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Technology : Outsourcing the front office : Heather McKenzie

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THE OUTSOURCING CONUNDRUM.

It is not an easy one to solve for those in the front office, according to Heather McKenzie.

Outsourcing has been a slow burn in the financial services industry. For around twenty years the benefits of handing over ‘non core’ activities to a third party have been strongly extolled by outsourcing service providers which typically include global custodians. Gradually financial institutions have moved from dipping a toe into the water, with functions such as personnel management being handed over, to much more extensive outsourcing arrangements including middle and back office operations.

The benefits are most often identified as the ability to move from fixed to variable costs as a service provider with scale and expertise that can deliver the same functionality at much lower costs. Those who outsource are told they will be paying only for what they use, rather than having to maintain systems and staff for both the peaks and the troughs of their business activities.

So established is the outsourcing trend in the asset management community, that in December 2012, the then UK Financial Services Authority raised concerns about the risks. The financial regulator was uneasy that in an industry where outsourcing of operational activities to external service providers was increasing, not enough attention was being paid to recovery and resolution plans should an outsourcing service provider fail. The regulator was also concerned that oversight of outsourcing providers was inadequate.

The outsourcing undertaken by the buyside has to date been squarely in the middle and back offices; outsourcing actual trade execution has not yet taken off. Those in favour of it argue that asset managers should focus on their core activity of stock picking and then hand over the execution of trade to the experts.

Be26_OHollen_ChristianiaSeIn November 2012, Norwegian broker Christiania Securities outsourced its trade execution activities to independent agency brokerage Neonet. For some commentators, the move was the beginning of a new trend but few other sellside, or buyside firms have followed its lead.

Based in Oslo, Christiania Securities, which focuses on technical stock analysis in Nordic markets, decided to outsource in order to focus on its core business, according to chief executive Oddbjørn Hollen at the time the deal was announced. Under the terms, Christiania uses Neonet’s execution services on a pay as you go basis. The firm taps into Neonet’s connections to markets and also employs its algorithms. Christiania does not have to pay for exchange memberships or maintain in-house resources dedicated to execution technology.

Putting the case forward

Firms that offer outsourced trading facilities argue that they have the infrastructure as well as the expertise required in order to focus solely on trade execution which frees investment managers to identify new opportunities and manage current investments. Such organisations operate global networks of buyside and sellside relationships and can execute large value trades while maintaining the confidentiality and anonymity of their clients.

Be26_BWood_GreySparkBradley Wood, a partner at London-based capital markets consultancy GreySpark Partners, says a “few” buyside firms are contemplating outsourcing execution but he does not think it is a trend or will happen “in a wholesale way”.

Wood says the main question firms must ask when considering such an arrangement is whether the function they propose to hand over is critical or not. “Is execution critical? The answer will depend on the nature of the trade activities being undertaken by a firm,” he says. An asset management firm trading only once a day, with a long investment horizon may decide outsourcing is appropriate. However, firms that are more active and trade in and out of positions regularly are likely to find that keeping the trading function in-house is more worthwhile.

Be26_PRowady_TabbPaul Rowady, principal, director of data analytics research at TABB Group characterises discussions about outsourcing execution as “more talk than walk”. While the outsourcing of technology to managed services providers has been ongoing among buyside firms for some time, outsourcing the actual “human capital” including financial traders and portfolio managers is not happening.

He agrees with Wood that if a firm does not have highly sensitive execution needs, it may well consider outsourcing execution. However, firms whose strategy is in pursuing alpha via rapid execution and are sensitive to short-term slippage, outsourcing execution is not yet a viable approach.

Rowady is sceptical about whether firms will save headcount costs by outsourcing execution. “Possibly some firms that have a large number of traders may look to outsource execution. It is a theme that is being tested at present, so I wouldn’t debunk it totally just yet.”

Outsourcing has not been a smooth ride for all firms. There are challenges that have to be overcome and that may prove significant for areas such as execution. Wood points out that there are numerous examples of firms that have outsourced call centre operations to low-cost locations only to bring them back into their home countries after ‘disastrous’ effects on their businesses.

“In outsourcing any area of business, a firm needs to be able to closely manage the relationship it has with the party to whom it is outsourcing,” says Wood. “This is non-trivial; if you outsource execution how will you know whether the service provider is executing properly? What will the implications be on costs and slippage? How will you know that outsourcing is worth it?”

Best execution

Given regulatory requirements for best execution, firms that outsource execution will have to deploy reliable, trustworthy transaction cost analysis processes in order to measure their third party provider’s performance. “This is not something that is done on any sort of scale today,” says Wood. “It would be quite difficult to ensure that there is value in the relationship and to manage that relationship.”

In addition, questions of security should be high on the checklist, says Rowady. “Confidentiality is very important. Firms must determine whether or not their provider will leak their orders. They also need to know what will happen if an order is wrongly executed.”

Trading where liquidity is plentiful, highly fragmented, with low-touch trading via smart order routers is sufficiently commoditised, says Wood, and may be a suitable candidate for outsourcing. However, trading in areas such as fixed income are unlikely ever to be suitable for outsourcing as there is so little liquidity, so a trader has to work very hard to execute trades. “Buyside firms should not let a third party conduct its trade execution if there is a large chance of slippage shortfall if the trade is executed poorly.”

Rowady says execution remains one of the more sensitive functions within any trading firm and therefore he is unsure how widespread the outsourcing of execution will become. “It is important in the current environment for firms to seek cost savings, but I cannot imagine execution outsourcing will become widespread.”

In fact, he believes trading strategies will become more complex and sophisticated across all asset classes and regions, making alpha much more difficult to find. In such an environment buyside firms will need new skills and better trading tools. There may be niche execution outsourcing offerings for basic trading strategies but not for the highly automated, high turnover strategies.

