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Addressing Technology Debt

GreySpark01-Technology Debt
GreySpark01-Technology Debt

Addressing Technology Debt
Managing the Unintended Consequences of Regulatory Change
A new GreySpark Partners report, Addressing Technology Debt, outlines principles on how financial markets organisations can proactively manage and reduce technology debt. Technology debt observed in 2015 occurred when companies applied a series of tactical bolt-ons or hacks to existing software platforms that created negative effects for the business. These repercussions were often exacerbated when regulators failed to articulate or complete new rules, or when they failed to provide companies with unambiguous, quantitative, verifiable requirements in good time. Repayment of technical debt is typically done in lieu of more important business processes, which is generally an anathema to stakeholders unaware of the impact of technology debt.

https://research.greyspark.com/2015/addressing-technology-debt/

Buyer’s Guide: FX E-trading Systems

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GreySpark02-FX E Trading

Buyer’s Guide: FX E-trading Systems
The Evolution of Vendor Offerings for FX Trading
In 2015, the technology vendor landscape for FX e-trading platforms and systems has achieved a state of maturity in terms of sophistication that remains unique within the capital markets arena. As a result, a plethora of incumbent and emerging software and hardware providers are competing for buyside and sellside market share that increasingly demands innovative, infrastructure-focused solutions addressing the need for full trade lifecycle services across flow FX and FX options instruments.

https://research.greyspark.com/2015/buyers-guide-fx-e-trading-systems/

Buyer’s Guide: Alternative Market Data Vendors

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GreySpark03-Market Data

Buyer’s Guide: Alternative Market Data Vendors
Challenging, But Not Impossible
Efficient functioning of capital markets trading firms relies on timely, accurate and reliable market data. Today, firms spend vast sums ensuring that everyone across their organisation has access to data thats meets their specific needs. Since 2007, the financial services industry has focused its energies on streamlining its business lines to enhance operational efficiency, and regulators are pushing hard to improve market transparency, which inevitably leads to increased compliance costs. These twin drivers mean that banks are concentrating on how to reduce the cost of market data.

https://research.greyspark.com/2015/buyers-guide-alternative-market-data-vendors/

 

 

 

Buyer’s Guide: Sellside Cash Equities OMS and EMS

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GreySpark04-Buyers Guide OMS EMS

Buyer’s Guide: Sellside Cash Equities OMS and EMS
A Plateau in Cash Equities Technology
In 2015, a broker wishing to select a technology solution for cash equities trading has a wide spectrum of choices. With core order and execution management functionality commoditised, the solution differentiation lays in the value-added functionalities that will support a broker’s specialisation. GreySpark’s report is an independent guide to the leading vendor offerings for cash equities order and execution management systems (OEMS).

 
https://research.greyspark.com/2015/cash-equities-oms-and-ems/

RMB Internationalisation

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GreySpark05_RMB Internationalisation-Part2

RMB Internationalisation

Translating Policy Into Practice

For further information, please Contact Us Concern about decreases in the rate of growth of China’s economy is both a pervasive and tenacious perspective in the media. While it is true that China is dealing with many troubling economic issues, the careful, incremental and long-sighted way in which reforms are being introduced should reassure international investors. Undeniably, foreign investment into China is becoming easier, and positions in Chinese capital markets can be unwound more quickly than in the past. This report describes the landscape for investment in China as well as the programs and schemes facilitating it.

https://research.greyspark.com/2015/rmb-internationalisation-2/

Rebooting the Corporate Bonds Market

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GreySpark06_Rebooting Corp Bonds Mkt

Rebooting the Corporate Bonds Market

Electronic Trading to the Rescue of a Broken Market

GreySpark Partners presents a report examining how an unprecedented wave of innovation is reshaping the market structure for corporate bonds trading. A re-evaluation of the corporate bonds market’s trading model by buyside firms and investment banks active in the marketplace is necessary because, between 2007 and 2014, secondary markets liquidity dried up.

https://research.greyspark.com/2015/rebooting-the-corporate-bonds-market/

Best Practices in Managing Conduct Risk 2015

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GreySpark07_Conduct Risk

Best Practices in Managing Conduct Risk 2015

The New Regulatory Frontier for Risk, Compliance and Operations in Financial Institution

Following the financial crisis, conduct risk has emerged as an important agenda for capital markets regulators. As regulatory reforms change the structure of capital markets, law makers are increasingly examining the behaviour and conduct of market participants with a view to imposing fines and other penalties for actions that may have only incurred a warning in the past. As a result, sellside and buyside institutions are leveraging internal resources as well as external assistance to develop best practices for addressing conduct-related risks.

