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News review

IEX TRADING VENUE WINS BITTER BATTLE TO BECOME AN EXCHANGE.

After months of brutal lobbying, upstart IEX has been given the green light by the US Securities and Exchange Commission to become the country’s 13th stock exchange. The fight has divided the US equities industry and will change the way shares are traded.

At the heart of the controversy are the speed bumps which are designed to slow orders down by 350 microseconds, thereby shielding the market from high frequency traders. The company has said that the slight delay is enough to prevent traders with a faster view of market information from racing to IEX and picking off orders that haven’t had time to update to the best price in the market. It has also avoided the practice of paying rebates to traders who send orders to its venue, founder Brad Katsuyama said in a recent interview.Be33-Web-02

Opponents including Nasdaq and other stock exchanges have argued that the IEX’s speed bump will violate rules mandating that exchanges make their prices available to all parties at the same time. Some brokers have also said the speed bump could restrain IEX’s growth, because some of the fastest electronic trading firms, which rely on the ability to update or cancel orders immediately, will consider any delay as a barrier to their strategies.

There are also those critics that are concerned the new trading structure will add an extra layer of complication into a stock market infrastructure that is already criticised for its complexity, plus it could potentially hurt small investors.

When announcing the decision, Mary Jo White, SEC chair said: “Today’s actions promote competition and innovation, which our equity markets depend on to continue to deliver robust, efficient service to both retail and institutional investors. A critical role of the commission’s regulatory framework is to facilitate the ability of market participants to craft appropriate market-based initiatives, consistent with our mission to protect investors, maintain market integrity, and promote capital formation.”

IEX is run by the people at the centre of the Michael Lewis book, Flash Boys: A Wall Street Revolt, which profiles the early efforts of the IEX team to create a trading exchange that implements speed bumps. The exchange accounts for less than 2% of daily volume in US equities, but being an exchange is expected to boost its market share since brokers now have to route to them if they show the best price at any given time.

Katsuyama said that IEX exchange’s unique structure minimises conflicts of interest and would appeal to large investors such as hedge funds, mutual funds and pension funds, who would have to lean on their brokers to route more of their orders to IEX.

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News review

ON THE LOOKOUT FOR PROJECT SENTINEL.

A new multi-bank initiative called ‘Project Sentinel’ has been launched to help mutualise the costs that firms incur related to MiFID II implementation for OTC-related front office trading technology. It will use a normalised regulatory data model that assists investment firms to meet the new OTC sales and trading requirements.

Currently, a group of between four and seven banks has officially signed up to be a part of the project, though their names have yet to be disclosed, with a further handful likely to join in the near future. It is thought that a number of large regional banks are included in the first wave.

It has been well documented that navigating MiFID II reporting and compliance obligations can be challenging and requires both human and monetary capital to research and implement appropriate measures, in addition to time constraints as new deadlines come into effect.

Etrading Software, which is serving as the project manager for Project Sentinel, said that “dealing with MiFID requires substantial human resources, expertise and technology investment” – which, if tackled on “an institution by institution basis, will demand substantial investment in areas that provide limited or no competitive advantage”.Be33-Web-03

Sassan Danesh, Managing Partner or Etrading Software, and who co-chairs the OTC product committee for the FIX Trading Community, explained in a statement: “We are delighted to facilitate this important initiative on behalf of market participants to create a modern, low-cost, standards-based MiFID II infrastructure capable of servicing client needs efficiently and electronically.”

Market participants will pool their resources in non-competitive areas, such as MiFID II, by investing in a standards-based, strategic MiFID II compliant technology solution which according to Etrading, “streamlines and automates the business processes for the front-office, brings value and efficiency back to the business and reduces commercial risk”.

The focus will be to reduce expenses and risks through mutualisation of analysis, interpretation and implementation as well as compliance costs due to the sharing of IT investments. Moreover, economies of scale will help create a competitive, market-leading, “best-in-class” solution while ensuring dedicated, focused resources working on a single project. The solution will also be flexible enough to be adapted to other regulatory regimes such as the European Market Infrastructure Regulation and Dodd-Frank.

The next phase of Project Sentinel is mapping out the MiFID II compliant workflows for the core permutations of interaction and client types, trading models and platforms and instruments across the trading lifecycle to allow the selection of best-of-breed technology solutions (buy or build) for the new market structure to come.

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Regulation & compliance : Post-trade : Mary Bogan

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CCPS TO THE RESCUE.

Mary Bogan assesses the new role of CCPs as banks withdraw under stricter banking regulation.

As Europe’s over the counter (OTC) derivatives business finally emerges out of the shadows and into the bright rays of lit exchanges, the demand for clearing services has taken a mighty shot in the arm. However, just as demand is ready to soar, the supply pipeline is spluttering. As the banks retreat from the market to nurse bruised balance sheets, how to fulfil mandatory clearing obligations has become a headache for clients. Enter to the rescue the once sleepy central counterparties (CCPs

Removed from the comfort of their protected markets and newly plunged into a fiercely competitive world, the drive to keep the clearing pipeline flowing and revenues rolling is stimulating new thinking at CCPs and producing fresh ideas which, they claim, will ease banks’ balance sheets, curb rising costs and open up new access routes into clearing for buyside clients.

The decision by regulators after the financial crisis to introduce mandatory central clearing for the $553tn OTC derivatives market looked like bonanza time for banks. As the main gateway into CCPs, they expected big volumes and juicy cross-selling opportunities from new OTC clearing services to clients. But not anymore.Be33-Web-38

“The financial landscape has been decimated over the past few years,” says Joshua Satten, director of business consulting at Sapient. “Volumes in the OTC space are at an all-time low, a lot of banks have gone down in value and successive delays to mandatory clearing in Europe have pushed potential investment returns further down the road.”