The confidentiality required by Rowady may be reflected in how many firms admit to having outsourced execution. He believes it is unlikely many buyside firms, tasked with managing investments for their clients, will admit they have outsourced what may be considered a core function.

© BestExecution 2014

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Viewpoint : Mark Hemsley : Best execution & market data

Mark Hemsley
Mark Hemsley

EXCHANGES CANNOT HOLD BACK THE TIDE.

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Two key measures contained in MiFID II will provide respite to European brokers: greater clarity around what constitutes ‘best execution’ and an attempt to restrict what incumbent European exchanges charge for market data. Mark Hemsley, CEO of BATS Chi-X Europe explains.

At present, brokers operating in the brave new world outlined in the first implementation of MiFID in 2007 are facing something of a limbo. For while MiFID I outlined a vision for markets, it failed to truly define the specifics of its banner initiatives.

‘Best execution’ is a case in point. In the US, ‘best execution’ is a defined metric that takes into account price, time and likelihood of execution. The same cannot be said in Europe, where any combination of: ‘price, cost, likelihood of execution or settlement, size, nature or any other consideration relevant to the execution of an order’ can constitute ‘best execution’.

While this elasticity can benefit investors pursuing specific trading strategies, a recent paper published by the FCA (Thematic review: Best execution and payment for order flow, July 2014) established that the ephemeral notion of ‘best execution’ creates considerable variance of service between broking firms.

It is helpful that MiFID II will seek to remedy this issue by creating a more prescriptive data regime to which brokers can respond to, and organise around.

But it remains the case that even with a more rigid, data-driven ‘best execution’ framework, exchange groups could do more to equip brokers with the fullest possible view of the pan-European marketplace at the most competitive price.

At present incumbent exchanges i) charge too much for European market data, and ii) further complicate the issue with a vast array of contractual terms and requirements. Given data should underpin any proper analysis of best execution, limiting data costs is of vital importance.

It is encouraging then that the European Commission, in its mandate to ESMA, agreed that data costs in Europe are too high. A combination of three steps, already outlined in the MiFID II consultation paper, will help to remedy the issue.

Greater transparency around costs is vital. Considerable opacity exists around existing market data agreements to the extent that exchanges do not use standardised definitions for common use. This impacts the ability of brokers to make like-for-like comparisons, and determine which solutions work best for them and their customers. A rational following step would be to mandate data unbundling – for example by offering auction and intraday trading data separately.

The proportion of income exchanges derive from data sales should also be measured and reported to customers, to address the issue of incumbent exchanges squeezing data sales to bolster net revenues as their share of trading declines. Very few brokers are happy to prop up exchange revenues, and many more would like to see venues address their internal management and long-term strategy to reflect the new competitive landscape in Europe.

However, transparency around either products or revenues will not be sufficient in limiting data costs. To that end, implementing a Long Run Incremental Cost (LRIC) model, similar to that used by telecommunications and energy industries, charging for ‘raw’ trading data, is essential. In effect, this will mean that data suppliers recover no more than it should cost to provide this basic service – plus a reasonable operating margin (hence ‘LRIC+’). In turn, this should prompt greater competition among data providers for ‘value-add’ products that deliver tangible benefits and insights to customers.

But exchanges also need to simplify the market for trade data. It should not be a stretch, for example, for exchanges to provide per-user pricing, or agree to a single definition of what (and what’s not) ‘non-display’ data. Clear reporting models should also be a minimum requirement. Yet incumbent national exchanges are furiously fighting any such intervention – either on the issue of cost or clarity.

Amongst other things, this ill-advised policy hinders the commercial realisation of a pan-European consolidated tape: bundling data costs and attempting to rationalise contractual terms from each exchange is far too costly and complex.

Yet such a tape would provide a very valuable tool for brokers, and ultimately, their end-customers. All trading participants would have the same view of consolidated liquidity, and the same access to post-trade data. Irrespective of how ‘best execution’ comes to be defined, creating a single, minimum data source significantly reduces the chances of miscalculation and misinterpretation.

There are also tangible benefits to making trade data cheaper and simpler: as the FCA notes, ‘every basis point of cost saving could translate in £264m in additional client returns each year. Over a thirty year period, a 1 basis point improvement in trading costs could represent an additional £37.5bn in client returns.’

That incumbent exchanges in effect conspire to prevent their customers fulfil best execution requirements is indefensible. Then again, given their history with MiFID I, perhaps it’s not surprising that they are still to learn you cannot turn the tide.

© BestExecution 2014

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Viewpoint : Outsourcing : Jerry Lees & Richard Lilley

CHANGING PERCEPTIONS.

In recent years the popularity of outsourcing in financial services has swung like a pendulum, and while to some it is still a ‘dirty word’ others see fresh opportunities. Best Execution spoke to Linear Investment’s chairman, Jerry Lees, and managing director Richard Lilley, about the rationale for outsourcing trading operations for buyside firms.

There is much discussion in the market with groups such as Alternative Investment Management Association (AIMA) around the subject of outsourcing trading and operational services due to increasing demands from regulators for proof of best execution, operational risk management and cost management. Is this leading to European funds embracing outsourcing and how will it be different from the past arrangements?

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Jerry Lees: This is exactly what is happening. There are a series of regulatory requirements including proving best execution that smaller and medium sized fund managers are obliged to provide and it makes more sense to outsource these requirements to specialist entities that can offer a bundled package of services and economies of scale. The change that it is happening is in the front office, although the trend is more established and more prevalent in the US. I think it will take time for European buyside firms to follow suit because of the multiple regimes, markets and currencies.

What type or size of organisation can benefit from outsourcing their dealing desk and/or middle and back office operations?

