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Best Execution for Managed Portfolios

Aleksander Weiler, Senior Portfolio Manager, Public Markets Investments, Canada Pension Plan Investment Board (CPPIB) talks to FIXGlobal about evaluating asset managers, best execution within FX and managing risk across portfolios.
Evaluating Asset Managers
We are looking for people and groups who have a sustainable edge and we use all the tools available to ascertain their suitability. That involves an understanding of the investment process and the investment team. This is supplemented by quite a detailed analysis of the track record as well as its veracity.
We spend a fair bit of time looking at risk in all its various dimensions. Typically, that devolves into examining the risk process, people and structure as well as the management of the balance sheet and the debt capital of the fund and how the equity capital is structured in terms of the investor base. Most asset managers are medium-sized enterprises, so an understanding of business structure and sustainability are required.
It is necessary to be able to evaluate expected return and expected risk and it is important for us to ensure that a manager’s definition of profit is as close as possible to ours. While you want someone with a good and sustainable expected return and reasonable and bounded amount of risk, there also needs to be a value proposition that sees a fair split in the profit between us, the capital provider and the manager, the risk taker.
For trading-oriented strategies, we use a number of analytical tools, specifically Excel and Matlab. In addition, a wide range of supporting data is used. We also use risk engines internally such as RiskMetrics and Barra.
Best Execution
We invest in a wide range of managers from those doing systematic, long-term investments to those doing systematic short-term high frequency trading as well as discretionary traders. Regarding best execution within FX, we are looking for people who are aware of both their footprint and the transaction costs that they are incurring; specifically, people with electronic execution and the capacity to execute in all time-zones.
Additional venues offer potentially greater liquidity to managers, which is important especially where managers are running multi-billion dollar portfolios. Not all currencies are equally liquid, bringing additional sources of liquidity that can be accessed in a less obvious fashion. This allows managers to not only get the trade done, but also execute in a quiet fashion that doesn’t disturb the market. We also like the fact that these venues are often technology based, allowing managers to perform finer and better transaction cost analysis, which is important because one of the great things about FX is its deep liquidity and 24-hour trading. However, not all currencies are traded equally at all times during the day. Getting a euro-dollar trade done during European business hours is relatively easy and low cost, but trading something like a minor emerging market currency outside its liquid hours can be quite expensive.
This in turn leads to heavier investment in technology. Managers need to upgrade their infrastructure to accommodate multiple feeds as they need smart routers, improved data storage capability and intercom connectivity with the various brokers or groups. All this means that the old days of picking up the phone to get an order done by your FX broker has been mostly replaced by a heavy rack of servers and top-notch IT people, though phones and people still matter for market colour and depth.
Best execution requires maintenance of a transparent chain of tracking orders from signal generation to execution. FX is not regulated in the same way as a stock exchange but you need to be aware of what is happening just because restrictions on various markets are changing every day. From that point of view, managers need an increased awareness of what is happening in the marketplace and an ability to alter their trading behavior if necessary. This in turn has emphasized the role of technology in best execution.

