and applications. The moment trust is lost in any component of a trading network, the entire environment is potentially compromised.  One of your first challenges is to know you are under attack.

Intrusion detection systems must be deployed, maintained, and monitored. A stable trading network has baseline levels of expected activity: deviations from this baseline are cause for investigation. Is a previously unused port suddenly listening for connections? Is there unexpected network traffic outside of market hours?

The only thing worse than a compromised trading network is when you don’t even know you are compromised. Proactive monitoring can prevent breach attempts as they occur and before they are successful.

Air gap
Most connectivity options for trading networks provide just that: connectivity. These are direct connections linking two networks.  This is a significant danger for trading institutions. Any vulnerability in your system could be exploited by malicious network traffic through direct connections. Wherever possible, “air gap” your most critical infrastructure and avoid direct connectivity from uncontrolled sources.

Security is best achieved with an application air gap, often in the form of a FIX engine.  Any inbound network packets never touch your trading systems without passing through this application air gap.   Counterparty FIX messages are read by a secured FIX engine, and separate FIX messages are sent from that engine to your trading infrastructure.

The application serving as the air gap provides a powerful layer of security. Its client-facing interface can be hardened against likely intrusion vectors (for example, buffer overflows or system-level network vulnerabilities), while clean validated trade information is communicated onward to the trading infrastructure.

Liquidity Is At the Heart Of Asia’s Latest Trading Evolution

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By Michael Corcoran, CEO, ITG Asia Pacific

The pendulum has finally swung to a model where buy-side trading is a valued function in its own right, so brokers must adapt to serve their clients effectively.

In Asia Pacific (APAC), institutional trading costs are typically higher than in other regions and have a material impact on fund returns. Fund managers with good Asia trading performance are saving an average of 50 basis points versus those with poor trading performance—enough to move a fund from negative to positive return over the past three years.1  As returns have compressed, managers have needed to look increasingly at reducing the costs of how they put their investment decisions into action.

Additionally, best execution requirements are now being driven onto managers not just by regulators, but by investors globally requiring high standards and demonstrable proof of efficient trading processes. Backed by the sweeping changes spreading across borders from Markets in Financial Instruments Directive (MiFID) II’s requirement to unbundle research from trading, the slow drip of asset managers overhauling their APAC trading desk processes has become a constant stream.

This new model makes the sole objective of a buy-side trading desk the delivery of efficient execution to maximise the investment return, rather than a payment mechanism for other activities. At more APAC firms than ever before, buy-side trading is now considered an activity in its own right, with a discrete existence as a cost and value centre. Particularly now that the shackles of directing trades for research obligations are being unlocked, the pressure on buy-side trading performance is stepping up to new levels.

A new service model
ITG’s execution-only brokerage model has always placed excellence in trading performance as its top priority, but we too must evolve as our clients’ requirements change. We have seen a particular shift in the value placed on liquidity sourcing, and a more pragmatic approach to the broker coverage model to help service those liquidity needs.

Buy-side desks increasingly expect a high-touch sales trading style of service from their electronic coverage, suggesting the term “low-touch” should be wiped from the trading dictionary. Our independence and execution-only focus have allowed us to quickly respond. In Asia Pacific, we offer a coverage model that maximises liquidity opportunities for clients through a consistent, unified service across all execution channels.

Operating a centralized coverage that extends to single stocks, program and electronic trading ensures a steady and reliable experience for clients across all three execution channels. They can choose whether they want a single touch point or product-specific support, and they can decide who within their ITG coverage team can see what piece of their trade flow and at any point in time. This drives liquidity sourcing opportunities across trading channels, as client coverage staff collaborate in the client’s interest. Importantly, we are also investing heavily in technology tools that identify real-time liquidity opportunities, enabling our traders to work across trading channels as an extension of the buy-side desk.