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Richard Lilley: It is across the board and the drivers are different. However, all funds are under greater pressure due to regulation in terms of trade reporting, risk analytics, risk management and proving best execution. Outsourcing of, particularly the front office, will also depend on the frequency of trading. For example, large long-only firms who trade infrequently do not have the flow to justify having an in-house trading team so may well decide to outsource the function. The same is true with small to mid-size hedge funds which only have one or two people on the trading desk and are looking to reduce the costs and improve the bottom line. As for small or start-up hedge funds it makes more sense to outsource the dealing capability from the beginning versus taking on a dealer in-house. Hedge funds that are not running high volume trading strategies will also be better off to outsource.

Many global prime brokers have recently announced staff and operational cuts and intended increases in fees while at the same time asking smaller funds to find an alternative broker in order to address internal capital and profitability targets. What impact is this having on the industry?

Jerry Lees: Regulation such as Basel III has had a massive impact and there are balance sheet implications for all banks. Most hedge funds have tiny balance sheets and a lot of assets under management but it has become expensive for banks to rent out their balance sheets. They are no longer willing to do this for nothing but are now looking for a higher return. The benefit of a service like ours is that we can act for several relatively small and medium sized hedge funds and bundle them up as one account. We will do everything for them, ranging from know your customer (KYC) documentation to on-boarding, risk and compliance management and reporting, and they benefit from the economies of scale. The larger prime brokers cannot afford to look after this segment of the market. We can because we do not have the same type of overhead.

Do you believe that by outsourcing trading, funds will ultimately enhance their performance and profitability?

Richard Lilley: Yes absolutely. Since soft commissions are no longer acceptable, research, previously obtained from sellside brokers, is just one of the many products that the buyside now pay hard dollars for. We offer full commission sharing agreement capabilities and are able to direct the flow to the broker research of their choice. Setting up an in-house dealing desk is also expensive. For example a firm with two to three traders will, in addition to the personnel costs, have to license three Bloomberg terminals, or similar, in order to trade effectively. Add in IT support, rental of extra office space and before you know it the total costs are anything up to £1m. By outsourcing trading this figure is directly removed from the bottom line, without impacting the service. Funds are unable to cover these costs, so they are paid from their standard management fees. By outsourcing, the problem goes away and the bottom line immediately looks better. Fund managers are also able to focus more on their core business of investing and can have higher execution quality if, for example, they use a specialist team of traders. We are an agency-only business with no proprietary positions. We have access to liquidity in a disguised way and can allow the fund to trade anonymously.

How are the deals being structured – are they on a component basis or lift out?

Jerry Lees: We do not see any broad discernible trends. We have general discussions with funds and they may buy components or decide to outsource everything from back and middle to front office. One of our main messages is that best execution is achieved by specialist traders.

What are some of the biggest challenges?

Jerry Lees: Changing the cultural mind-set and the decision making process of the CFO and CIO are the biggest challenges. There is a perception that outsourcing is like asking turkeys to vote for Christmas in terms of losing jobs and internal controls. That is not the case.

Richard Lilley: There are numerous buyside dealers who do not trade electronically, but use a broker. They can be paying unnecessary and inflated dealing commissions. One of the benefits of outsourcing the execution is that we are able to capitalise on our higher volumes and offer a more attractive rate. The brokers will not lower their rates to individual funds because there is no incentive to do so. I think over the next two to three years, there will be a major transition, mainly due to the regulatory changes. This will create more interest and an increase in the number of firms who will outsource their execution desks. It will not happen overnight, but once funds recognise the benefits to their current dealing process and see the increase in their bottom line, I expect the demand for outsourcing trading to increase dramatically.

© BestExecution 2014

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Appeal : Children in crisis

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(Ex)changing places.

Alasdair Haynes is well known in financial circles as the founder and CEO of Aquis Exchange, and former CEO of Chi-X Europe, as well as spending 11 years heading up to ITG’s international business. However, Alasdair is also the Chairman of Trustees for Children in Crisis, a charity providing children in some of the world’s poorest countries with the education needed to transform their lives. They support children to read, write, think, pursue their life goals and contribute positively to their communities. Through an initiative with the Department for International Development (DfID), Alasdair asks for your support today, so that they can get funding matched pound for pound, by the UK government. Read on and find out how.

Tell us about the work of Children in Crisis

All too often we take our education for granted – as a father, I can testify to the Monday morning blues of getting my sons ready for school. But Children in Crisis recognises that education is the inoculation against poverty; that escaping poverty is more than just about money. It is about having hopes and plans for a future. It is about having dignity and a voice to shape events around you. For countries smashed by war, a quality education is a powerful defence against resurgent conflict.

Where does Children in Crisis work?

Children in conflict-affected countries are often forgotten when the cameras turn away. The challenges seem too huge and the resources too limited. Children in Crisis does not turn away from these isolated and vulnerable communities. We reach out to the tough, remote, unstable places where few agencies venture. We currently have programmes running in Afghanistan, Burundi, Democratic Republic of Congo, Liberia and Sierra Leone.

You visited Sierra Leone and Liberia last year, tell us about this

Since becoming Chairman of Children in Crisis I have been on a couple of field trips* to River Cess County in Liberia and to Kambia district in Sierra Leone to see for myself the work the charity is doing. I was given a warm welcome wherever I went, and very soon realised the great value and respect placed on Children in Crisis and our partners in these areas. I now speak with pride for this charity and all that it does.

Be26_SisFelicia_TeaShop_CISI remember meeting Isata, a disabled girl, in Sierra Leone, who had to climb through the window to get into the classroom because she could not get her wheelchair up the steps. She was so embarrassed by this that she got to school hours before the other children and stayed until they had all gone home. She now has ramps in her school and we are supporting her teachers to take her needs into consideration.

I have seen the resourcefulness of mothers – many of whom never went to school because of the war – who want their children to be educated, so that they can have a better life. Children in Crisis runs vocational training programmes for these illiterate mothers so that they can learn skills like pastry making, tailoring or soap making; they set up small businesses, where they can generate an income and give their children more chances and opportunities in life. In Liberia, one lady, Sister Felecia (left), has set up a tea shop, where she bakes and sells bread and cakes to support her family.

