I wrote previously about recent declines in trading volumes as an indicator that the HFT “backlash” is having effect. HFT is the unpopular kid in the class no-one wants to sit next to. Witness the recent spate of announcements of new venues that explicitly exclude or penalize HFT and its practitioners. In the FX space we’ve heard about

Mako FX’s plan to build what it calls the fastest trading platform in the wholesale FX market, and more recently the launch of a new venue called FXSpotStream backed by 6 major FX banks who will also be the primary liquidity providers. 

This all gives a real sense of déjà vu, bearing in mind that the EBS FX market was started by a bunch of banks to provide a private inter-bank market, before they let the sharks in and ruined the party. It seems that EBS themselves are now having second thoughts. This highlights something I’ve been saying for some time with regard to HFT; namely, that the market is well equipped to take corrective action if participants care enough, without knee jerk recourse to poorly thought-through regulation. Commercial imperatives will force balancing actions once the pendulum swings too far. This trend is not confined to the FX markets – see CA Chevreux’s launch early this year of Blink, a Dark Pool for European Equities that excludes HFT.

Besides excluding or penalising the HFTs, another "balancing action" I'm seeing is the rapid rise of smart FX execution algos. Our customers have been using traditional VWAP and Percent of Volume style Algos with our Progress Apama FX eCommerce solution for some time, but more recently customers have been telling me how they've had to adapt these algos and build more sophisticated variants, to avoid signalling risk and defeat the HFTs.

This trend to smart algos follows closely what we've seen in the equity and exchange-traded futures markets previously. If it seems like we're re-treading old ground here than that's hardly a surprise - fashions come and go.

But right now it certainly seems that HFT is rapidly running out of friends to play with.

Tune in to our P&L Webinar  “FX Aggregation without the Aggravation” tomorrow to hear more. If you're attending P&L's 2012 Readers’ Choice Digital Markets Awards and Hall of Fame dinner in NYC on Thursday May 31, stop by the Progress Software table to learn more about the Apama FX eCommerce solution. 

The following is an excerpt from Dr. John Bates’ recent commentary on Huffington Post, whch discusses the current state of high frequency trading regulation.

As Aerosmith famously sang: "Rats in the cellar... losin' money, getting no affection." Lately, HFTs have been compared to everything from rats in a granary to highway robbers intent on stealing Granny's pension. Bashing high frequency trading firms has become the latest sport in the financial services industry. So much so that the Futures Industry Association has publicly taken exception to the "emotive language" being assigned to HFTs.

"For example, many people don't realize that market abuse -- as well as being morally reprehensible -- comes at a hefty price for the market. So principal trading firms such as our members have a very real economic incentive to fight market abuse and back regulatory reform," said FIA European Principal Traders Association chairman Remco Lenterman. He noted that the industry's critics chose to overlook the value that principal trading firms add to the real economy in terms of lower transaction costs and greater liquidity, according to Finextra.

Read the full post from Dr. Bates here. 

It seems clear that, with the ever-increasing volumes of data that firms need to manage and monitor in order to catch abuse, Europe has decided to take a firm stance on automated trading. But is all this a case of, as my colleague Richard Bentley suggests, using a sledgehammer to crack the nut?

Clearly, increasing red tape will place a significant burden on firms and may, if we’re not careful, lead to a situation of regulatory arbitrage, or lock those without deep pockets out of the market. Perhaps a better answer is to adopt a three-layered approach to surveillance where the brokers, trading venue and regulators all have a different role to play will help stamp out abuse without necessarily stubbing innovation?

On a recent visit to London, I met with Phillip Stafford at the Financial Times Trading Room to discuss EU market abuse regulations as can be seen in the video here.

So as many new regulations remain wooly, ignored or have yet to be implemented - or in the case of ESMA (the European Securities and Markets Authority) the regulation is simply statements of clarification – the panel was asked how surveillance and risk is going to be managed moving forward? Questions were also  raised about the regulatory burden in the future and whether those outside of the "Big Five" would be able to resource the demands for growing compliance departments. Will this lead to an uneven playing field?

According to TABB Group new compliance costs are indicated at between 512 and 732 million euro, with ongoing costs between 312 and 586 million euros.  But while regulators are still determining what regulation will look like, the need for market surveillance is undiminished. Traders made about 13.3 billion euros ($18.2 billion) from market manipulation and insider dealing on EU equity markets in 2010, according to an EU commission study.  With some arguing that firms can only do so much to survey markets themselves as trades cross multiple brokers and gateways, the panel discussed the need for fragmented market data to be brought together in a consolidated tape and surveillance performed at an aggregate market-wide level. 

With respect to High Frequency Trading, there was discussion and agreement that pre-trade checks should be built in and regulators should be feared, as in some Asian markets where some market participants adopt a mindset that constantly asks "will I be allowed to trade today". That "Fear Factor" is key and there isn't fear of regulation yet in Europe.

The timeliness of market surveillance was discussed with the panel suggesting that transactions should be monitored retrospectively, but also in real-time as they happen. Clearly, there’s still a role for historic analysis of the market as some abuse takes place over an extended period of time and new abuse scenarios are discovered which can then be applied to historical data. It’s a little like having your DNA stored on file for a time in the future when forensic techniques improve. But there is also no doubt that the need for real-time surveillance to spot manipulation as it happens can be a significant factor for organisations looking to protect themselves and the market, which is one of the reasons it is mandated by Dodd-Frank and MiFID II.