In the meantime, new Basel capital calculations, and the advent of the leverage ratio, has made clearing a much more capital-intensive and expensive business for banks.Be33-Web-37

“In response, we’ve seen some banks pull out of some aspects of the clearing market altogether while others are reviewing their client base and choosing to either turn away clients or even resign as clearing brokers for clients where there’s no potential for cross-sales or other commercial opportunities,” says Kevin Liddy of derivatives advisory firm Solum Financial. “In addition clearing costs, which have already risen by a factor of four to five in some cases, are on an upward path.”

As clearing business becomes concentrated into the hands of fewer larger banks not only does pricing power increase but, for the buyside in particular, a shrinking pool of clearing brokers also poses large risk issues around portability. In the event of a clearing broker going bust, some buyside clients could struggle to find another bank willing to take on their portfolio given the capital costs involved and find themselves closed out by the CCP.

According to Liddy, the changing clearing landscape means it’s time for clients to review their clearing arrangements and consider direct membership of CCPs.

“The decision about how clients should choose to clear was typically made about five or more years ago. But we’re looking at a very different landscape now. Clearing services provided by banks are more expensive and there are access and portability concerns,” says Liddy. “In my view, there are some sizeable clearing clients who could and should clear directly with CCPs”.

Technology eases the pain

New technology solutions could help those clients remove the strain of direct CCP membership. “There are now cloud- based clearing platforms that allow clients to interact directly with a CCP and provide all the tools and analytics needed to manage a portfolio, post collateral, exercise obligations under the fire drill or put in a bid on a defaulted portfolio if required. That infrastructure didn’t exist before and I expect it to gain more traction once OTC clearing in Europe is fully up and running.”

Creating opportunities to form more direct links with clearing clients, while at the same time making it easier and cheaper for banks to provide clearing services, has also become a focus for CCPs too.

At the end of March Eurex announced it is to launch a new access model this summer. ISA Direct creates a new membership type, allowing the buyside to have a direct contractual relationship with the CCP but facilitated by a member bank or clearing agent. It will initially be offered for Eurex interest rate swaps and repo transactions. Listed derivatives and securities lending transactions are to follow. Under the model, end-investors become responsible for posting their own initial and variation margin needing the clearing agent simply to contribute to the CCP’s default fund on their behalf.Be33-Web-39

Apart from helping to reduce clearing costs and widen the choice of provider, the buyside benefits from reduced risk, according to Philip Simons, global head of trading and clearing sales at Eurex. “Porting is much less of an issue in this model. The position accounts, collateral accounts and margin accounts actually belong to the buyside client. So in the event of their clearing agent going into default, the buyside is fully protected and they just need to find another clearing agent to take over the contribution to default fund and the role in the default management process rather than having to port or even liquidate their collateral.”

And because banks are left with just the capital charge from the default fund contribution, and not the client’s margin call, the model makes clearing a less capital-intensive business for them.

ICE already offers a similar direct access model – a halfway house between full-blown CCP membership and traditional clearing arrangements and other CCPs are known to be following too. Simons though says the Eurex model has distinctive features.

“It’s very important to note that in our model a clearing agent is not sponsoring the end-client from a risk management perspective. From the clearing angle, there is no counterparty credit risk to the buyside client. If the buyside client went into default then we, the clearing house, would step in and take over the unwind process. In other models, it is still the responsibility of the clearing member to do that and that’s why other models don’t attract the same capital release that ours does.”

Eurex says interest in the model has been strong and early movers include seven clearing agents and more than 10 buyside clients.

Cross margining options

For CCPs with a dominant position in related financial markets, portfolio cross-margining has become another area of innovation that helps banks cut costs and keeps clearing business flowing. Indeed a key benefit of Deutsche Börse’s proposed merger with the London Stock Exchange is that it would allow firms to reduce the collateral they needed to post against swaps and futures cleared by Eurex and LCH.Clearnet according to Deutsche Börse’s chief executive Carsten Kengeter and others agree.

“Bringing together the best available pricing and optimal execution along with cross-asset collateralisation and savings would be a hugely popular and valuable offer,” says Satten.

When CME became the first to offer clearing offsets between euro/dollar futures and dollar interest rate swaps after mandatory clearing began in the US, it cleaned up the market partly because of the margining benefits on offer.

Hoping to do something similar, LCH recently launched a portfolio margining tool to offset margin between OTC and listed interest rate derivatives. It will be available on an “open access” basis to any trading venue connected to LCH.

Instead of posting collateral for each trade, cross-margining allows firms to net the collateral requirement for trades that move in opposite directions and act effectively as a hedge for each other. Concerns have been raised however about a model that reduces overall collateral in the system and fuels a move towards fewer, “too big to fail” CCPs.

However, the pressure on CCPs to compete on services and particularly cost shows no signs of abating. “Based on the US experience, we expect to see widening basis spreads between CCPs in Europe and a widened spread between US and Europe where the same products are traded”, says Satten. “In the US we’ve seen a widening basis spread, specifically in the interest rate market between CME and LCH, where you can get better prices on LCH because there’s more liquidity.”

Competition can only drive CCPs in one direction. “There will be more consolidation in the CCP market and more innovation,” says Liddy. “The question is how low are CCPs prepared to go in terms of riskiness.”

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Fixed income trading focus : Systematic internalisers : Geoffroy Vander Linden

THE ROLE OF SYSTEMATIC INTERNALISERS IN MIFID II TRANSPARENCY.