Can you update us on what has happened since your last visit

Recent news reports have talked about the state of emergency that has been placed on West Africa with the outbreak and spread of Ebola. My heart goes out to all those I have met in these countries, and hope that they, and their families, stay healthy. Sierra Leone and Liberia have been ravaged by war and a decade on are still trying to recover from its impact. This virus is another blow to these nations. Communities who were starting to support themselves are now in a situation where schools and markets are closed, trade has come to a standstill and food prices have rocketed. I am determined that we do not neglect these communities.

*Alasdair covered the costs of his trips

 

Be26FergieAHaynesAlexandraPlease join me to secure the funds to bring these communities a chance to learn and a chance in life. It is vital that you act now, as your donation will be matched by the UK government, pound for pound. For every child that you send to school, their sibling can go too. All children deserve the gift of education.

Help Children in Crisis unlock match funding through the UK government and give via
www.childrenincrisis.org/ukaid. Children in Crisis, 206-208 Stewart’s Road, London SW8 4UB. UK Registered Charity No: 1020488

If you share Alasdair’s passion to give the poorest children a chance to learn and a chance in life, you can adopt Children in Crisis as your Charity of the Year. For more information go to:

www.childrenincrisis.org/get-involved

Alasdair Haynes at a London
fundraiser, with Sarah, Duchess
of York, founder of Children
in Crisis (left) and Alexandra
Buxton, Trustee of Children in
Crisis (right).
Photo: Charlotte Barnes

© BestExecution 2014

Derivatives trading focus : Dan Barnes

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INTO THE ETHER.

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Dan Barnes assesses why volumes on SEFs have not materialised.

Artificially low interest rates and high capital requirements are depressing fixed income trading activity, while the reform of trade processing is driving up trading costs for over-the-counter (OTC) derivatives.

“Draghi and the European Central Bank have done everything in their power to kill volatility in the front end of the [yield] curve,” says the head of European Futures and Options Sales at a Tier 1 dealer, speaking on condition of anonymity. “The market is dead but it is very hard to know how much is a reaction to the Dodd-Frank Act and its implications, versus a very challenging market environment in European fixed income.”

Exchange-traded derivatives are simultaneously suffering from low levels of activity, as a result of limited volume and volatility in underlying markets such as equities. In combination it is crushing sellside firms’ derivatives businesses and a shake-out may be in the wind, with only bigger, full-service firms able to support derivatives trading operations.

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“There are completely new market conditions which have become the new normal, with low volumes and low volatility,” says Sylvain Thieullent (above), CEO for electronic trading at trading technology supplier Horizon Software. “Volumes are maybe a fifth of what they were in the listed derivatives market in 2007. With low volume people are looking for some liquidity at an interesting price. Previously OTC products were widely used. Now people are moving towards listed and there is a lot of sophistication in terms of the algos they use to access the market.”

However any migration to listed products is occurring at a far slower pace than many market participants had expected, or perhaps just hoped. The acquisition of a controlling share in agency broker Newedge, by investment bank Société Générale in May 2014, and the sale of RBS’s equity derivatives business units to custodian and broker BNP Paribas in February 2014 suggest that some banks are already choosing between exiting or expanding in the derivatives business.

“We are seeing a bifurcation of the market, across asset classes, into big flow monsters and specialist niche folk,” says Steve Grob, director of group strategy at trading platform provider, Fidessa. “The flow firms are all about reach and coverage and efficiency; the smaller firms have to demonstrate real expertise, either in a given market or around a particular product. We have built the capability [in our platform] for those smaller firms to trade via the larger firms’ infrastructure, so they can offer members a global service. We have had to work hard in developing an application programming interface that can be used for that purpose without any degradation of service.”

For the ‘flow monsters’ competition is fierce and investment significant. The regulatory requirement to clear OTC derivatives trades, already in force in the US and coming into play in Europe, has considerable associated costs for buyside firms through the requirement to find collateral that a clearing house can hold as protection against a contract’s price movements and counterparty bankruptcy. For a full-service broker, providing clearing connectivity also requires it to provide sourcing, optimising and posting of collateral.

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Supurna VedBrat (above), co-head of the electronic trading & market structure at asset manager BlackRock says that clearing is generally a volume business which makes scale crucial to broker offerings.

“Whether you are a tier 1 or tier 2 clearing broker, as long as you have an optimal model to clear for clients you should be able to attract the volume,” she says. “That is what people need to focus on. Designing a business model that is robustly risk managed and designed for volume/scale across products and optimising operational components to reduce inefficiency.”

Kickstarting the market

There had been an expectation that exchanges would be able to migrate trading from the bilateral swaps market onto the listed futures markets by creating ‘swap futures’ that provide the same cash flows as swaps, albeit with less flexibility. However they are yet to prove attractive.

“The swap futures launched in anticipation of and as a reaction to Dodd-Frank, have seen very little in the way of real end user demand,” says a head of European Futures and Options Sales. “That is a bit curious. All of these catalysts exist that make a future traded on-exchange that mimics the performance of a swap very appealing. I think it is a function of market timing. The truth is no-one knows what the futures market structure will look like and how it will evolve, so everyone is betting on different horses right now. I think in the absence of a clear winner, people do what they always did, and that might be part of the inertia.”

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In addition, the advent of swap execution facilities (SEFs) in the US was expected to increase trading volumes as the illiquidity of fragmented bilateral trading was replaced by centralised trading venues. Again they were confounded.

Hirander Misra, CEO at derivatives exchange operator GMEX, says “Many people thought with the advent of SEFs in the US we’d see the floodgates open and a lot of the volume that is traded bilaterally would come on to the electronic trading venues, but when they went live – with the first wave in July last year – there wasn’t this deluge. There was an initial spike in volumes and swaps, futures also benefited, then volumes very much tailed off. One year on the volumes are still small in relative terms.”