Harnessing technology
We have also seen rapid regional adoption of technology that focuses on liquidity sourcing. POSIT Alert, ITG’s anonymous institutional block-crossing platform, has already set and subsequently beaten its own daily records for value traded in APAC in January and February 2017, demonstrating the ongoing increase of liquidity being transacted through the platform. Now operating in 11 APAC markets, and 37 markets globally, we continue to invest in POSIT Alert to improve the user experience and add new and different liquidity.

The key to success is the scale and reach this technology can bring to the traders’ desktop. Asset managers trading Asian equities from all corners of the globe—including Canada, the U.S., Europe, Asia and Australia—can be presented with relevant liquidity opportunities without having to devote time to looking for needles in haystacks. Because the technology is smart enough to recognise when two or more buy-sides have potential to trade with each other, block opportunities can be discreetly offered within the buy-side community without showing their hand to the street.

Furthermore, we are devoting investment and resources to algo development and customisation across APAC and globally. Clients will benefit from algo refinement that improves their trade performance, which in APAC includes new tools for list-based trading, specialist consultation on performance-driven strategy selection models and data-driven changes to strategies that optimise passive fills and spread capture.

As asset managers in APAC focus increasingly on measuring and proving trading performance, and finding liquidity, ITG will continue to evolve the service we provide and the products we offer to deliver value for our clients.

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The Fundamental Review of the Trading Book in the EU: An Assessment of How the Sellside Business Model Could be Strategically Reorientated

The Fundamental Review of the Trading Book in the EU: An Assessment of How the Sellside Business Model Could be Strategically Reorientated

 

This report explores the ways in which the Fundamental Review of the Trading Book (FRTB) proposals would impact the ability of EU-based banks to continue operating principal-centric, front-office business and trading models for all relevant asset classes.

 

https://research.greyspark.com/2017/the-fundamental-review-of-the-trading-book-in-the-eu/

Asset Managers Embrace Fintech

 

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By Bill Stephenson, Senior Vice President, Global Head of Trading, Franklin Templeton Investments.

Disruptive technologies and innovation will enhance speed, scale and accuracy in active asset management, and alternative data will create new sources of alpha.

Active and passive investments have moved in and out of favour through various cycles, but at Franklin Templeton, we have always been active in how we think about managing client assets, from security selection all the way through to the dynamic implementation of those strategies on the trading desk.

It has always been about technology, data and analytics, but most recently, it has been about faster and more automated technology, alternative datasets, and robust pre- and post-trade analytics.

Although we have prided ourselves as being on top of the latest trends and innovations, we have also known that there were likely many great ideas that were unheard.  There was no dedicated neutral, noncommercial forum to bring our peers, competitors, innovative ideas, and new thought leaders together in a collaborative setting. That was the genesis of the AIR (Alpha Innovation Required) Summit, first held in early 2014.

Last December, we hosted our third annual event in Ft. Lauderdale, Florida.  It was attended by about 185 professionals from around the world, and was deliberately kept smaller than other more mass market conferences.  With executive support from the top ranks of Franklin Templeton, our president, Jenny Johnson, kicked off the event by describing how innovation is driven by bringing thought leaders together so that we can learn from each other in a collaborative and reflective environment.

A community of people who want to think critically about innovation and the future of active management is imperative to our success as an industry.  And the true measure of that success is the execution of these ideas, which is by far the hardest step in actual innovation.

While the event covered the general topic of innovation within financial technology (Fintech), our focus went deeper. It examined technology that helps a trader, portfolio manager, analyst, or risk manager make a better or faster decision.  This sub-section alone is massive, where we vetted hundreds of companies a year, but eventually selected 20 to present.

In addition, more of the innovation is appearing globally. Five of the presenters in 2016 were from outside the US, up from four and two in 2015 and 2014, respectively.  The 20 ideas presented can be truly disruptive within investment management if the vision can be realized by their founders and the potential users of that technology, such as firms like ours.