By Geoffroy Vander Linden, Head of Transparency Solutions, Trax.Be33-Web-21

With the 25 April 2016 release of the Delegated Regulation from the European Commission, Article 13 now sets out its final proposal for the determination of Systematic Internalisers (SIs) for bonds. The texts states: An investment firm shall be considered to be a systematic internaliser in accordance with Article 4(1) (20) of Directive 2014/65/EU in respect of all bonds belonging to a class of bonds issued by the same entity or by any entity within the same group…

This is an important distinction from previous proposals and leaked drafts of the regulatory text which has shifted from an instrument by instrument approach, to a class of instrument approach, to the proposed approach in the Delegated Regulation which is now by reference to both class of bond and the financial group of the issuer. An investment firm will be an SI if it trades on a frequent and systematic basis in liquid markets for all bonds in the same class, which are issued by the same entity or by any entity in the same group.

As an example, if an investment firm is deemed to be an SI for a specific corporate VW bond, the firm will be deemed an SI in all corporate bonds issued by any entity within the VW Group, and therefore it shall be subject to all pre- and post-trade transparency (trade reporting) requirements for all corporate VW bonds. A further implication is the requirement for SIs to provide its competent authority with reference data relating to financial instruments (e.g. VW bonds) admitted to trading or traded on its system.

What are the challenges?

A particular challenge of the 25 April Delegated Regulation will be the ability to determine what issuers form part of the same “group”. For the purposes of MiFID II, a “group” is defined by reference to the Accounting Directive, which includes (broadly) a parent undertaking and all its subsidiary undertakings. Group structure information is not readily publically available for all entities worldwide and even where it is available, it is not necessarily accurate. It will be very difficult for any firm to ascertain this with any reliable certainty and manage this information.

Taking the example above for VW – a quick glance on the VW website indicates that in addition to the twelve car brands, the group engages in a range of commercial businesses including financial services, within the VW umbrella. This example helps demonstrate the complexity with which corporations and their related entities may issue debt and thus the required data management burden.

The need for sophisticated solutions to help participants manage this level of complexity will be fundamental to ensuring regulatory compliance.

What’s the potential impact?


While it’s difficult to predict how the market will react once MiFID II is implemented, it’s reasonable to assume that investment firms will:

  • carefully review their trading behaviour in any one particular bond to limit any unnecessary market exposure as a result of becoming an SI in all relevant bonds of the same issuer, as well as;
  • extend that caution to the trading behaviour in relation to the financial group of that issuer, regardless of whether or not the different entities in the group are active in the same business sector.

One thing is certain, the proposed rules present greater operational complexity in meeting the challenge of determining SI status.

Accordingly, it is very difficult to predict whether or not the rules shall result in more or less SIs than would have been the case under an instrument-by-instrument determination, or even by a class of instrument determination. Presumably, it will result in less SIs than would have been created under the class of instrument proposal.Be33-Web-22

Importantly, given the consequent lack of clarity on the number of firms that will become an SI, market participants cannot assume that that bond markets will be flooded with SIs to take on the trade reporting obligation. It is therefore even more critical for all buy- and sellside participants to ensure they have relationships with Approved Publication Arrangements (APAs) to ensure they meet their transparency obligations under MIFIR. The workflow diagram indicates the trade reporting process for buy- and sellside firms.

What next?

It’s critical that all market participants understand how MiFID II will impact their business and take action to implement the necessary processes to meet their regulatory obligations. At Trax, we are working closely with the industry to ensure readiness ahead of the expected 3 January 2018 MiFID II implementation date.

We launched the Approved Publication Arrangement (APA) Demonstrator, a validation engine that provides an early opportunity for firms to view the effect of the MiFID II trade reporting regime. We have also developed further transparency solutions such as SI determination tools to assess whether a firm would be an SI at instrument level and to what extent a firm would be subject to pre- and post-trade reporting as well as reference data reporting obligations.

This article was first published online in the MarketAxess and Trax, Capital Markets Forum: www.capitalmarkets-forum.com

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Industry viewpoint : SmartStream : Haytham Kaddoura

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TOWARDS A NEW BUSINESS PARADIGM.

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Financial institutions are under mounting pressure to meet stringent budgetary controls and to respond quickly to incoming regulatory requirements, says Haytham Kaddoura, CEO, SmartStream.

SmartStream provides solutions and services to financial institutions. Aimed primarily at the back and middle office, these solutions and services also have a growing front office perspective. This reflects the increased importance of the post-trade aspect for the front office and, in particular, the potential impact it can have on the funding of trading activities.

Firms are increasingly turning to technology in order to comply with new regulatory requirements and budgetary controls. Our technology allows financial institutions to drive down operating costs as it enables them to restructure the organisation of their back office. Uniquely, SmartStream has developed a single technology stack – Transaction Lifecycle Management or TLM® – for the processing of transactions. By deploying SmartStream applications – which offer highly flexible workflow controls and have a great degree of scalability – organisations can rationalise and consolidate the number of solutions they have in use, as well as create an internal utility model and shared services. The same flexibility of design also means that financial firms can respond promptly to new regulatory measures or to market changes.

Driving innovation in the financial industry is a constant focus for SmartStream and the company has participated in a number of major strategic initiatives. The SmartStream Reference Data Utility (RDU), is another example. The first industry utility, the RDU responded to the pressing need across the financial industry for greater market data standardisation, as well as for higher levels of reliability and efficiency in the way data is managed. SmartStream joined forces with Goldman Sachs, JPMorgan Chase and Morgan Stanley to set up the RDU, providing services for instrument reference data normalisation and validation across all asset classes. The founding banks will also become clients of the utility.

Another initiative is the Accenture Post Trade Processing (APTP) utility, set up by Accenture, one of its technology partners and SmartStream. APTP combines Accenture’s global business process outsourcing capabilities and global capital markets industry expertise with SmartStream’s leading post-trade processing and technology services that support reconciliations, reference data, exception management and corporate actions processing.