Time to kill

The reasons behind the slow pace of change are complex. Asset managers can vocally support new products and venues but have no obligation to use either, until significant cost and liquidity imbalances develop. Brokers report that asset managers are in many cases simply trying to carry on with their day-to-day business to support end investors. Once they are settled with the market structure, product migration may occur.

Kunal Patel, principal consultant at capital markets advisory firm Capco, says, “The demand for sophisticated hedging instruments across the buyside hasn’t changed. You could almost argue that over time the level of sophistication required to hedge has become greater. That will then mean that the buyside will need to have an array of strategic choices available in order to hedge, they will need options around how to structure the hedge.”

However the failure of SEFs to significantly change the bilateral model of trading is seen as a stumbling block by several sellside dealers. For buyside firms, the current use of a request for quote (RFQ) model on SEFs simply replicates the process of calling around dealers without using a telephone. Using a central limit order book (CLOB) to find liquidity and match orders might revolutionise the business.

“Once that happens the most liquid products, whether on a SEF or exchange, that were previously bilateral will suddenly explode in terms of volume on the CLOB,” says one dealer.

Waiting for these changes will be painful for brokers particularly. Their real challenge is the cost of supporting client trading. The Volcker rule in the US, part of the Dodd-Frank Act, prohibits proprietary trading and excessive investment in firms that engage in ‘high risk’ activity, such as hedge funds. Equally the capital adequacy requirements of the Basel III regulation, which is intended to ensure that risk is balanced by capital reserves, applies punishing costs to sellside businesses.

“We’re in a Catch-22,” claims one US-based head of derivatives at a large investment bank. “If we were a purely agency business we would have an acceptable business model, but no-one would trade with us because without capital reserves we wouldn’t be seen as stable enough.”

 

© BestExecution 2014

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Derivatives trading focus : OMS : Jon Batty

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F&O TRADING: DO WE NEED AN OMS?

 

Jon Batty, Managing Consultant, Technology Consulting at GreySpark Partners examines the argument.

The futures and options trading platform has historically been driven primarily by the need for market gateways and white-labelled, sellside-provided screens to capture their client flow in a DMA (Direct Market Access) style of trading. With margins and commissions being squeezed there is very little ‘stickiness’ from buyside clients who look to switch brokers on a regular basis to save cost.

Whilst there is a high level of electronification within the global futures and options (F&O) space, the market has moved towards a ‘utility model’ where the focus is on industrialisation of the trading process, cost optimisation and efficiency.

Buyside firms, and even the traders within those firms, can have a strong attachment to a specific trading platform (screen) or SDP (Single Dealer Platform), demanding that the brokers provide these systems in order to capture their business. This leads to sellside brokerage firms having very little structure in terms of the trading technology architecture as they tend to offer access via many trading screens and not one single interface in order to compete.

This has triggered the view that an Order Management System is not needed. It’s been a long journey, and generally F&O OMS platforms lack maturity, having been predominantly spawned from a cash equities platform base.

The cash equities OMS space is now very crowded with the platforms highly commoditised and with many vendors offering solutions of comparable capability.

Vendors are now looking at opportunities to diversify and extend these platforms as multi-asset-class solutions. Starting with listed F&O, and then moving on to Fixed Income, FX and Swaps.

Whilst there is a lot of overlap in features and functionality between a cash equities OMS and a listed F&O OMS there will be elements of these platforms that will be less advanced for F&O and will require refinement over time. As product features mature, and competitors emulate the leading vendors, commoditisation of the feature set occurs as product offerings become less differentiated. Clearly, it is the area of least commoditisation that vendors have the opportunity to differentiate their offerings.

The diagram opposite illustrates the features of an F&O OMS and shows GreySpark’s view of the areas of commoditisation by feature set.

The different types of F&O trading systems

F&O trading systems can be broadly categorised as an OEMS, an EMS, or a pure dealing screen. Unlike in the cash equity market, F&O trading businesses are not looking for value-added services like research, sales trading, trading tools, but are focussing purely on cost (per screen). Market access and low touch EMS solutions are what the market will be looking for, at the right cost. Global order management and complex workflow solutions are only important to a niche set of players.

The market is still dominated by dealing screens. These are pure trading terminals, providing straightforward direct market access with relatively simple functionality. With 90% of listed F&O being traded electronically with execution and clearing done on exchanges and CCPs, these dealing screens provide many clients with all the functionality they need.

With e-commerce offerings now expanding from their traditional roots of research delivery and FX trading, more banks are providing the capability to trade listed futures and options via their SDP. However, the most common trend in dealing screens is dedicated vendor market access platforms that allow white-labelled trading screens to be deployed to clients at relatively low cost and with minimal technology impact. There is a significant use of sponsored access (i.e. no-touch direct market access) for the more performance-sensitive trading houses.

EMS platforms are an extension of these dealing screens, giving traders enhanced execution features such as smart order routing and access to trading algorithms. High-touch trading on F&O dealing platforms is now fully commoditised and thus, vendors will compete on the following value-added features and services:

• Availability and customisability of strategies and algos;

• The breadth of the market connectivity.

The provision of an order book is not yet a clear differentiator among clients seeking purely dealing functionality.

F&O OMS usage is only really needed by small set of global banks who have the need to manage global books with complex structures and hierarchies, multiple asset classes and integrated risk margin management features.

What to look for when choosing an F&O OMS

Be26_GreySpark_TableTo build an efficient trading desk it is crucial to have both an OMS and an EMS. Both systems should feed each other with information: an OMS manages the client orders and feeds the EMS with execution instructions; and an EMS manages the trading and execution of those orders on the available venues. Once orders are executed, the OMS captures the post-trade status, handles the position-keeping, P&L and any interactions with the back office.