Flow of Information
We want to understand how mangers continue to execute strategies on our behalf because that is what we’ve retained them to do. If a manager is large then efficient execution matters because they are moving around a larger position when they are trading on our behalf, and we want to know how they are executing, what they are seeing in the market and if that has changed.
If the manager is expecting to make 3-5 basis points on a transaction for us and they used to be able to execute at 1 basis point then the net to us is 2-4, but if that creeps up to 2-3 then that starts to become a less attractive proposition.
We also have internal trading teams that we poll for their views of transaction costs as a way to benchmark what the best practice is. This helps us not only compare managers but also provide a snapshot of the market that can be helpful in understanding if we have internal requirements.
Monitoring, Assessing and Managing Risk across Portfolios
Generally, there is no one risk measure for us. We need the ability to analyse risk using multiple methodologies – not only the manager’s holdings and positions, to provide snapshots of risk at a given time, but also to see if a manger is systematic in understanding the return to the specific factors that they are trading as those are often the risk units that are being allocated. This and the style the manager uses are combined with a number of qualitative insights to ensure monitoring it is a fairly intensive process facilitated by technology.
Assessment of risk is a conversation across the investment team including analysts and portfolio managers. Our goal is to understand the risk an individual manager poses, and, at the same time, what that risk looks like globally across our portfolio.
Technological Solutions
Historically, the large FX banks have been in the best position to see the depth of the order book because they’re the ones collecting it and holding it. Transparency into the true order book is something that would be helpful to people, and the fragmentation of venues offers benefits and challenges in terms of being able to be a little quieter in your execution.
FX is one of the important asset classes for us both internally and externally and it is a market that we do believe offers trading opportunities as well as a fairly wide eco-system of styles and good managers. Today, when I look at what you are able to do with the advent of various initiatives like the FIX Protocol it gives me hope that FX can continue to be an important asset class for institutional investors.

Buy-side Trading in China:The Positive Impact of QFII

Rachel Wu, Head of Trading for Franklin Templeton Sealand Fund, talks about the impact of changes to QFII quotas, what buy-side traders want from algorithmic trading and China’s readiness for HFT.
FIXGlobal: What impact do you think changes to the current Qualified Foreign Institutional Investor (QFII) quotas will have on turnover and volatility?
Rachel Wu, Franklin Templeton Sealand Fund:
The changes will have a positive impact on the A share market as the China Securities Regulatory Commission (CSRC) has increased QFII quotas and lowered the entry barriers. However, the changes will be implemented gradually as applicants for QFII status need to apply for a license, which takes time. In the short term, I do not think we will see a significant change in turnover or volatility; however, in the long term, I think the changes will result in increased market stability.
FG: As a domestic fund, how have you had to change your trading as the QFII programme has come online and what changes do you think you will have to make in the future?
RW: Since the launch of QFII in 2003, market participants have gradually started to understand the philosophy behind investing. As a domestic fund, we are pursuing better execution with low market impact that has a similar target to QFII. Increasing numbers of domestic funds are deploying algorithmic trading systems to manage market impact and risk. Exchanges are also promoting block trading systems to execute more efficiently, and these mechanisms will replace most manual execution in the future.
FG: What do buy-side traders want from algorithmic trade offerings? Are domestic funds in China doing enough to remain competitive in terms of trading systems?
RW: As a buy-side trader, I use algorithmic trade offerings to get a target price with less manual intervention. After Hundsun, which is supporting the third-party development of algorithmic trading, domestic funds are the main users. We use algorithmic trading to satisfy the portfolio manager’s requirement for stable results; however, there are some limiting factors including efficiency, speed and the commission ceiling.
FG: Are you seeing a change in current holding periods and do you see a future for HFT in China?
RW: Increasing numbers of traders are discussing how to reduce trading costs and establish efficient ways to execute orders. When we execute orders, we face several challenges including the issues of fair trading, low liquidity and market impact. China is not ready to introduce high frequency trading (HFT). Regulators are worried that HFT will hurt the market as the market lacks value investing. In addition, potential trading costs are raising concerns.
FG: How are regulators striving to improve access to and quality of information for investors and how will funds benefit from this increased transparency?
RW: China aims to improve market information transparency by establishing a sound and comprehensive system for information disclosure, improving the enforcement of information supervision and establishing a longterm mechanism to protect the interests of investors. Funds benefit from regulators tightening supervisions of listed companies to reduce market price volatility.