SmartStream is well known in the financial industry as a market leader in reconciliations processing. Its strategic application, TLM Reconciliations Premium, reflects the company’s deep understanding of the transaction matching, exceptions and investigations needs of financial institutions – whatever the size of firm and regardless of the processes or the lines of business in operation. By using TLM Reconciliations Premium financial institutions are able to carry out reconciliations across all asset types, unlimited by volume or throughput. In addition, SmartStream has developed TLM SmartRecs OnDemand, a configuration component leverages the capabilities of TLM Reconciliations Premium via the cloud. It features a simple, highly intuitive, wizard-based user interface, as well as drag and drop capabilities. Its simplicity and ease of use make it an ideal solution for business users, enabling them to perform reconciliations tasks without the reliance on technical support. 

In recent years, SmartStream has delivered additional specialist solutions for account reconciliations, OTC, ETD and NAV reconciliations, as well as utilities services such as account receivables and last, but not least, treasury confirmations management.

Looking beyond reconciliations, SmartStream provides mission critical systems for the management of cash and liquidity. The company today delivers real-time liquidity management for the back-office and, importantly, for the front-office. By using SmartStream’s cash and liquidity management solutions clients are able to understand fully their exposure to trading activities on a minute-by-minute basis.

Another recent addition to SmartStream’s suite of TLM products is the TLM Collateral Management solution, acquired from IBM. This provides a fundamental contribution to our liquidity control platform and gives financial organisations the ability to manage exposures in an accurate, timely fashion. In addition, SmartStream’s TLM Corporate Actions solution delivers critical management of a client’s position at the trade level. It is also fully compliant with the SWIFT message lifecycle.

All of our solutions are underpinned by a common exception management layer. This allows firms to understand the lineage of exception failure, meaning that a failure at settlement can be traced back through all of its previous steps to the initial trade. Importantly, in recognition of the financial industry’s movement towards real-time processing, TLM solutions support real-time loading and processing, on receipt of transactions.

Financial institutions currently operate against a background of reduced staffing levels and we recognise that firms need additional support today with projects. SmartStream can make available remote configuration and project staff, highly experienced personnel who are able to assist customers to expand their utilities or to extend the use of SmartStream solutions within their organisations. SmartStream delivers solutions and services to meet the market demand for traditional on premise deployment but is also responding to the ever-increasing industry appetite for cloud and managed services. To this end, the company provides managed services – as BPO – for all solutions, including reconciliations, corporate actions and cash management.

Reflecting our belief in the necessity to the financial industry of a new business model – one which makes full use of BPO and managed services – SmartStream has established a Centre of Excellence (CoE). The CoE, which has been operating for eighteen months, enables the faster onboarding of reconciliations, as well as a full managed service for reconciliations processing. The Centre has seen a surge in interest and is being used currently by more than twenty major financial institutions. It is already delivering time and cost savings to clients, in some cases lowering the cost of implementing new reconciliations by as much as 65 percent.

In conclusion, SmartStream is fundamentally geared to drive forward BPO and managed services, across the back, middle and front-office. We believe that these services deliver not only substantial reductions in operating costs but also tangible benefits through the mutualisation of common operating processes within these new market configurations, improving not only cost but also quality and, importantly, process governance. 

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Market opinion : Blockchain & derivatives : Jannah Patchay

FULFILLING ITS POTENTIAL.

Applying blockchain technology to derivatives will have its challenges, but Jannah Patchay, Director, Agora Global Consultants argues that those who do not see the possibilities will be left behind.Be33-Web-49

Blockchain technology has, in certain circles, been touted as a death-knell for financial intermediaries, a disruptive power with the capability to completely transform financial markets infrastructure. And there is no doubt that it is an interesting and innovative technology with myriad potential uses. For those coming in from the cold, blockchain technology is not synonymous with Bitcoin, although the latter is dependent on the existence of the former, and is its most famous application.

The blockchain, in a nutshell, is a secure, decentralised, distributed digital ledger technology that provides all parties having access to it with a single view. Key characteristics include the immutability of entries (creating a permanent record and audit trail for every update made to the ledger), and the near-real time availability of data to all permissioned parties. So in essence, every entry is immediately accessible to all parties. Cue instantaneous payments, rapidly decreased settlement times for securities transactions, elimination of the need for time-consuming confirmations processes, and all the associated cost reductions from improved operational efficiencies and fewer reconciliations processes.

The benefits to retail banking and the equity markets, if done right, have been widely discussed in forums, blogs and white papers: lower transaction costs and speedier and more efficient settlement. Rather than tread this familiar ground once more, let us turn to the derivatives market, an area that is facing a deluge of almost biblical proportions from the vast torrent of new regulation directed at it following the global financial crisis.

Transparency, certainty of outcomes and reduction of systemic risk have been key drivers in the development of the new global regulatory regime for derivatives markets. The last crisis was arguably exacerbated to a massive extent by the uncertainty of banks in their understanding of their exposure to other banks, and the complexity of unravelling trading books and positions to understand, at the end of the day, who owed what to whom.

The Dodd-Frank Act introduced the concept of ‘confirmation at the point of execution’ on Swap Execution Facilities (SEFs), anticipating a world in which all transactions would be cleared and all trading participants would agree to execute with each other on the venue and immediately face off to a central counterparty (CCP). Sadly, for the idealistic rule-makers, in this earthly realm not all derivatives contracts are centrally cleared, and there remain significant questions around the feasibility of clearing some rather large classes of instrument, such as FX forwards and options.

As a result, regulators have imposed complex and prohibitive margin requirements for uncleared derivatives. Can blockchain technology save the day in this instance? The answer is rather complex. On one hand, the purpose of central clearing regimes is to reduce counterparty risk, in practice by the CCP taking on all counterparty risk exposure itself (perhaps not such a great idea given their commercial nature and imperatives, but that’s one for another day). Blockchain technology in this context does little to help, as by its nature it is a disintermediator, allowing counterparties to face off directly to each other.