For cash equities this space is well managed and well defined, with many well-integrated solutions covering both OMS & EMS. As mentioned earlier, this is less defined for F&O and solutions have typically focussed purely on the EMS.

Pre- and post-trade reporting are becoming more and more important to trading houses; it is no longer a question of whether a broker has pre- and post-trade reporting, but the quality and level of detail provided. An effective OMS choice should either provide analytical capability or have an effective API (Application Programming Interface) to allow seamless integration with third party solutions.

Licensing of the OMS is always going to be a concern for F&O brokerages. As explained above, the market is still dominated by the distribution of dealing terminals. For an OMS vendor to compete in this space they will need to have a competitive licensing solution that allows the brokers to license external users on a flexible basis without being locked in to long-term, costly contracts.

Above all else, an OMS needs to provide benefits. The ability to manage the end-to-end trading workflow is a critical part of the value chain, and should include tight integration with the clearinghouses, margin management and strong risk management capabilities.

The demands from regulators will continue to grow across all jurisdictions. An F&O OMS solution should provide support for all regulatory change relating to the markets it supports. This can be costly and time consuming and so any selection of an OMS should ensure the vendor has this catered for.

In summary

It is GreySpark’s view that an OMS is slowly becoming a requirement in the F&O trading space and not just a nice-to-have. Unlike its peer in the cash equity markets it has not yet established itself as a mandatory platform in order to compete, but with focus from software vendors and the maturity of solutions that perception will change over time.

Whilst still predominantly a solution aimed at tier 1 and/or global brokers, the expansion and commoditisation of features that support the increasing needs of regulators and buyside clients will only serve to make an OMS solution an attractive requirement for all types of F&O trading desks.

In June 2014 GreySpark Partners published a report about vendor solutions for F&O trading called Buyer’s Guide: Futures & Options OMS and EMS 2014. Further details about the report are available at:
https://grys.pk/fno14 

© BestExecution 2014

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Derivatives trading focus : The cost of compliance : JWG Group

PJ DiGiammarino
PJ DiGiammarino

FIVE REASONS TO EXPECT BAD NEWS.

JWG Group explains why market participants should brace themselves.

The challenges of gaining clearer oversight of the financial system are not going unnoticed. We come back from summer holidays with five leading indicators that suggest we are on the brink of bad news. Bad news that is likely to spread far and wide.

Firstly, in a new report, the US Government Accountability Office (GAO) faulted the Financial Stability Oversight Council (FSOC) for failing to enact certain reforms that were recommended in a similar oversight report issued two years ago. “FSOC still lacks a comprehensive, systematic approach to identify emerging threats to financial stability,” wrote GAO staffer, Nicole Clowers.

The second big piece of news is that LEI (legal entity identifiers) registrations have tailed off to levels far below expectations this summer. Even though the new risk reporting regime is requiring ever more registrations, thanks to the bold move of the European Banking Authority (EBA) to mandate the LEI, the numbers of registered legal entities just aren’t there, and there are the statistics to support this.

The third newsflash comes from an HM Government report published this summer looking at the ‘Balance of Competences’ between the UK and the EU. In it, they cited JWG’s 2012 research conclusion: “EU financial services industry will spend 33.3bn on complying with regulation between 2012 and 2015”.

We note that the figure they cited was based on an optimistic set of assumptions about the clarity and timeliness of reporting rules. The actual number is likely to be far bigger, especially if reporting problems continue to persist. Regardless, they are clearly concerned by the cost of European regulation to UK financial services.

The fourth big story comes from research published by Rachel Wolcott, a UK based financial regulation correspondent. Wolcott argues that the US and European regulators have failed to enact suitably robust trade reporting standards and as a result global regulators are now seeking to regroup and address the data quality and collection problems related to OTC trade reporting.

Wolcott notes that a lack of clear standards for reporting data, together with insufficient IT spending by regulators, has been blamed for what is in fact a failure of OTC trade reporting. Ultimately arguing that If regulators do not develop more descriptive standards for regulatory reporting, particularly for OTC derivatives trade reporting, financial institutions may have to do it themselves.

PJ DiGiammarino

As part of the same report, JWG’s CEO, PJ Di Giammarino (above), has been offering his insight into these reporting issues. “Unless there’s a better rule-making culture that promotes collaboration between technical specialists in the investment firms, the problems will only get worse. We need more informed political decision-making and a practical industry dialogue on how we get to reporting standards that make sense. We can’t keep doing it piecemeal. To have a fragmented approach across OTC derivatives trade reporting, equities trading, risk and stress testing makes it difficult to make decisions about a fast-moving and complex system.”

The final news item? As reported at a conference in London during September, Germany is starting to get tough on reporting infractions. Rumours abound about the pharmaceutical CEOs that are facing fines of 500,000.

The bottom line is that the reporting problem is only just starting to make itself known. If you are one of the parties that can be held accountable for it, watch out!

© BestExecution 2014

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Derivatives trading focus : CLOB vs RFQ : George Harrington

Be26_GHarrington_BloombergONE SIZE DOESN’T FIT ALL.

George Harrington, Global Head of Fixed Income, Currency and Commodity Trading, Bloomberg L.P., gives Best Execution his view on the CLOB vs RFQ debate.

 

Regulatory catalysts in the US, aimed at migrating OTC swaps to an exchange-like central limit order book (CLOB), have largely failed so far this year. One theory is that clients get better liquidity from the RFQ (request for quote) model and the buyside like the fact that there is no commitment to make prices. What are the other reasons?

While there continues to be some trepidation among buyside players about putting a firm price into an order book, we have recently seen that start to change. An increasing number of our clients both on the buy and sellside, are starting to explore order book trading on more liquid instruments. Based on the level of interest, we would expect this trend to continue.

What will the catalyst be for increased use of CLOBs? Will it be a natural evolution from voice to RFQ and then CLOB?