The BSE: An Evolving Entity

V Balasubramaniam from the BSE talks about the changes the exchange has undergone in recent years including new technology and a move towards diversification.
The BSE (formerly known as the Bombay Stock Exchange) has witnessed dramatic change in the past few years. New management, new technology, a customer-focused outlook and a clear strategic shift to diversify the businesses of the exchange beyond just equity trading,have all started to have an impact. Central Depository Services (India) Limited (CDSL), which is 54% owned by the BSE, is performing well and pushing into new areas such as dematerialization and the record-keeping of insurance policies and academic credentials. BSE Institute, the 100%-owned education and training subsidiary, is expanding beyond its traditional Mumbai-base and becoming a truly national business.
Revival of the BSE Derivatives Business
Without a doubt, the most dramatic change at the BSE since September 2011 has been the revitalization of the equity derivatives business. This revival did not happen overnight. It required a complete technology overhaul – abandoning a previously used derivatives trading system in favor of a re-vamped and upgraded integrated cash/derivatives system. It also required building back up its derivatives membership ranks with over 400 members in the derivatives segment. In addition, it was helped by the introduction of a new real-time risk management system (RTRMS) and new multi-asset collateral management software (CLASS). Finally, a low-cost cloud solution called Fastrade-on-Web (FOW) was introduced to reduce the initial cost of a new member interested in trying out BSE’s derivatives segment without a big investment in infrastructure.
In addition to all these developments, the new regulatory framework to allow liquidity enhancement incentive programs (LEIPS) for derivatives has undoubtedly had a big impact. The BSE has offered a series of LEIPS programs in index futures and index options to incentivize market-making in order to build longterm liquidity in these products.
The results have been encouraging. BSE’s volumes and open interest in equity derivatives have grown steadily since the fall of 2011. Currently there is an average volume in excess of two million contracts per day. With high participation that continues to grow, the SENSEX index option contract clocks the highest volumes daily (approximately US$6 billion).


BRICS Exchange Alliance
On 12 October 2011, executives from the stock exchanges of the BRICS countries (Brazil, Russia, India and China) convened at the World Federation of Exchanges (WFE) meeting in Johannesburg to sign a memorandum of understanding (MOU) to form the BRIC Exchange Alliance. In the following months, five founding members of the Alliance – BM&FBOVESPA from Brazil, Open Joint Stock Company MICEX-RTS from Russia, BSE Limited from India, Hong Kong Exchanges and Clearing Limited (HKEx) as the initial China representative, and JSE Limited from South Africa – finalized an agreement to expand their product offerings beyond their home markets and give investors of each exchange exposure to the dynamic, emerging and increasingly important BRICS economies.

Moscow Exchange: Shaping Russia’s Financial Markets

Ruben Aganbegyan of the newly formed MICEX-RTS (Moscow Exchange) discusses the challenges and benefits presented by the recent merger both locally and globally.
The Impact of the Exchange Merger on Trading in Russia
The merger lays the foundation for tomorrow’s success today. It is a landmark transaction for the Russian market. The primary challenge faced by the united exchange is withstanding foreign competition. Therefore the most important benefit of the merger will be the market’s increased competitiveness and stronger position in the international arena. Both RTS and MICEX bring enough to the table to complement one another. MICEX came with a strong position in cash equities, fixed income and FX trading. RTS came with derivatives and clearing. This has created a very strong basis for growth and increased investment into new products and technologies. In general, the united platform will provide better infrastructure for Russian capital markets. Moscow Exchange plans to have a strong voice in shaping Russia’s financial markets and will become a regional financial hub with the potential to create a CIS exchange platform network.
The Financial Impact of the Merger
We understand that the market expects us to reduce costs and create a comfortable environment for business. Our fee policy is determined by the Supervisory Board, which makes decisions based on the recommendations of the Customers’ Committee. Fee changes are subject to the approval of this committee in a vote of at least 75% of its members. If the Customers’ Committee has objections, the resolution in question will be reconsidered in order to find common ground. The Supervisory Board can lift the veto imposed by the Customers’ Committee, but only in order to resolve a dividend situation.
Algorithmic Trading
Algorithmic trading already accounts for a large percentage of trading on MICEX-RTS. There is a global trend toward an increased share of algorithmic trading at all exchanges. This makes it necessary for banks and brokerages to expand their infrastructures in order to process the rising volumes of trades and orders. The exchange also needs to develop both technologies and regulations concerning algorithmic and high frequency trading (HFT).
We have extensive plans for improving the trading environment for HFT and algo traders. MICEX-RTS will modernize its technology infrastructure and provide a seamless transition and uniform access to its participants. The exchange already provides access via the internationally recognized FIX Protocol and allows qualifying clients to host their HFT platforms at co-location facilities. The technology migration and upgrade plans will take place during the next year.
Currently the priorities for technological development are reducing data distribution intervals, expanding core services capacity and stabilizing FIX solutions.