The meaning of disruption

By disruptive, we mean technology that can dramatically change how asset managers pick securities, how they might construct portfolios and how they might trade in the marketplace.  This could require different skill-sets, but in order to truly innovate, the industry must overcome the fear that certain job functions might change or evolve faster than individuals can learn them.

The most disruptive technology will bring speed, scale, and accuracy to a new level.  It will also be accomplished with data that doesn’t yet exist or data that isn’t structured to be consumed in a productive way to make real decisions.  That is why it will likely become more important for asset managers to build an infrastructure to find, scrub, normalize, model, and inject this data into an existing and proven strategy.  Basically, it is the formation of a research and development hub with a team of data experts, quants, data scientists, and investment personnel that understand the full investment process, including the existing “secret sauce”.

This is not just plugging a black-box into a fundamental approach: it is about integrating new sources of information that can help better predict fundamental inputs into an investment process.  This is no simple task, because it requires a significant investment in people and technology, along with a strong culture that embraces new approaches.

Every year we have held the AIR Summit, the feedback at the end of the event is the same: everyone is a bit overwhelmed with the feeling that they are so far behind and by how much they didn’t know existed.  It can be staggering to hear how individuals and companies are re-inventing how and why decisions are made, in more and more unconventional ways.

New alpha

However, as decision making is re-invented, there may not be a historical process that will stand the test  of time in the way it has for decades in the past. The shelf-life for an alpha-generating strategy is becoming shorter, which has been running in parallel to the amount of time it now takes for information to travel.  Not only is information dissemination faster than ever, but insight is created from it across a range of data points – almost instantaneously.

Innovation not only drives our process, it also drives new products faster than ever.  Investment products created specifically around new data sets, such as social- or crowd-sourced data, are leading investment managers to find new ways to leverage sentiment to create alpha.

We call it “new alpha” because outperformance in the future will be driven by new or alternative data sets that are created from potentially unconventional sources.  Those sources might be GPS tracking smartphone applications, satellite imagery, car insurance information or credit card transaction data – to name just a few.  Some of these data sources might not even be considered “alternative” anymore since new primary sources of data seem to be created and monetized regularly, some of which might have been considered useless “exhaust data” in the past.

Machines learning to be humans

Data scientists, or the professionals who extract insights from data, seem to be hooked on artificial intelligence or, more specifically, machine learning.  With machine learning it is all about leveraging data and predictive analytics, and then systematically “learning” and modifying behaviour in the future based on the new insights gained from the data.  This could be the most interesting and disruptive force to affect our process as it will spawn new and improved strategies faster than we could have ever created in the past.  The challenge is determining where machine learning fits in the process without creating too much of a black-box approach.

At the latest AIR Summit, participants frequently recalled the new HBO series called Westworld, where human-like robots were programmed, as part of a game, to be emotionally nuanced in order to appear more human.  As the parallels between the show and the innovations we were discussing for those two days appeared to converge, it seemed that perhaps decision-making could become even more automated in the future, with alpha driven by how well your “bots” can interpret new information in a more human-like way.

If we consider how far algorithmic trading has come during the past 15 years, maybe the “bots” will eventually be better than humans across multiple dimensions of our investment decision making process.  For now, however, we agree with businessman and philanthropist Paul Tudor Jones, who recently said, “No man is better than a machine, and no machine is better than a man with a machine.”

Blockchain potential

No discussion about Fintech and disruption is complete without mentioning blockchain, which has been one of the most globally-hyped innovations over the past year or so.  From the Australia Securities Exchange’s use case for settlements and clearing to the UK’s suggestion that this kind of distributed ledger technology could help collect taxes, issue passports, and register land – the opportunities within finance and elsewhere are exciting.

Yet, although there will likely be significant innovation in and around blockchain technology in finance, such as smart contracts, the impact of it within investment decision making could be much further out into the future.  However, given all the research and development (expected to exceed $1 billion by banks in 2017), regional “hack-a-thon” events, and hundreds of global patent applications, it wouldn’t surprise us if AIR 4.0 will feature more on blockchain technologies that touch the investment process.