On the other hand, if the goal of CCPs is to provide some certainty for parties in the case of a counterparty default scenario, a single distributed ledger provides a single consistent view to all counterparties and arguably provides them with sufficient transparency to anticipate what the outcome would be in a default scenario.

Can derivatives markets too, benefit from improved operational efficiency and cost reduction? Several banks are testing the concept of the ‘smart contract’ – a system in which blockchain technology is overlaid with an automated logic layer. Smart derivatives contracts would benefit both from being available to counterparties via the blockchain infrastructure but also from the ability to automatically trigger execution of certain contract terms as certain conditions are met.

An example might be an options contract that is automatically exercised when the target date or price is reached, or in response to specific market events. As soon as the triggering event occurs, the resulting transaction is executed and the blockchain ledger is updated. Simple, elegant and predictable in its outcome.

Barriers to entry

Regulators are not blind to the potential opportunities afforded by blockchain technology, particularly in the areas of market surveillance and monitoring of systemic risk. In a recent speech addressing the role of blockchain technology in the regulatory arsenal, Commissioner J. Christopher Giancarlo of the CFTC expressed his belief that access to the real-time ledgers of trading participants in 2007-2008 might have given regulators the ability to recognise anomalies in market-wide trading activity and counterparty exposures and to have better managed and mitigated the impact of the crisis.

Significantly, regulators around the world have recognised not only the potential that blockchain technology has to transform financial markets, but also the need for financial markets regulation to be agile and responsive to these innovations. This growing awareness is epitomised by the recent emphasis on collaborating with innovators and understanding new technologies, through initiatives such as the UK Financial Conduct Authority’s Project Innovate.

Blockchain technology does face significant barriers to entry in the derivatives space: complacency of market participants, attention focussed on coping with the influx of new regulation rather than looking for opportunities to innovate, the high cost of replacing existing infrastructure and migrating to new systems. On the other hand, if (or when) concepts such as smart contracts start to really take off, those following behind will find it difficult to maintain ground as the vanguard is able to offer more competitive pricing and improved services to clients.

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Market opinion : The impact of regulation : Mark Robinson

THE IMPLICATIONS OF A COMMON REGTECH AGENDA.

Mark Robinson, Research Analyst, JWG Group Ltd. argues the case for harmonisation and standardisation in this fast changing fintech world.Be33-Web-09

The push for increased transparency following the financial crisis has had an evident impact on the financial services industry. While it is in a safer place than before, the cumulative effects of multiple legislations and the inconsistencies therein have made regulation an imperfect game on both sides, as the recent MiFID II delay reveals quite well.

It is now being increasingly advocated that technology, applied in a collaborative and secure method, provides the best opportunity to achieve regulatory change more efficiently. Here we discuss the ways in which RegTech (regulatory technology) is already having an impact, and argue that with a concentrated effort from the regulators these technologies can be at the forefront of a revolution in the way policy is designed and implemented from now into the future.

As a regulatory think tank, the most prominent trend we have witnessed over the last decade is the increasing complexity of the regulatory landscape. Between 2009 and 2014, regulators published over 50,000 documents, more than a 500% increase compared to the previous 5 years.

The biggest burden has been the cumulative effect of overlapping regulations which do not share coordinated timelines or well-aligned agendas. Traditional approaches to managing the volume and multitude of regulatory changes have proven costly, slow and, in many cases, resulted in further complexity, confusion and fines.

However, recently emerging challenges such as Brexit, the Panama Papers tax scandal, and Climate Change, thrown into the mix make for a much more fatal concoction than there had been before. Now there is more urgency than ever to harmonise global standards for tax, risk reporting, and trading before policies fall through and financial institutions are grounded in unachievable requirements.

RegTech: a whistle stop tour

Fortunately, this build-up in complexity in recent years has coincided with the rapid development of emerging technologies such as big data, blockchain, and artificial intelligence, which have the potential to alleviate much of the regulatory burden.

Growing availability of large pools of data has been paralleled by the increasingly intelligent use of them. Big data advances are helping technologists provide solutions such as the enrichment of transaction data with market data to prove best execution compliance. New forms of artificial intelligence are utilising pattern recognition in trade flow monitoring for AML purposes to easily flag suspicious trends and trigger alerts to the right people in ways that manual processes never could.

Migration to the cloud is increasingly being seen as a cheaper and more efficient method to report to the regulators, particularly due to its dynamic attributes in an age of continually changing regulation. This movement is joined by the push for open data and data sharing (led by HM Treasury) accompanied by an open banking standard for the exchange of information – much needed for those measuring interconnectedness and systemic risk.

In their search for transparency, regulators have found blockchain a perfect match. Though distributed ledgers (the technology behind blockchain) may require further proofs of concept before competing with more established technologies, their potential to remove the need for intermediaries in the financial services ecosystem could simplify entire clearing and payments systems and counterparty risk.

One example is with smart contracts – which offer a self-paying, fully automated financial contract between counterparties that eliminate the need for any registration or verification. Regulatory requirements focusing on collateral, settlement and dispute resolution would all be solved with one computer protocol.

Observably, technology providers are cropping up across the solution base to bridge the divide between what firms have and what regulators expect to see. Regulators too are increasingly taking an interest; establishing innovation hubs, publishing position papers, and signing collaborative agreements with one another. As it stands, RegTech offers a world of exciting possibilities.

Concentrating efforts

As interest from across the industry has accumulated, many actors – particularly technology providers – have been calling for standards to be put in place before interoperability issues prevail. Regulatory agendas for innovation will likewise require harmonisation before they too diverge and lead us astray from the foundations required at the start of this new field.