Alternative Venues:Going from Strength to Strength

Bryan Harkins from Direct Edge talks about the benefits of innovation and the need for good customer service.
FIXGlobal: What has enabled the new breed of exchanges to succeed in an illiquid environment?
Bryan Harkins, Direct Edge: This is certainly a challenging time in the marketplace with respect to trading volumes. We are addressing this through a range of products, services and revenues that are non-transactional based and by moving towards more subscription-based products such as market data and connectivity services – basically a suite of technology and connection-based products. The role of an exchange is not just to put buyers and sellers together but also to help move their members’ businesses forward with new data and connectivity products. Innovation is especially important when trading volumes are low.
FG: What advantages do alternative venues, such as dark pools and ATS, in the US enjoy that the incumbent exchanges do not?
BH: Dark pools and alternative trading systems (ATS) are two different business models and there are advantages for each that an exchange may not have, and vice versa. Dark pools and ATS are allowed to restrict access to their platforms, offering different types of incentives for different types of flow.
Exchanges are at times hamstrung, however, because of the current application of the principles of ‘fair access’ under federal securities regulation. Exchange efforts to provide a better experience for retail and institutional orders are often reviewed under the principle: “if it isn’t made available to everyone, it can’t be made available to anyone”. As a result, exchanges can be constrained in their efforts to provide a better environment for retail and institutional investors. This can lead the firms who manage this order flow to seek off-exchange executions. There is nothing nefarious about this; in fact it is consistent with the duty of best execution. If exchanges don’t offer the best trading experience, trading volume should and will go elsewhere.
In the US, we are working with regulators to empower exchanges to offer a better product and experience to long-term investors. Not only would this help restore investor confidence, it would prospectively improve trading outcomes.
On the other hand, exchanges have advantages that dark pools and ATS do not. For example, we have a protected quote. Under regulation NMS, any quote inside the market is protected. It is a very powerful advantage to have a quote in the public market place. Exchanges also have significant brand advantages. It is very prestigious to be an exchange, and with that prestige comes a great deal of regulatory responsibility, which itself produces stronger confidence in our platform for our members.
FG: What will it take for alternative venues to experience further growth in the US?
BH: Alternative venues need to not only provide a place to trade with quality liquidity, but they also need to provide much needed competition against some of the larger exchanges, with lower fees and a variety of trading strategies that help members fill their orders efficiently.
Alternative venues should be a source of innovation, continually thinking of new ways to help members meet their trading goals. In these days of high-speed technology and very sophisticated trading platforms, it really does all come down to aligning yourself in a customer-friendly way and providing good customer service.