Finally, if we take a step back and think about all this innovation in the context of a trading operation, then trade execution is where alpha can be created or lost – it’s where the rubber meets the road.  It can involve timing, emotion, speed and a host of other factors that can be improved with data, automation, technology, and of course human interaction.

Whether it is in the trading function or elsewhere in the investment management process, innovation isn’t going away.  A different type of thinking, with alternative tool-sets and the associated skills to create new alpha will be in high demand, and a significant investment in pushing forward these innovations will benefit end clients.  Embracing Fintech, no matter where in the world it might be developed, is really our only option not just to compete, but to ensure active management thrives.

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A Buy-Sider’s Market

michael-chinBy Michael Chin, Managing Director, Global Head of Trading, Thomson Reuters.

Fund managers are gaining the upper-hand over trade order and execution systems vendors, who respond with flexible technology.

A significant change is underway in the relationship between the buy-side and the providers of the technology to process trade order management and execution.

Budgetary constraints, stricter compliance oversight and the momentum towards extending electronic trading to a wider range of asset classes and geographical jurisdictions make fund managers more demanding. Meanwhile, the number and variety of systems offered by vendors mean they can be more selective.

In addition, technology expenditure is shifting from the sell-side to the buy-side, and as a result, vendors are forced to reassess their client base and product suite.

An increased demand for timely and accurate analytics and risk management emphasises the need for a seamless integration of data throughout the investment cycle, from the front- to the back-office: pre-trade idea generation, execution, post-trade confirmation, end-of-day compliance and final settlement.

The buy-side has greater choice, mixing and matching order management systems (OMS) and execution management systems (EMS) from different vendors to meet their specific requirements, opting for the combination most appropriate for the scale and focus of their businesses.

This conclusion might seem counter-intuitive. After all, many vendors have invested in and promoted ones-top, fully-integrated OMS and EMS systems. But in reality, OEMS products have often proved unsatisfactory because of the inherent differences in functionality of the two systems and because they often lack the flexibility needed by individual buy-side firms.

A better alternative is to offer discrete OMSs and EMSs that can be synchronised to provide a seamless process that accommodates the different roles that each system plays in a transaction. OMSs within buy-side firms transmit trade order communications between portfolio managers and their dealing desks, and provide pre-trade and post-trade workflow to support internal operations. EMSs are at the point of interaction between the dealing desk and the market, managing and executing orders in real time.

Integrated process
There are three main functions within the transaction process, from pre-trade to execution to post-trade that must be incorporated in a successfully joined-up OMS and EMS.

First, there is staging, which is the link between the OMS and EMS leveraging the FIX protocol, the standard electronic language for order communications and trade execution. In the staging process, the OMS interacts with the EMS. A portfolio manager has a trade idea, notifies the OMS, and the details appear on the dealer’s EMS screen or blotter.

Before it arrives, automated risk checks are undertaken to ensure fund covenants aren’t breached and counterparty limits aren’t exceeded, as well as basic verifications such as confirmation that there is enough cash available to make a purchase or sufficient securities to make a sale.

When the transaction is completed, details of the trade then flow back from the EMS to the OMS to update positions and profit & loss.

Second, the EMS operates in real time. The trader slices up the order using algos, and the EMS manages information updates immediately. Access to real-time market data and the ability to rapidly filter noise are essential to make trading decisions especially in a low latency environment populated by high frequency trading.

However, this can cause a disjunction in a buy-side firm’s internal process, because most OMSs are not designed to handle real time updates which can lead to a bottleneck in the process.

Third, the combined system has to meet regulatory requirements for achieving best execution. Transaction cost analysis (TCA) is typically conducted through a real time interactive tool within the EMS that includes a course-correction facility, and supplements the post-trade compliance check.