In order to address the standardisation issue at its heart, regulators could harness these new technologies to establish a policy hub, or semantic ontology, that centrally hosts the entirety of their legal document library in a common digital format. For regulators, the more jurisdictions hosting their rules in the hub, the more of them can be mapped to one another and compared, revealing gaps and duplicate requirements in regulatory regimes that can subsequently be realigned.

With the power of rule-based algorithms and an open API to map the rules onto any firm’s internal organisational structure, firms can query what obligations they are subject to and what functions need to change. Regulators could conduct detailed impact assessments on the effect of proposed policies across the industry before they are implemented. Serving as a standardised language for regulatory requirements the hub could then be used as the basis for new industry standards for RegTech initiatives such as blockchain and open data, fuelling their widespread adoption.

Change management

From the viewpoint of firms, one of the major roadblocks to migrating from the predominantly manual processes currently used towards a holistic and common approach to compliance, such as that described above, is the risk involved with doing so. “I don’t think we can overstate the hurdle that legacy issues represent. Fixing them and getting to a point where data can be provided easily and readily is hard and costly.” said Mark Braddock, commercial director at RecordSure.

Fortunately, this could not be a better time for pushing the RegTech agenda forward – observers are now noticing that the MiFID II delay has given firms the time to reduce their “tech debt” (inferior aspects of the technology environment, resulting from firms being forced to rush to meet tight compliance deadlines) and amalgamate their reactive processes into cross-organisational databases with more dynamic and comprehensive compliance engines.

In this dynamic regulatory landscape, the use of digital policy to provide interoperability standards and serve as a platform for the innovative yet harmonised use of new technologies is an agenda that we can all get behind. It is these foundations that need sorting first.

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Fixed income trading focus : Technology driving change : Umberto Menconi

MAKING READY TO FACE TECHNOLOGICAL AND STRATEGIC CHALLENGES.

By Umberto Menconi, Market HUB E-Commerce Distribution Banca IMI.Be33-Web-23

The European fixed income market has been recently facing unprecedented changes and will continue to do so for several years, mostly driven by technological innovation and regulation. The old‑style bond trading models, such as RFQ and OTC high touch, are the focus of much discussion and while there are signs of new models/protocols emerging, no clear view has so far emerged on how the secondary bond market will look in coming years.

The consultancy firm McKinsey issued a working paper on corporate & investment banking on the 28th October 2015, forecasting a near-future Wall Street dominated by the use of “machines” and financial institutions forced to heavily invest in “digital” technology (from electronic trading, to blockchain, big data management and algo-trading). The paper also highlighted a decrease in human intervention across the STP chain from front to back office functionalities. At the same time, an increasing number of industry reports has highlighted that regulatory changes have led to a 70% drop in bond inventories, yet the stock of fixed income assets outstanding has doubled on the back of years of low interest rates. All in all, this has led to major liquidity shortages as fixed income traders have had to become accustomed to an era of trading in an environment with a dearth of liquidity.

Basel III and other post-crisis legislation (the Dodd Frank Act in the USA and MiFID II/MiFIR in Europe) have brought about structural changes in the way credit institutions have had to reduce their asset inventories, and the capacity to hold, finance, or hedge trading positions, and pare back their long-held intermediary roles as principal. The reduction in balance sheet due to Basel III, combined with investors’ reluctance to trade, has led to a diffusion of liquidity across platforms.

This is particularly the case in corporate bonds where it is often heard that liquidity is “a mile wide and an inch deep”. Sourcing and aggregating liquidity is paramount for sellside and buyside traders. Technology is the only way to enable these participants to uncover the liquidity available. As a consequence, the traditional bond trading model, mostly reliant on market makers and voice broking is being reshaped.

The principal-to-principal model still remains central on the dealer side, but with more weight being placed on agency brokers and on new trading protocols (e.g. all-to-all trading, central limit order book, anonymous auctions, indication of interest). In Italy in particular, due to its particular market structure, solutions that put together price provider specialists and fixed income trading venues in a sort of virtual book, with a combination of different market protocols and commission fee models, have been available since 2007.

The role of sales and market maker will change heavily due to tighter spreads and lack of liquidity, hence low touch will improve, and high touch will only be reserved for very highly profitable tickets. This change will be a gradual shift from a one-stop-shop (supported by strong bilateral relations) towards a multilateral trading solution. We believe that the specialisation of market makers around the world can recreate liquidity through some type of ‘hub of hubs’ or ‘web net’, comprising regional specialised liquidity providers, authorised as systematic internaliser (SIs).

A SIFMA report in 2015 on new US electronic bond trading platforms released the results of a survey of more than 20 electronic bond trading platforms for US corporate and municipal securities, while an ICMA electronic trading platform mapping study in 2016 analysed more than 24 European trading platforms.

Both results highlighted that the fragmented environment will lead to a concentration process in the near future. In Europe, trading venues will compete to harmonise the pre- and post-trade regimes, evaluating the threshold effects and impact on on-venue trade size, with transparency and electronification/STP processes as a key competitive advantage.

In this new marketplace, the role of the buyside and the sellside is being reshaped at many levels. The bigger buysides in particular need to take on a greater responsibility, playing an enhanced role in the new market environment, and in the market infrastructure evolution from a trading process based on RFQ and ‘polling’ the market to more standardised practices.

The new transparency regime may also impact issuers behaviour and the size of issuance (‘threshold effects’), as well as promoting more automated practices in new issues distribution. A good balance between transparency and liquidity thresholds may avoid the possible negative impact on SMEs (small and medium-sized enterprises). The considerations over the possible impact on market liquidity of a wrong calibration of transparency obligations, together with the need to complete MiFID II level III requirements are among the reasons for the delay requested by the European Authority on MiFID II implementation.

Paramount in this phase is the role of vendors in supporting market players still wondering whether to use in-house or external solutions in order to to fulfil pre and post trade transparency, trade reporting, best execution and SI obligations.