Outsourced FIX Connectivity:Implementation and Integration

George Rosenberger, Head of ConnEx at ConvergEx, discusses the need for outsourced FIX connectivity and how it can be integrated and beneficial to broker-dealer infrastructures.
The Need for Outsourced Connectivity
Connectivity-related expenses are probably the second highest expense item for broker-dealers behind execution-related expenses. Most broker-dealers struggle to keep tight cost controls on their own FIX connectivity due to lack of transparency, lack of proper connectivity tools and lack of FIX/vendor expertise.
Benefits of Outsourced Connectivity
Every broker-dealer can benefit, in some way, from outsourcing. Whether it’s helping to reduce infrastructure expenses (such as staff, hardware and telecommunications) or creating greater efficiency and providing for the ability to focus on their core business, outsourcing connectivity makes sense for everyone. Larger firms with in-house technology teams can employ an outsourced FIX connectivity provider to supplement and support their staff for special projects. Small firms that do not employ their own IT staff can outsource this function entirely.
Implications of Implementation
The initial cost of conversion to outsourcing is minimal and any associated costs are normally offset by additional savings realized within two or three months of the conversion. The key is to find an outsourced FIX connectivity model that allows for rapid deployment. Customers need to be live in weeks rather than months. Outsourcing FIX connectivity to a platform-neutral provider means that you can easily swing your inbound FIX connectivity from one provider to another without any repercussions.
Effect on Latency
Most customers will not even notice latency when using a gateway that certifies directly into each customer’s sell-side order management system (OMS). Because this type of solution can replace other types of FIX servers or gateway components, the latency differential can actually be a positive experience, in some cases, depending upon the customer’s current FIX configuration. Also, the added benefit of using dynamic rerouting of order flow for resiliency or real-time message customization makes such models compelling regardless of any latency gaps.
Safeguarding and Segregating Trading Data
It is important to ensure that customers receive the benefit of comprehensive information security policies and procedures, and yet don’t feel disconnected from their connectivity data. While some infrastructure can be shared within a software solutions firm such as telecommunications, routers and firewalls, the primary infrastructure should be managed independently from any broker-dealer. FIX messaging can be isolated by providing each broker-dealer customer with a dedicated FIX interface, ensuring that their order flow is kept segregated and completely confidential. All application data security should be tightly controlled and monitored with a security and access control system that restricts data access.

Real-time Liquidity Mapping:Transparency and Insight

Mark Palmer, CEO of StreamBase discusses how real-time liquidity mapping can be used to improve liquidity sourcing tools and what liquidity mapping offers that aggregation does not.
FIXGlobal: What problems can occur if a trader is unable to access their desired venue, counterparty or price point? How have these problems been exacerbated by lower liquidity?
Mark Palmer, StreamBase: There are two obvious problems about not fully understanding liquidity in real-time: first, missed opportunities for the buy-side. And, second, if you’re a broker-dealer, then the problem is the potential loss of revenue resulting from the exposure created by not fulfilling trades immediately.
FG: What are the tools commonly used to source liquidity and how would real-time liquidity mapping improve them?
MP: The most commonly used tools are rear-view mirror oriented. That is, brokers and traders compile a map of liquidity and performance of liquidity providers in databases. They then generate reports that are reviewed at the beginning of each day, when adjustments are made. The problem with this approach is that traders and brokers become exposed to daily fluctuations and system market errors, which can lead to risk and missed opportunities.
FG: With overlapping aggregators of lit and unlit venues, what does liquidity mapping offer that aggregation does not?
MP: Ad-hoc, real-time liquidity mapping offers three features that simple aggregation does not: predictive analytics, interactive visualization of live venue state and alerting.
Predictive analytics allow firms to establish ‘standing’ continuous queries and to insert them into the stream of live venue information. For example, a trader can ask to identify any security with insufficient liquidity above a certain amount in real-time; continuous queries re-evaluate this condition millions of times a day, and traders can identify exception conditions as soon as they occur, rather than waiting for a report to be issued.
In terms of interactive visualization, like interactive warehouse and business intelligence tools, live liquidity mapping provides ad-hoc, user-driven exploration of data through charts, graphs and tables. Unlike traditional tools, however, real-time analytics allow users to explore information that is literally live – with just milliseconds of latency between the time that data changes and the time when the liquidity data is sliced and diced on behalf of the user.
Push-based alerting and notifications can proactively notify traders, risk managers and heads of desks according to live analytics and business function, creating a kind of push-based reporting style of processing that is revolutionary when compared to traditional reporting styles, and essential when analyzing dynamically changing liquidity pools.
FG: Faster, more detailed information enables a better service for clients, but will realtime liquidity maps be a ‘game changer’ given that brokerdealers and agency brokers have been working on retroactive liquidity maps for some time?
MP: According to a recent Aite Group report on broker-dealers, the quality of their Execution Consulting Services is now seen as more important than that of their trading algorithms. What good is a better mousetrap if it can’t be understood and managed? Live analytics allows broker-dealers and agency brokers to provide real-time transparency and insight as is being increasingly demanded by buy-side institutions.
FG: To what extent is the response to liquidity maps on a human time scale and how much will be handled by smart order routing (SOR) technology?
MP: Real-time liquidity maps are essential to understand, optimize and manage SOR technology. They allow more time to be spent on larger orders, as sales traders are freed up by the increasing ability of technology to provide live order information enabling smaller orders to be processed more quickly.
In large broker-dealer and agency broker environments where multiple SOR technologies are deployed, CEP-based real-time analytics platforms can help integrate and correlate multiple streams of execution data from multiple SOR , providing a single, live view of execution and liquidity insight.