This desire and requirement for accurate and trustworthy real time data provides some vendors an opportunity as buy-side firms adopt open, mix-and-match OMS and EMS platforms. They can safeguard information integrity by channelling content that is a “single source of truth”.

However, in a highly competitive marketplace, vendors are under constant pressure to deliver more features and functions, integrate more tightly, provide more data, cope with different asset types, and reach more markets. The buy-side’s cross-asset trading capabilities are rising and they have an increasing choice of execution strategies.

A survey of buy-side traders by a leading independent consultancy last year found that as equity execution venues and tools proliferate, traders want more control over order handling. Active traders require trading functionality such as configurable trading blotters, real-time depth of market data, charting, and alerts.

Traditional OMSs provide the baseline capabilities to route orders via brokers’ algorithms, but lack the additional controls and colour that give active equities traders an edge, according to the Greenwich Associate report ,“Move Over, Neighbor: EMS Establishes Residency on the Desktop” (April 2016).

Furthermore, it found that seamless integration of the front-middle-and back-office systems is no longer considered a luxury, but are instead a basic requirement.

Although in an ideal world, a fully-integrated OEMS that reduced complexity and costs would meet that need, the options increasingly available to buy-side firms means that they can construct their own unified system and modify or augment it as they enter new markets or trade new asset classes electronically.

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Multi-Tasking For Successful Implementation

Tim Healy 14By Tim Healy, Global Marketing and Communications Director, FIX Trading Community

FIX Trading Community is taking the initiative as markets prepare for the impact of MiFID II and meet new challenges.

The second half of 2016 saw a significant uptick in meetings and calls relating to the impending Markets in Financial Instruments Directive (MiFID II) regulation. What became clear, is that the marketplace is keen for FIX to provide some practical answers to the implementation questions and members have stepped up to work collaboratively and set down on paper, guidelines, best practices and workflows.

Additionally, changes to the FIX Protocol will occur with new tags and new values for existing tags in order to pass required information between investment firms and venues. Clearly, 2017 will be another busy year for the FIX Trading Community and its members.

By the time this article is published, the first in a series of extensions to the FIX Protocol will have been published which covers a number of the requirements of MiFID II, particularly RTS 22 and 24. Without going into specific detail here, what is worth noting is that FIX is endeavouring to make sure that all firms who are under MiFID II obligations will have the ability to be compliant in an efficient manner.

FIX is ubiquitous in trading and it is important that the enhancements to the Protocol are available for all investment firms. Regulators are keen to see a standardised approach to the solutions that investment firms use to meet their obligations and a unilateral, rather than bilateral, approach is far more sensible and efficient.

Away from the regulatory aspect, there were a number of other initiatives during 2016 that members worked on, the aim for these being to bring even greater efficiencies to processes and workflows.

Last August, new guidelines were released for the use of FIX in post-trade processing for multi-asset classes. The Global Post Trade Working Group has been working on providing a standardised and detailed set of guidelines for futures, equity swaps and FX equity options for some time now and, with the release of this new document, FIX has addressed issues by providing a common workflow with minimal differences across asset classes.   Market participants will be able to reduce risk and have the ability to leverage off their current FIX infrastructure in place for trading and, by doing so, minimise implementation time and costs.

The Cybersecurity Working Group was particularly active last year. It is a topic that is never far from the news and the headlines and it is important that FIX Trading Community addresses these concerns and encourages information sharing among its members. In addition to updating the FIX Security White Paper earlier in 2016, the working group has been drafting guidelines for the use of a Transport Layer System (TLS) protocol with FIX. TLS is a rich protocol with many features and options and allows for new security functions to be added and vulnerable functions to be dropped.