 

https://research.greyspark.com/2015/bofnk/

RMB Internationalisation

GreySpark08_RMB Internationalisation 1
GreySpark08_RMB Internationalisation 1

RMB Internationalisation

Easing Foreign Investor Access to Mainland China

In 2014, China’s currency – the Renminbi (RMB) – passed several key milestones on its way to becoming an international trade and investment currency. RMB internationalisation is a process whereby the Chinese currency will eventually become fully convertible with other currencies and inward and outward RMB-denominated direct and portfolio investment controls are relaxed. RMB internationalisation, a long-standing objective of the Chinese government, is slowly becoming realised through a program of government-mandated initiatives that include both regulatory and legal reforms, as well as economic infrastructure development. However, the ongoing success of the internationalisation process hinges on the alignment of this state-sponsored change programme with global macroeconomic and market forces driving demand from foreign investors for financial exposure to the Chinese market.

 

https://research.greyspark.com/2014/rmb-internationalisation/

Upcoming Regulation: Changing The Trading Technology Landscape

By Sacha Fellica, Global Product Manager, Sales and Trading, Bloomberg

After the crisis of 2008 a host of new regulation has been introduced and has driven many of the changes in the trading technology arena. This article examines how the upcoming MiFID II and recent regulation such as the Market Abuse Directive (MADII) and Market Abuse Regulation (MAR) will continue to drive this change. Particular attention will be paid to potential implementation challenges that these pieces of regulation will bring and some suggested solutions will also be presented.

Best execution under MiFID II

A key focus for the regulators post MiFID II will be monitoring how market Sacha-Fellica-Crop1participants will comply with their obligation to provide best execution to their clients. MiFID II does not steer away from MiFID as it pertains to the “best ex” obligation but does offer a step up in the wording asking participants to take “sufficient” instead of “reasonable” steps to provide best ex. Therefore the focus on the multi-factor approach (price, cost, speed, likelihood of execution and settlement, size and any other relevant consideration) will still stand. It is also clear that particular attention will be paid on how best ex is applied to non-Equity asset classes such as FX, Fixed Income, Derivatives and Contract-Based Instruments.
Market participants will be required to develop easily accessible best ex policies and clearly communicate these to clients. Regulators appear to be eager to ensure that appropriate best ex monitoring is in place and that the results of the monitoring process are fed back into the way in which firms run their business. For example the UK regulator, the FCA, which has been very active in driving the best ex agenda, during their Thematic Review published last year,[1] concluded that ‘most firms are not doing enough to deliver best execution through adequate management focus, front-office business practices or supporting controls’.
This means that from an implementation perspective regulated firms have their work cut-out; they will have to address the shortcomings highlighted by the regulator and also enhance their best ex framework to be multi-asset if this is not in place already. From a data consumption perspective the new best ex framework will substantially increase the amount of data that will have to be captured and analysed. Sub optimally implemented TCA processes will be therefore placed under substantial strain from the new requirements. It is therefore reasonable to expect that a significant part of the MiFID II implementation costs will be directed to solve the data problem that the new best ex framework will offer. Unresolved issues such as the lack of a European Consolidated Tape will continue to impact the quality and cost of implementing a TCA process for Equities and the renewed focused of providing best ex for asset classes that lack price transparency will bring new challenges.
The regulators will carefully scrutinise how firms implement their best ex process and integrate its results to their core business. Therefore it will be critical that firms will work hard on enhancing the integration between their OMS and TCA system. This will help dramatically towards improving the outcome of the TCA process and its ease of use whilst seamlessly integrating its results with the OMS where the core business is managed. Because of the strong focus on best ex outside of Equities, the new framework will have to thoroughly support other asset classes. Therefore from a data perspective it will be important to obtain and create reference prices from all available sources (RFQ systems, leading composites such as WM for FX and CBBT for Fixed Income or modelled prices for very illiquid instruments).
As it pertains to the accessibility of the results and the disclosure of the best ex policies to clients, a suggestion would be to move to easily accessible and consumable reporting formats such as portals instead of static pdfs or printouts. This will help dramatically a firm to explain and summarize to its clients, how venues are selected, what execution strategies are employed and how the firm generally monitors TCA.
Standards such as FIX should be used wherever appropriate in order to bring the cost of implementation down. Prime examples of how FIX can be used to drive costs can be found in the Market Model Topology (MMT), very relevant for TCA reporting in that it harmonises condition codes across venues, and the now widely utilised tag 30 (Last Market) and tag 851 (Liquidity Indicator).