Author Profile: David Leinweber

David Leinweber, author of Nerds on Wall Street: Math, Machines and Wired Markets, talks about the impact of big data on technology, trading, regulation and risk management.
David Leinweber heads the Lawrence Berkeley National Laboratory Computational Research Division’s Center for Innovative Financial Technology, which was created to help build a bridge between the computational science and financial markets communities.
His professional interests focus on modern information technologies in trading and investing. As the founder of two financial technology companies, and as a quantitative investment manager, he is a pioneer in the transformation of markets. At the RAND Corporation he directed research on real-time applications of artificial intelligence that led to the founding of Integrated Analytics Corporation (IAC). IAC was acquired by the Investment Technology Group; its product became QuantEx, an electronic execution system used for millions of institutional equity transactions daily.
He is a graduate of MIT in physics and computer science. He also has a Ph.D. in Applied Mathematics from Harvard.
FIXGlobal: How has big data changed the technology and hardware requirements for latency-sensitive trading strategies?
David Leinweber: Every system has a capacity. This is true for both networks and the many execution systems that make up our modern market systems. Coordination based on new rules places additional demands on that capacity.
We are talking about structured big data, getting too big and too fast for systems to handle. For unstructured big data, some forms – such as simple ‘one-note news’ – has also created a race in latency.
FG: Does big data affect short term, higher frequency strategies more or less than long term, fundamental strategies?
DL: In one sense, high frequency trading (HFT) is not possible without big data. However, longer term investors are affected as well: by the trading process and also by the need to keep up with the techniques required to understand unstructured big data when making investment decisions.
In a broader sense, investor confidence in markets is important. Big events like the Flash Crash tend to erode this confidence. Many traders maintain that there are thousands of smaller anomalies that underpin their confidence in the safety and stability of markets. So far we have been lucky and have avoided major cyber security problems. All this combines to undermine market confidence and many people feel this has contributed to reduced volumes.
FG: Are regulators better off attempting to curtail data volumes (Tobin Tax, excess messaging fees) or radically expanding their capacity for data analysis?
DL: A collection of individually stable systems may be unstable in aggregate. Our ability to realistically simulate and test this is not what it could – or should – be.
Even our ability to look back at what happened when things go wrong is limited by data collection from an earlier era. The heads of both the Commodity Futures Trading Commission (CFTC) and Securities and Exchange Commission (SEC) have pointed to this regarding analysis of the Flash Crash.
FG: Have the risk management strategies at large brokers and institutional investors changed to reflect the increased size of financial data? What changes should be made to intraday risk systems to account for the increased volume?
DL: I don’t have enough information on what has changed at the big firms to give a good answer. Systems may have improved but people have to use them properly. Transparency in markets (especially the much larger swaps markets), and what is traded on them are hot political issues (for example, the Swap Execution Facility (SEF) and Financial products Markup Language (FpML)).
When you say increased volume, I assume you mean volume of data, which is a direct consequence of technology. Trading volume has gone down.
FG: Who can ‘get away with’ not looking at the full data set? For low frequency firms, is the consolidated, summarized version sufficient?
DL: Higher turnover firms are most affected, but big issues of safety, security and stability of modern markets affect all investors.