Technology is the key and also the ‘passport’ to this change. Innovation is vital in supporting the radical changes across the scope of financial asset classes, from those where more traditional trading behaviour is still central (with particular reference to corporate bonds), to others that are leveraging changes already in place in other asset classes.

Firms are re-directing their business strategies to adapt to the changes in fixed income. The requirements will of course need huge technological investment and this might constitute an entry barrier to new players and reduce their number due to the high levels of competition.

©BestExecution 2016[divider_to_top]
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Fixed income trading focus : Future of the bond market : Russell Dinnage

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BOND TRADING: A BRIGHT, BUT CHALLENGING FUTURE.

By Russell Dinnage, GreySpark Partners lead consultant.Be31_RussellDinnage

A May 31 blog post on Tradenews.com asking, “Is the bond market dead for good?” provoked a flurry of social media discussion among a range of different types of fixed income market participants. In particular, the conclusions of the largely anonymous points of view of a number of buyside market participants voiced in the blog post largely boiled down to (in paraphrased form):
  • ‘Yes, the bond market is dead;’
  • ‘MiFID II pre-trade transparency requirements killed it, evidenced by declining sellside FICC revenues seen so far in 2016;’ and
  • ‘The only solution to the problem is to further delay the implementation of MiFID II or, at best, revise it by reneging on the pre-trade transparency proposals for bonds trading.’

These buyside perspectives on the challenges facing the bonds market – specifically, corporate credit – in the EU in the future are not completely accurate. Yes, it certainly is true that MiFID II’s objective to apply the same standard for pre-trade transparency in the exchange-traded equities market to the bonds market – which largely trades on an OTC basis – will increase the already high degree of difficulty associated with selling illiquid corporate bonds.

The reality though is that – by definition – it has always been difficult for bonds traders of any ilk to source liquidity in and then price illiquid corporate bonds trades; in that respect, the implementation of MiFID II’s pre-trade transparency mandates will only serve to make an already challenging corner of the bonds market more challenging. The nature of that challenge, however, has not changed, and the remedies it requires definitely do have a solution, despite the suggestion of the blog post.Be33-Web-17

The promise of an exchange-traded future

Naturally, the 42 new electronic corporate bonds trading platforms launched since 2007, according to GreySpark Partners analysis, have a role to play in mediating the liquidity sourcing and price formation challenges posed by regulations like MiFID II. Specifically, it is interesting to note that, while the majority of the all-to-all (A2A) or client-to-client (C2C) corporate credit venues launched since 2013 remain focused on facilitating anonymous block-size trading, many of them now offer users access to lit axe trading or odd lots liquidity pools. Furthermore, some of the platforms in both Europe and the US are now integrated with the leading buyside order management systems to scrape blotters for small-size line items in an effort to automatically lubricate the corporate credit market with a necessary amount of liquidity depth designed to allow it to remain functional at a certain baseline level on a daily basis.

Electronically facilitated block-size trading remains the Holy Grail for buyside, sellside and exchange platform operators alike, and all of those types of market participants frequently freely admit in 2016 that they do not foresee a future in which a trading venue would be able to service demand for such tickets without some degree of bank intermediation via the balance sheet. The goal then becomes, for both A2A and C2C block size-centric corporate credit trading venues, to develop a series of workflow methods or protocols that allow sellside counterparties to increase the velocity at which large ticket trades in illiquid bonds can be shifted off their balance sheets and back into the marketplace.

The rank of banks that can legitimately claim leadership in corporate credit trading across a variety of small and large tenor sizes, instrument types and currency denominations has undeniably thinned in recent months. The bulge-bracket dealers that remain strong in the marketplace succeeded in doing so by either renovating their fixed income business and trading models into hybrid principal-agency models (see Figure 1) or they set out their bonds trading stalls to become the leading corporate credit intermediaries in the marketplaces where their reputations as regional specialists are already established.

However, there remains a large number of bulge-bracket and regional dealers who are unwilling or unable yet to adjust their fixed income business and trading models. This constituency of banks are unwilling or are unable to do so because of the constraints placed on the utilisation of their balance sheets by Basel III to warehouse risk, which prevents them from being able to match the liquidity sourcing and price formation demands of the marketplace in its current form and still maintain the ability to eke a modicum of profitability from every bonds trade that they do on both a principal and on an agency basis.

The necessity of an independent mid-point reference price

In order for the illiquid portion of the corporate credit market to address not only the legitimate, medium-term challenges posed to it by MiFID II pre-trade transparency requirements and the long-term challenges posed to it by Basel III and the Basel Fundamental Review of the Trading Book proposals, the corporate bonds market as a whole must find a way to spawn some form of independent mid-point reference price. Doing so would solve the dilemmas posed by MiFID II and by Basel III that are currently challenging the workings of the market’s structure.

Specifically, an independent mid-point reference price could be used by market participants – along with other proprietary or vendor-provided historical pricing data – to develop values for trades in the illiquid corporate bonds that make up the bulk of the estimated 250,000 ISINs available globally to trade on any given day. As a result, a necessary level of pre-trade transparency required by MiFID II to allow block-size trades in illiquid instruments to shift onto exchanges could reasonably be developed. In turn, the depth of liquidity available to trade on the exchanges could then increase organically over time.

This turn of events could then serve as the trigger enabling a higher level of buyside and sellside support for dark environments in which they are able to not only accurately gauge how to situate pricing for their own indications of interest or firm orders, but also to gauge the pricing waters around bonds they are interested in trading in block-size, breaking parent orders into child orders or trading in bulk based on the presence of fair pricing close to the mid-point received in response to a resting order.