Collaborative efforts
FIX Orchestra was conceived as machine readable rules of engagement between counterparties. Anyone who has worked with FIX in onboarding, testing and certification will understand that some of the workflows can be time consuming.  The aim was to create a much more efficient process with machine readable rules of engagement with the intention to cut time to onboard counterparties and improve accuracy of implementations. At the end of 2016, the working group was producing a technical standard proposal that will be reviewed and released in 2017.

The Blockchain and Digital Currency Working Group have been working on a number of different initiatives relating to post trade and symbology for digital currencies. Although nothing has been firmed up as of writing this piece, discussions are underway with a trade association to create a governance structure for maintenance and assigning values and to create symbology which would be used for digital currencies.

In a similar way, the Trade Cost Analysis (TCA) Working Group has been working with a buy-side trade association on the original TCA for Equities Best Practices document that was released a few years ago. This new input will serve to enhance the already detailed document and the working group are now keen to move forward to relook at TCA for other asset classes.

As you can see, there is a strong air of collaboration in the marketplace at present. FIX is not a lobbying body or a trade association, but is a trade standards body that brings together the actors in the market, as well as the vendors, and affords them the opportunity to look at how the use of standards can address and solve real issues in the market.

This neutrality has been recognised by the regulators and trade associations and FIX members are working with both to ensure coordinated action to keep any potential duplication of effort to a minimum. As an inclusive organisation, FIX welcomes new members so if you are not a member of FIX Trading Community and wish to help shape the future of trading, please contact us at fix@fixtrading.org to learn more.

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Announcement : Bats block trading to tackle MiFID II caps

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BATS GLOBAL MARKETS HAS LAUNCHED A NEW BLOCK TRADING SERVICE FOR THE EUROPEAN EQUITY MARKET.

Launched on Friday, 17 March 2017, the Bats Large in Scale (LIS) trading service brings together the block flow from both the buyside and the sellside. All permutations of matching indications of interest (IOI) are allowed with no directional information published, and no IOI details exposed unless a firm opportunity to trade exists. Changes to the negotiated price cannot be made subsequently.

With MiFID II coming into effect in January 2018, the amount of trading executed in dark pools will be capped at 4% of the total volume in any stock on any particular venue and 8% market-wide in any 12-month rolling period. Minimum size requirements for Bats LIS will be based on tables published by the European Securities and Markets Authority (ESMA).

“Our analysis on the potential impact of the dark pool caps indicates that many stocks would almost immediately breach the 8% market-wide limit. For buyside participants who rely upon dark pools to trade without signalling to the market, the volume caps will have a significant impact on how they execute their trading strategies.” says Mark Hemsley, CEO Bats Europe.

Under MiFID II, large in scale block trading will benefit from one of the waivers enabling market participants to negotiate trades without the need for pre-trade transparency. Bats LIS is a MiFID II compliant solution targeted at buyside firms looking to trade large blocks of stock without market impact. Bats LIS also brings together the flow from both US and European firms who want to trade European equities, which helps increase matching opportunities.

“MiFID II regulations are restricting what can take place in broker-crossing networks, or internalised within a bank, therefore flow needs to find other venues or ways of executing. Block trading platforms such as Bats LIS are the solution required to enable block liquidity to execute under MiFID II. When MiFID II is introduced people will look for information on where trading has moved to and adapt their strategies accordingly” says Hemsley.

One of the other key areas of MiFID II impacting buyside trading is regulations governing best execution, which are set to become more prescriptive under MiFID II. The overarching MiFID I best execution obligation requires investment firms to take all reasonable steps to obtain, when executing orders, the best possible result for their clients. Buyside traders are less able to ask sellside traders to trade on risk for them, giving the buyside more responsibility on how execution is achieved.

“When looking at how to maximise the chance of execution, we believe it is important to have diversity of flow across market participants and geographies, which is what Bats LIS provides. Additionally, making it easy for buyside firms to execute their trading strategies through their existing order management systems and execution management systems really simplifies the process for them, which is why our partnership with [IT provider] BIDS, who already has extensive buyside channel distribution, is such an important component of the Bats LIS offering.” says Hemsley.