The catalyst really is the seeding of the books. RFQ execution is popular and will remain popular for some time, but growth in CLOB execution will require momentum of participation and we’re certainly starting to see early signs of this.

There is a view that in the future the two formats can be used in tandem with standardised trades executing in CLOBs and less liquid products remaining in the RFQ format. Do you think this will be the case?

I think you will see RFQ and CLOB co-exist for the foreseeable future. In markets where spreads are wide, the RFQ model is likely to be preferred. In markets with tighter spreads, the CLOB may provide price improvement.

What are the advantages of using a CLOB?

The principal advantage is anonymity. In the traditional OTC markets, there have been clearly defined lines between the client-dealer space and the interdealer space. CLOB meanwhile allows true all-to-all execution.

What other changes do you see in the fixed income and derivatives space?

I would expect continued product innovation to be an ongoing theme to allow for alternatives to traditional swaps. We have already seen it with innovations in swap futures, and I think that will continue.

And how do you see the industry developing in Europe?

The European regulators are on track with the G20 commitments on central clearing and reporting. However, they seem to be less prescriptive in regards to execution. European markets have traditionally been progressive in terms of electronic execution and I anticipate they will closely scrutinise how SEFs evolve in the US and adopt the solutions that work. When MTF/OTF rules come into effect, it’s likely new trading protocols will be deployed across the markets given the broader regulatory scope.

©Best Execution 2014

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Derivatives trading focus : Electronic trading : Sassan Danesh & Tim Healy

Be25_FIX_Danesh-Healy_582x375
Sassan Danesh & Tim Healy, FIX

 SEFs to OTFs.

Be26_FIX_Danesh-Healy_602x395

The migration of swaps trading in the US onto SEFs has resulted in a seismic shift in OTC derivatives markets towards electronic trading. Sassan Danesh* and Tim Healy* ask what has been the impact and what lessons can OTFs learn?

The birth and rise of the SEFs (apologies to Star Wars’ fans) has been dramatic since the first mandatory swaps trades were completed in February this year. According to statistics released by the Futures Industry Association (FIA), the overall volume in June was the highest of any month since mandatory SEF trading began. During the year, there has been a steady upward volume curve with the value in June for USD Interest Rate Swaps (IRS) coming in at almost $1,250bn. On-SEF volumes now account for approximately 60% of all cleared USD swap trades; a number that might further increase as more complex package trades migrate onto SEFs in November this year.

The volumes show that traders are becoming more acclimatised to trading electronically, liquidity is strong and regulators can monitor risk given that all contracts are now recorded in data repositories. On the face of it, the transition, whilst being huge, has been relatively smooth. However, given the size of the $710trn swaps market, small changes have the potential to present large issues to market participants.

The market now seems to be entering the next phase of its dramatic development from opaque, predominantly phone-based trading to a fully transparent electronic market. FIX has been at the forefront of this substantial change. The FIX Trading Community has been working closely with the investment community since 2011 to develop guidelines on how FIX could be used to trade swaps following the requirement by Dodd-Frank a year earlier for regulated trading of certain swap instruments. This work has resulted in the establishment of FIX as the de-facto standard for swaps trading on SEFs.

Although the different global regulators’ goals are fundamentally the same, the difference in legislation between the US and Europe has brought with it some issues. Currently, the US Commodity Futures Trading Commission (CFTC) has authorised approximately 20 SEFs for trading.

As in the equities world, the emergence of different liquidity pools has led to volume fragmentation issues. Separate pools of liquidity have formed for “US Persons” and “Non-US Persons” who are looking to trade off SEFs in order to avoid having to comply with the Dodd-Frank rules. On top of this, there are two distinct trading models – request for quote (RFQ) and central limit order book (CLOB). Historically, the majority of electronic markets have been CLOB based.

However, this model reduces the overall level of human interaction, an important element of the OTC derivatives market historically.

The major investment banks in particular will need to adapt their models as the expected uptick in electronic volume grows. One major investment bank recently set up a new team dedicated to monitoring trades across asset classes and electronic platforms, to look for opportunities and assess where there are potential threats to the bank’s market share.

There will likely be some consolidation in this space. Whilst the market is huge in notional USD terms, profit margins are under pressure as spreads naturally narrow with electronification. Will there be a need for 20+ SEFs? How will the buyside start to interact with the SEFs?

In Europe, MiFID II will lead to the creation of Organised Trading Facilities (OTFs) with the same goal as that of Dodd-Frank and the creation of SEFs – to reduce systemic risk and increase transparency in the OTC derivatives market. To clarify, the main distinguishing feature between an OTF and a Regulated Market (RM) or Multilateral Trading Facility (MTF) is that the execution of orders is carried out on a discretionary basis. This is an important difference, of course, as it will require the OTF to provide conduct of business duties to its clients.

In addition to the extra registration and on-boarding costs for market participants associated with the emergence of OTFs, similar concerns are likely to arise in Europe as have been seen in the US. Should the finalised rules not allow for a certain degree of interoperability between MiFID II and Dodd-Frank then the risk of further liquidity fragmentation is substantial. There is a clear directive that OTFs will not have any interaction with each other, so market participants will need to connect to each OTF, much like they have done in the US with SEFs, to make sure they have access to a broad pool of liquidity. As experience has proved, not all venues are created equal, some will thrive while others will fall by the wayside. Having an agreed connectivity standard for the OTFs in Europe, similar to what the FIX Trading Community has produced for the SEFs in the US, will allow banks to easily integrate with the new venues in a standardised, low-cost manner.

OTFs will also be allowed the luxury of voice brokerage. Given the size of the OTC derivatives market, there is a dangerous and incorrect assumption that all contracts are liquid. The idea that transparency is good for all aspects of the market is a concern and could lead to information leakage and the potential market manipulation of less liquid contracts – all things that the regulators are trying to avoid.