This theory, explored in a recent piece of GreySpark Partners research, is supported by the supposition that a truly independent mid-point reference price for corporate credit trading would ideally emerge from the formation of a deeper and more robust retail market for trading the securities. For example, there already exists a historical market for retail investor bonds trading in Italy that, in 2016, is focused within EuroTLX, which – in addition to retail venues such as the London Stock Exchange’s Order Book for Retail Bonds platform – services retail corporate credit demand across Europe. Likewise, in the US, retail investors gain access to corporate credit liquidity via mutual funds and mutual funds indices. Meanwhile, the rapid growth of the fixed income ETF market witnessed since 2013 serves as a marker for wholesale market support for a wider range of retail-level entry points for investor exposure to the corporate bonds marketplace in both Europe and the US.

Despite these early-stage signs for the potential long-term development of a more robust retail market for corporate bonds trading, there remain significant hurdles to the ability of large buyside investors to link pricing for specific ISINs in retail markets as a means of creating their own independent mid-point reference rates for block-size trades in existing lit or dark electronic dealer-to-client or dealer-to-dealer venues. If these hurdles are ever overcome, it will be as a result of significant changes in the buyside’s cultural attitudes toward fixed income trading price formation workflows in general and toward corporate bonds price formation specifically.

©BestExecution 2016[divider_to_top]

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Fixed income trading focus : Primary markets : Herb Werth

CORPORATE NEW ISSUANCE: A MARKET READY FOR INNOVATION.

By Herb Werth, Managing Director, Buy Side Product Strategy and Marketing, IPREO.

Be33-Web-24As 2015 drew to a close, the growth in primary issuance of corporate bonds, a constant since 2008, was in doubt for the coming year. Market volatility reared its head early in the first quarter, and as a result, 2016 was off to a bumpy start. One of the trends we observed was that as markets became volatile, new issuance slowed to a virtual standstill; however, as the volatility dissipated, often many issues in the pipeline came to market simultaneously. This created a stop/start pattern with a number of very busy days for both syndicate banks and investors.

Continued low interest rates and the European Central Bank’s decision to invest in corporate bonds further fuelled a market hungry for new issues. As a result, a stronger and more consistent pattern of primary issuance emerged in the second quarter.

Both the stop/start pattern of the first quarter and the heavy, constant flow of deals in the second quarter present numerous challenges to both the syndicate banks and investors due to inefficiencies of the new issuance process, which are detailed below.

A flood of unstructured data

Let’s start by understanding what happens in the course of a single deal. When the issuer and syndicate banks decide to bring a deal to market, it’s announced by passing the terms and conditions of the deal to the banks’ sales teams, who in turn, send it on to their clients on the buyside. This is primarily accomplished through a text-based announcement email that is forwarded along in this process. Most deals have multiple active book runners, and in many cases, the salespeople at each of those banks overlap in coverage of the buyside. As a result, the buyside trader will receive the same information multiple times – once from each of the salespeople that are affiliated with each bank on the deal.

A far too manual process

The buyside trader needs to now take that information and distribute it within his firm, to the portfolio managers and analysts, and possibly also to the operations team that set the deal up in the firm’s compliance, order management and risk systems. If any updates to the terms become available, the trader needs to again quickly route that information to the appropriate parties. Sometimes this is accomplished by directly forwarding the information that is sent by the sellside banks, in other cases, the trader aggregates the deal information for that day into a spreadsheet and emails a summary sheet on regular intervals. A few buyside firms have even gone as far as to invest significant amounts of money in internal systems to capture and distribute this information to become more efficient.

Once the deal information is available to the portfolio managers, they decide if they would like to participate in the deal. This is often done via email, chat or phone back to their buyside trader. The buyside trader then needs to aggregate orders from multiple portfolio managers to determine his firm’s overall demand. Next, the trader communicates this information back to his sales coverage. Multiple banks means multiple salespeople, and consequently, multiple communications of the same information by the trader. When allocations are determined, the process reverses once again and emails and chats are used to inform the buyside trader of his firm’s allocations.Be33-Web-25

Clearly, the process of managing new issue participation on the buyside is quite cumbersome and time intensive. The buyside trader is put in a difficult position and is most concerned about missing inbound information from either the sellside (deal updates) or his investment teams (order updates). The existence of many deals at the same time, as discussed earlier, compounds the problem. Buyside traders can be shown five, ten, even twenty deals in a single day. That’s a lot of unstructured information and manual co-ordination. The largely administrative tasks of consuming deal information, co-ordinating with portfolio managers and communicating instructions to the sellside on a day with many deals in the market often leaves the trader with little time to do the rest of his job.

Room for improvement

Notwithstanding the workflow inefficiencies, deals get done. This is because the market has applied enough brute force to the problem, there is an established ‘protocol’ between the buyside and sellside, the sales person on the sellside serves a critical role, and banks are experts in the legal and regulatory aspects of running a deal and ensure that deals are brought to market properly.

Improvements can be made to lessen the strain on the buyside trader by drastically reducing the amount of time spent on clerical tasks and simultaneously lowering the risk that is inherent in a highly manual process. In particular, consensus is building around the following changes:

  • Thoughtfully apply technology to improve the quality of deal-related communication so that information can be more easily consumed and organised.
  • Improve the current methods of alerting market participants (especially the buyside trader) in order to reduce the risk of missing deal announcements, updates, and orders from portfolio managers.
  • Increase the auditability and visibility of new issue related information.
  • Exchange order and allocation information electronically, reducing the possibility of manual error.
  • Reduce the massive administrative workload for both the buyside and sellside enabling them focus on more value-added activities.

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The overall sentiment that we regularly hear is that the new issue market can benefit from thoughtful innovation. Technology can certainly help, but consideration needs to be given to those elements of the process that are working well today. The best solution will preserve those things that are working well while improving those areas that are not, and in the course of doing this, advance today’s market practices for the ultimate benefit of both issuers and investors.

©BestExecution 2016[divider_to_top]

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