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Enhancing Securities Settlement Systems: The Application of Distributed Ledger Technology in Hong Kong

Enhancing Securities Settlement Systems: The Application of Distributed Ledger Technology in Hong Kong

 

This report presents a blockchain solution to the time-consuming and costly securities clearing and settlement processes currently employed in Hong Kong. Blockchain is a protocol for building a replicated and shared distributed ledger system that can be implemented to process and record securities transactions across a decentralised private network.

 

https://research.greyspark.com/2017/enhancing-securities-settlement-systems/

Blog : CBOE takeover of BATS : Sylvia Smit

Sylvia Smit, Delta

Does the CBOE takeover of BATS go against the spirit of MiFID?

Sylvia Smit, DeltaBy Sylvia Smit, Head of Equity Markets Delivery at Delta Capita

From expanding into more asset classes, to offering new ETFs, currencies and cash stocks trading, there is no question the $3.2 billion acquisition of BATs provides CBOE with a truly global multi asset one-stop shop. CBOE will benefit from new revenue streams from the fastest growing markets. Recent estimates also suggest that by using BATS technology, CBOE will make annual cost savings in the region of $65 million. Everything is certainly rosy in the CBOE garden.

But given the fact that many initial post-crisis regulations aimed to increase exchange competition as opposed to reducing it, what knock-on effect will a deal of this magnitude have on European market structure? To answer this question, it is worth looking back before fully assessing what could lie ahead. The original MiFID removed the so-called concentration rule, which led to the proliferation of new MTF venues which, as a consequence, triggered a boom in trading volumes away from primary exchanges. There is no doubt that this ruling has, in large part, led to the benefits that so many MTFs bring to the market today. These benefits range from more competitive lower commission structures, particularly for liquidity providers, to smarter and more agile technology which reduces latency.

However, in the thirteen years that have passed since MiFID I, the CBOE/BATS deal is just one of a plethora of deals that have affected how markets operate. Mergers between LSE/Turquoise and BATS/Chi-X have given the major exchanges a firm grip on large European MTFs. And it is not hard to see why the bigger players have moved in. To put things into context, prior to MiFID, the share of trading on MTFs was practically non-existent. But in the year to March 2017, MTF trading represented over 40% of the total turnover in listed names across the FTSE 100 and MIB, DAX, CAC 40 and IBEX.

Today, the top five exchanges each have a decent slice of the market. The LSE, Deutsche Börse and Euronext have market shares of approximately 16.2%, 14% and 13% respectively, while Turquoise has 12.5%. But perhaps most significantly with the CBOE deal front of mind, BATS is responsible for 23.5% of total turnover of the above mentioned market. At first glance, this shows a strong level of competition between regulated markets on the one hand, and innovative MTFs on the other. Digging a little deeper to break the numbers down ‘by ownership’ rather than ‘by venue’, paints a different picture. Following the CBOE/BATS merger, 88% of the turnover from the aforementioned indices, is now back in the hands of traditional market operators. So where does all this leave the smaller alternative MTF venues that have contributed so much of the innovation in the markets since MiFID I?

In the year to March 2017, the remaining European MTF players hold a 5.5% market share. It is, therefore, slightly ironic that given the early success of these nimble venues, that BATS has ended up under the control of an exchange that MiFID I tried to remove volume from through its concentration rule. If the CBOE/BATS can deliver on economies of scale, then the market will benefit from much lower fees. At the same time, an ever-expanding electronic market maker community will want to make sure it has an ever more diverse range of choice of where to trade. With all this considered, coupled with the issue of transparency being front of mind with MiFID II fast approaching, the remaining MTFs will surely have little choice other than continuing to innovate around products and pricing in order to remain competitive.

The views and opinions expressed in this article are solely those of the original authors. These views and opinions do not necessarily represent those of Best Execution, or any/all other contributors to this site.
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