Monitoring and accessing liquidity under MiFID II

When focusing on liquidity issues post-MiFID II it is appropriate to consider separately the Equity and the OTC worlds. As it pertains to Equities it is clear that the dark trading caps[2], affecting trading under the Reference Price Waiver (RPW) and certain type of negotiated trades, will be the main challenges to address.
If a stock will breach any of the two caps it will be banned from trading in the dark for six months and trading for that security will have to move to lit venues. Undoubtedly this will be a significant change and whilst it is still uncertain how market participants will respond, it is clear that trading under the Large in Scale (LIS) waiver will become increasingly significant. There is a feeling that the trading caps might put an end to trading under the RPW since it will be very difficult to monitor how close a stock is approaching its limit especially on a consolidated basis. Some market participants have therefore already started to look at ways to encourage LIS trading. Noticeably the BlockDiscovery service offered by Turquoise with the use of conditional orders, the introduction of a midday auction from the LSE and the creation of the Plato Partnerships are some initiatives that have recently materialised.
From an implementation perspective it is therefore clear that it will be important to build solutions that will allow easy monitoring of block trading activity across venues. The same can be said about the use of block discovery analytics and analytics that will flag quickly and easily when a position or order qualifies to trade under the LIS waiver. Further implementation challenges will apply to algorithms which will have to be recalibrated in order to deal with the introduction of new intra-day auctions. In this case the algos’ capability of pausing from continuous trading, switching into auction and back again to continuous trading will have to be added. Moreover the algos’ participation and slicing logic will also have to be recalibrated; this is so that the execution strategies will be capable of coping with additional auctions and the opportunity of interacting with larger blocks of liquidity.
Switching to the liquidity challenges facing the OTC market, there is an on-going debate within Fixed Income which is centred around the calibration of the pre-trade transparency rules. Many institutional investors are concerned that illiquid instruments might get classified into liquid buckets under the pre-trade transparency regime. The concern is that an incorrect classification of instruments might result in additional thinning of liquidity, the surge of predatory strategies, higher costs for investors and increased market volatility. A lot of discussions are also still on-going as it pertains to what needs to be done with the publishing of individual RFQ prices. Some institutional investors are backing the idea of publish a composite average of received quotes by volume bands whilst others are in favour of the creation of a quote batching system with built-in delays for publication.

Trade surveillance under the Market Abuse Directive (MADII) and the Market Abuse Regulation (MAR)

Lastly moving on to new regulation that has been recently introduced but where there is still huge scope for system and process improvements, MADII and MAR continue to be at the forefront of the regulators’ agenda. Generally surveillance processes monitor market abuse by applying a “sampling” approach to analyse a firm’s order flow. A suggestion for improvement would be to use an exception based monitoring approach instead. This would enable a firm to monitor all of their order flow and focus only of the exceptions generated once that the surveillance process has been calibrated accordingly.
The surveillance tool should then be further enhanced to capture all relevant electronic communications (emails, voice calls, file exchanges and website visited to name a few) into a data store in order to provide point in time analytics of the exceptions highlighted by the tool. The proposed solution would allow users to reconstruct a trade and pool in every relevant piece of information that happened around that trade (communications, news, events, and so on) and offer a very powerful investigative tool. Whilst the surveillance and best ex processes are separate bringing these two closer will eventually provide further efficiencies to the users.

Conclusions

In conclusion regulation will continue to drive changes within trading technology over the next 2 to 3 years. From a best ex and trade surveillance perspective, it will be important to implement a multi asset TCA process and move away from a sampling approach and towards exception based surveillance. It will be critical to ensure that the results of the monitoring processes will be integrated to the core of the business as regulators will pay particular attention to this. Different challenges will impact the liquidity of Equities and OTC asset classes. For Equities trading under the Large in Scale waiver will become critical as market participants will focus heavily on trading in blocks as much as possible. For OTC asset classes such as Fixed Income the calibration of pre-trade transparency requirements will be a critical issue. Finally as an additional comment it is very apparent that the trading of OTC asset classes is becoming increasingly more electronic. This means that what has been learned from the Equity experience can be applied to OTC asset classes too. However it will not be possible to simply port Equity technology to cater for OTC trading as the nuances of the different after class will have to be accounted for.
[1] TR14/13: Best Execution and payment for order flow, July 2014: https://www.fca.org.uk/static/documents/thematic-reviews/tr14-13.pdf
[2] 4% on the amount of trading in a stock that can be carried out on any single dark pool
8% on the amount of trading in a stock that can be traded across all dark pools
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Profile : Keith Saxton

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LETTING GO OF THE PAST.

Keith Saxton, chairman of the Financial Services and Payments Programme for techUK, explains why banks need to move technology to the top of their agenda.

What are the greatest challenges facing financial service institutions from a technology perspective?

In the past, the industry would look at big events in terms of being a bull or bear market. This drove a great deal of behaviour and if there was a downturn, banks would make cuts and then when revenue returned they would hire armies of people back to deal with the backlog of work. The financial crisis changed everything. Today they can no longer rely on past behaviour because the business model has fundamentally changed due to regulation. Revenue streams have been damaged and return on equity is down to the 2% to 4% range for the major UK banks versus the teens in the fifteen years prior to 2008. We have had a number of conversations with banks and there is a great need for infrastructure revival and a new way of thinking about technology. However, many firms look at technology as a barrier, but they should see it as an enabler to change parts of the value chain and help deliver higher returns. We see many examples of technology and new services being deployed, although the underlying infrastructure remains inflexible.