Legislation has led to a seismic change in the marketplace, and as with all seismic activity, there is the ripple effect and that has yet to settle.

*Sassan Danesh is Co-Chair FIX Trading Community Global Fixed Income Subcommittee, and Managing Partner, Etrading Software. Tim Healy is Global Marketing and Communications Manager for the FIX Trading Community.
 

 

© BestExecution 2014

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Derivatives trading focus : Impact of EMIR : Irene Mermigidis

SATISFACTORY PROGRESS.

Be26_IMermigidis_RegisTR

2014 has been an important year for OTC derivatives trading with the implementation of the European Market Infrastructure Regulation’s (EMIR) trade reporting requirements. Irene Mermigidis, Managing Director of European central trade repository REGIS-TR explains how, after a shaky start, market participants are now getting their houses in order.

Way back in 2009 the G20 agreed that all standardised OTC contracts should be traded on exchange, or on electronic trading platforms, and cleared through central counterparties. Non-centrally cleared contracts would be subject to higher capital requirements and all OTC contracts would be reported to trade repositories.

The first phase for trade reporting was 12 February 2014, but as anticipated by some commentators, this first deadline did not pass without significant problems. From our perspective, understanding what went wrong and why was key to avoiding more problems when the next deadline of 11 August rolled by. I’m glad to say the lessons appear to have been learnt because the more recent deadline went much more smoothly.

A range of issues

One of the main challenges hampering the February deadline was the short time-frame market participants were given to get ready. The confirmation of trade reporting registration on 13 November, 2013 only left a 90-day window until the reporting starting date (RSD). Although a number of REGIS-TR’s larger financial customers were well prepared, having taken advantage of the test platform and documentation provided in advance, many non-financial customers were either unaware of the pending deadline or believed they were exempt.

In fact, non-financial entities were the single biggest group that struggled with timely compliance. They had asserted that EMIR should have been purely a banking regulation because so few companies used derivatives extensively, and those that did were looking to hedge interest and exchange rate risk, not trade speculatively. For many of the smaller firms in this group regulation is not a core focus as it is for a financial institution, and they do not have the extensive legal, compliance or project resources available to navigate the complex trade reporting landscape.

Meanwhile, several buyside clients assumed their bank would be undertaking the reporting on their behalf. The reality was that the sellside would provide reporting services largely on a ‘best endeavours’ basis, while the buyside was responsible for the accuracy of the data being reported, and were answerable, in respect of any breaches, to the European Securities Market Authority (ESMA) and their National Competent Authority (NCA).

There were also other organisations that waited until trade repositories (TRs) were officially registered by ESMA before even starting the provider selection process. Against this background, all TRs experienced a surge in account opening requests in the run-up to the RSD. Although it was challenging for REGIS-TR to on-board all of its customers in time, our system proved to be robust and customers did not experience the performance issues witnessed by some participants.

Another key issue was related to data quality and legal entity identifiers (LEIs). While ESMA continued to provide clarification on a number of issues – through its Q&A documents – there was no definitive protocol for reporting all fields of applicable data. A backlog in the issuance of LEIs resulted in situations where interim IDs were used instead, which did not match with the CCP. The absence of a definitive protocol for the generation of unique trade identifiers (UTIs) also caused data mismatches.

These two simple examples illustrate how the two counterparties of a trade might technically be reporting ‘correctly’, yet not in a way that is conducive to reconciliation, which, after all, is the primary validation of data quality. We continue to work with ESMA, the other TRs and relevant industry working groups to help define best practice and reach agreement on appropriate tolerances that should be applied without compromising the fundamental integrity of the data reconciliation process. It requires a collaborative effort and will take time for intra-TR reconciliation rates to substantially improve.

The next phase

Implementation of Phase 2 of EMIR reporting for collateral and valuation was more efficient because market participants were much better prepared for the 11 August deadline. One reason was that the majority of corporates were not obliged to report collateral and valuations updates, as this phase was only applicable to financial counterparties and non-financial counterparties that fell above the EMIR clearing threshold (referred to as ‘NFC+’). These were the more sophisticated and better-resourced market participants, who were also amongst the best prepared for the 12 February target date.

REGIS-TR had already laid the groundwork, with clients being able to report collateral and valuation since February. We already had the connectivity channels, access to test environments and the know-how to best leverage the support mechanisms. To further support customers we issued a comprehensive Guide to Reporting Collateral and Valuations in early June. Similarly, the updated ESMA Q&A was also available in the same month, several weeks prior to the implementation of the requirement.

Buyside long-term solutions

Some buyside firms also took greater control of the process. It had been generally assumed that the August deadline would see banks provide the necessary information via their own internal models, but there were buyside firms who chose to report collateral and valuations on their own behalf. This was predominantly because the valuations were deemed to be strategically sensitive and they wanted to protect their own proprietary information.

More generally, now that the process is starting to bed in, some buyside clients are re-evaluating the reporting models they hastily implemented to be compliant in time for 12 February, with a view now to develop a long-term strategic solution. The REGIS-TR offering, which has flexible participation and delegation models, is proving a popular option.

On the regulatory road

Under MiFID, the application of new rules is expected in 2017, with ESMA, which is mandated to produce the technical standards, publishing a discussion and consultation paper earlier this year. Both Deutsche Börse and Bolsas y Mercados Espanoles (BME) have MiFID reporting products in place and, as the requirements become clearer, REGIS-TR will look to align their product offerings.

However, beyond MiFID we also need to consider, for example, FinfraG (the Swiss Financial Market Infrastructure Act), REMIT (Regulation on Energy Market Integrity and Transparency) and Shadow Banking. Trade reporting in Europe is set to expand across transaction and instrument types, obligated entities, and regulatory jurisdictions. Whilst there is still work to be done on EMIR, the regulatory juggernaut rolls on, but REGIS-TR is well prepared.

© BestExecution 2014

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