Finally, the panel discussed how turbulent markets and highly publicised breaches of banking controls have demonstrated the importance of protecting market integrity. So while an increase in the complexity of market surveillance inevitably leads to an increase in cost, the panel felt that the punitive and reputational risks associated with surveillance failures justify the business case for improving compliance training, processes and technology.  After all, just as you wouldn’t expect the police to prevent all crime by themselves, it’s clear that investment is needed in surveillance technology to give the regulators a helping hand.

The capital markets globally are experiencing a similar revolution now with regulatory change, and the current climate threatens to create a revolt as well.  Market participants may push back on reforms to the point of creating a new state of stress.  Either way, the future presents very real threats to companies that aren’t prepared.  We’re observing a vast expansion of global rulemaking, and a coming deluge of data - especially in the derivatives markets. It’s very expensive and distracting to fix problems after the fact, so we need to act now.  “Hope is not a strategy” – as is often said to have been uttered by famed (American) football coach Vince Lombardi.

In an open letter to Barack Obama published on January 23, 2009, Benjamin Ola Akande advised, "Yet, the fact remains that hope will not reduce housing foreclosures. Hope does not stop a recession. Hope cannot create jobs. Hope will not prevent catastrophic failures of banks. Hope is not a strategy."

Now we have the Dodd-Frank Act in the U.S., MiFID II and EMIR in Europe, all preceded by the de Larosiere Report (EC, 2009), Turner Report (FSA, 2009), Volcker Report (G30, 2009), G20 – Feb 2009 Declarations, Financial Stability Forum Report (FSF, 2009), INF Report (IMF, 2009), Walker Review (UK, 2009), Basel / IOSCO Reviews… the list goes on.  And the rest of the world is watching, waiting, for another revolution.  The intended scope of the most recent reforms seems to almost be panacea, and transparency is the first step.

The next Revolution is happening in Boston, fittingly.  Progress Revolution 2011, from September 19^th through the 22^nd, offers the chance to learn from industry innovators on how they have successfully tackled these challenges within the capital markets.  Customers including PLUS Markets and Morgan Stanley will be there to share success stories.  And Kevin McPartland, Principal at the TABB Group, will be there too.  I’ve included a sneak peek into Kevin’s “Path to Transparency” below.

According to the New York Times, at the Republican Convention in 2008, Rudy Giuliani once said while contemplating Barack Obama’s candidacy, “… ‘change’ is not a destination ... just as ‘hope’ is not a strategy.”  Rudy will be speaking at our Revolution too.  Will you be there?  It will be a lively conference – I hope that you can join us!

-Dan

The Path to Transparency

By Kevin McPartland, Principal, TABB Group

Managing the vast quantities of data born into existence by the Dodd Frank Act and related regulation will present a challenge in the post-DFA environment; but collecting and producing the required data is just the tip of the iceberg. The ability to analyze and act on that data is what will separate the survivors from the winners. This is already true in many other parts of the global financial markets, but the complexities inherent in swaps trading coupled with the speed at which these changes will take place creates unique challenges. Spread this across all five major asset classes and three major geographies, and the complexities become more pronounced.

Margin calculations are proving to be one of the biggest concerns for those revamping their OTC derivatives infrastructure. In a non-cleared world, dealers determine collateral requirements for each client and collect variation margin on a periodic schedule—in some cases once a month, and in other cases once a year. When those swaps are moved to a cleared environment, margin calculations will need to occur at least daily. The result is an upgrade of the current batch process with dozens of inputs to a near-real time process, with hundreds of inputs. Whereas before major dealers could perform margin analysis, client reporting and risk management in a single system, those systems now need to operate independently within an infrastructure that provides the necessary capacity and speed.

The trading desk will require a similar seismic shift, as flow businesses will provide liquidity across multiple trading venues to an expanding client base. Most major dealers are at some stage of developing liquidity aggregation technology intended to provide a single view of liquidity across multiple swap execution venues. Creating this type of virtual order book requires receiving multiple real-time data feeds and aggregating the bids and offers in real time.

Furthermore, rather than comparing model-derived prices to the last trade price to produce quotes, inputs from SEFs, CCPs, SDRs, internal models, third-party models and market data providers will be required inputs to real-time trading algorithms once reserved for exchange-traded derivatives.

Providing clients with execution services presents other challenges. Executing on multiple platforms also means tracking and applying commission rates per client per venue in real time. Trade allocations also complicate the execution process.  In the bilateral world a big asset manager can do a $100 million interest rate swap and spread that exposure across multiple funds as it sees fit. Under the DFA, the executing broker must know which funds are getting how much exposure. Account allocation in and of itself is not new, but cost averaging multiple swap trades and allocating the right exposure at the right price to the proper account presents complex challenges, especially in a near-real time environment.

Risk management, compliance and back-testing data will also require huge increases in processing power, often at lower latencies. Risk models and stress tests, for example, are much more robust than they were before the financial crisis, requiring a considerably higher amount of historical data.

Compliance departments now must store the requisite seven years of data so they can reconstruct any trade at any moment in the past. This is complicated enough in listed markets, when every market data tick must be stored, but for fixed-income securities and other swaps, storing the needed curves means that billions of records must not only be filed away but retrievable on demand. Similar concerns exist for quants back-testing their latest trading strategies: It is not only the new data being generated that must be dealt with. Existing data, too, is about to see a huge uptick in requirements.

In the end these changes should achieve some of the goals set forth by Congress as they enacted Dodd Frank – increased transparency and reduced systemic risk.  The road there will be bumpy and expensive, but the opportunities created by both the journey and the destination will outweigh any short term pain.

This perspective was taken from the recent TABB Group study Technology and Financial Reform: Data, Derivatives and Decision Making.