What progress has been made from your first White Paper?

There has been movement since the publication of our first White Paper – Towards a New Financial Services – over a year ago. The majority of companies have developed new technology strategies and begun initiatives but some are farther ahead than others and in general, in all but a few cases, real momentum is lacking. One reason is that banks have been reluctant to take the risk and incur the significant cost involved in moving from their old legacy platforms.

We have just published a second White Paper – Taking the Initiative: Leading with Technology in Financial Services – which expands on this theme. It not only discusses how legacy systems are limiting the progress banks can make but why and how they need to implement a completely new return on investment approach with technology. The aim is to build competitive, agile, fully inter-operable systems that will benefit the clients and create new products.

What is the main thrust of the second White Paper?

There are three distinct sections. The first is that financial service firms must change core systems to make better use of cloud technologies, allowing for an agile response to shifting consumer demand and regulatory requirements. Second, incumbents must use data and analytics to enhance performance. While the last section shows a renewed emphasis on customer experience is needed to improve customer satisfaction. All three areas need to be addressed concurrently to drive competitive value.

Can you go into more detail about the use of the cloud?

In the past, the saying was that banks spent 80% of their time running the business and only 20% on innovation. Today I think that 80% of the 20% is spent on regulatory compliance. Unless these projects are collectively renewing systems and collapsing data silos the investments will not be effective. We definitely see the cloud and cloud enabling technologies playing a greater role for financial service firms especially in terms of addressing the issues associated with legacy systems. One of the main problems is their inability to extract information and link the data. The cloud, on the other hand, is able to better to respond to additional volume of activity and changes in customer or regulatory requirements. Firms should be able to build localised clouds which use APIs (application program interfaces) that transfer data without collapsing the system, and allow for that data to be exposed for analytics and insight.

Adoption has been slow not only because banks are reluctant to move away from their old systems but also cloud technology has yet to gain the full approval of the regulators. This is changing as the Financial Conduct Authority and other regulators are now more interested to engage with the sector and suppliers to discuss how cloud might be more extensively deployed to access the intrinsic improvements available in operational risk management, cost, availability and security. I think when this happens, cloud-based systems will be the default option across the sector.

How can banks better leverage their data?

BE29-KEITHSAXTON-TECHUKThere is a great deal of discussion over big data. Many of the larger financial services firms have significant amounts of data but they are often held in silos and not integrated throughout the organisation. A more holistic approach is needed. It would enable management to extract customer, operational and transaction data from multiple sources This would give them greater control over their business in terms of capital and resource allocation as well as risk management and compliance with the new regulations. The data could also be used for predictive purposes and help ensure that the right product was placed in front of the right customer in a timely manner.

What are some of the main issues in the post‑trade world and what solutions are on the market?

Until now, most of the technology spend has been in the front office rather than in the back and middle offices. However, I think they will be a major focus of fintech investment because they have the same requirements as the front office, such as real time collateral management, as well as data governance. We could, for example, see an increase in the use of cloud for aggregation and consolidation of information.

Another development we see is blockchain technology that underpins the cryptocurrency Bitcoin. It could, for example, be used in the settlement process for derivatives. At the moment, post-trade providers still have legacy systems running in the background, but there are many firms trying to identify how blockchain technology could effectively be used.

Things are changing but do you see banks moving IT higher on the agenda?

One thing that companies can look at is if there is enough representation of IT at the board level. Other than the chief or senior technology officer having a technological background, others have to demonstrate that he or she understands the risks to the business and how technology can help address the issues. For example, from a personal viewpoint, I do not classify myself as a technologist but someone who can see both sides when trying to grapple with the issues of an incumbent versus new technology discussion.

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Biography: Keith Saxton is chairman of the Financial Services and Payments Programme for techUK, the UK trade association for the technology industry. As an independent advisor Keith is engaged with a several organisations, from new entrants to large established players, helping with business strategy, technology imperatives, FinTech initiatives, and risk management. Saxton was also an expert panel member for the recent UK Government Office for Science FinTech Futures review, and is a member of the advisory council at Innovate Finance. Until recently Saxton was leading IBM Research’s Financial Services strategy. At IBM he held various industry-focused leadership positions for a number of business units at a country, regional and global level. Prior to joining IBM, Saxton worked in the industry for over 20 years and held a number of executive positions including managing director of fixed income capital markets at Scotia Capital Markets, board director and head of fixed income at IBJ International and head of fixed income trading at a Deutsche Bank.

©BestExecution 2015

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