Increasing Stability and Reducing Risk

Edouard Vieillefond of Autorité des Marches Financiers looks at the factors that contribute to financial stability and how investor choice needs to be balanced with investor protection, market fairness and efficiency concerns.
FIXGlobal: How can the Commission and the European Securities and Markets Authority (ESMA) ‘encourage’ institutions to trade via multilateral facilities?
Edouard Vieillefond, Autorité des Marches Financiers (AMF):
Market transparency, efficiency and integrity are essential to financial stability and to ensure that financial markets continue to play their core role of financing the real economy.
In the context of the financial crisis, in 2009 the G20 leaders declared that “all standardized over-the-counter (OTC) derivative contracts should be traded on exchanges or electronic trading platforms, where appropriate, and cleared through central counterparties by end-2012 at the latest”. In order to implement these objectives, in 2012 the International Organization of Securities Commissions (IOSCO) identified some key characteristics that electronic trading platforms should fulfil in this context, amongst which were pre- and post-trade transparency and “the opportunity for platform participants to seek liquidity and trade with multiple liquidity providers within a centralised system”. We believe that this multilateral criteria, which is not consensual amongst regulators, is absolutely essential in defining what a trading venue is and ensuring the real efficiency of the price formation process on financial markets.
As regards the perspective of the MiFID review, in Europe the Commission proposes an obligation for derivatives to be traded on multilateral trading venues, which shows progress in the right direction. On cash securities, unregulated trading has developed over recent years, including in the fully OTC bilateral space. The Commission’s aim of catching all these new trading spaces within a new EU regulatory framework is a positive one. However, without clearly defining the boundaries of the European trading environment, it leaves aside the possibility for new trading concepts to be developed, including bilateral ones. It also leaves aside more structural issues – such as the role that we want financial markets to play in the near future with regards to the real economy. An essential first step for legislators and regulators in Europe would therefore be to define in greater detail what the EU trading space shall consist of; and then to incentivize trading of standardized and sufficiently liquid financial instruments on genuine trading venues such as exchanges and multilateral trading facilities (MTF).
FG: Where is the balancing point between investor choice and encouragement towards certain venues?
EV: Investor choice is of course to be kept fully flexible but also, on the regulatory side, to be balanced with investor protection, market fairness and efficiency concerns.
In Europe, MiFID has led to excessive market fragmentation, despite the legitimate intention of the directive to enhance competition between exchanges and multilateral trading facilities. This approach has produced very mixed results, including no real overall cost reduction for final investors, an increase in dark trading and a decrease in the quality of pre- and post-trade transparency to the detriment of the market as a whole.
If financial markets are to remain a reference and to serve investors and the real economy, an essential step in reviewing MiFID is to ensure that orders be primarily executed on genuine trading venues. So, a clear distinction must be made between trading venues where prices are formed according to transparent, non-discretionary and publicly known principles that reflect real supply and demand (exchanges and MTFs), and the other trading spaces. To that extent, it is not possible to consider broker crossing networks (BCNs) and therefore organised trading facilities (OTFs) as equivalent to regulated markets (RMs) and MTFs as they do not offer the same degree of transparency (and hence efficiency) of the price formation process. Crossing networks should at best be considered as an intermediate way to execute transactions, for residual transactions that do not constitute addressable liquidity or with a very strict ceiling above which those BCNs should be transformed into truly multilateral MTFs.

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By Jacqueline Loh

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