Phew! No more HFT for me

Some might remember the surprise, back in March 2012, when it became apparent that an individual personal trader could end up being classed as a high frequency trader (HFT) under MiFID II. Admittedly I’m quite proud of my 10 finger touch-typing skills, but I wasn’t sure whether my ability to type really fast could be held against me one day. Finally, after four years,... Read More

Slave to a label?

ESMA has just published a report on high-frequency trading (HFT) activity in EU equity markets. It’s good to see the regulator producing an empirical study on such a hotly-debated and emotive topic. Taking a sample of European stocks, and applying two possible definitions of HFT, ESMA estimates that between 24% and 43% of value traded is done by HFT. This sounds like a nice... Read More

Synchronising regulation

US securities industry regulator FINRA recently implemented new time-stamping rules, a topic also on ESMA’s MiFID II task list. FINRA requires US firms to express time in milliseconds when reporting trades to the FINRA facilities and order events to OATS, while ESMA’s proposal wants HFT firms to timestamp records to the nanosecond. That’s a whopping one million... Read More

Algorithmes de type franḉais

Just as we’re all getting used to the idea of having to flag algos on an EU-wide basis under MiFID II by 2017, the French regulator recently published further guidance under the French banking bill that came into force in July last year. Amongst other things the French bill targets algorithmic trading/HFT and this recent notice calls for French entities to notify the regulator... Read More

What I did not do

When I got into work this morning, I decided not to return a missed call, not to review a document, not to read a report, not to ask some colleagues for advice, not to fill in my timesheet for last month, not to think about further job training and, most importantly, not to join an internal weekly meeting which was covering a topic not relevant to me. Instead I decided to write... Read More

True intentions

With the advances made in automated trading in recent years, regulators are having to work pretty hard to catch up with the markets. ESMA currently has two documents out for consultation on the Market Abuse Regulation (MAR) and has announced a public hearing on October 8th. In parallel, last week saw the publication of the CME’s Rule 575 on disruptive trading. The implications... Read More

Please lock the door behind you

Under MiFID II European regulators introduce new rules around algorithmic trading. Whether it’s algo IDs, enhanced audit trails or business clock synchronisation, none of these items would have been on the agenda if it were not for the rapid innovation in information technology over the past decade. Now ESMA is extending its reach into cyberspace, discussing issues such as cyber... Read More

Hang on a second!

MiFID II introduces the requirement to synchronise the business clocks of trading venues and their customers, standardising the recorded time on post-trade data, transaction reporting and, most importantly, order event auditing. Regulators argue that in the event of unusual market activity they will be able to pinpoint the exact moment things turned sour. A noble cause then, but... Read More

Algo identifiers galore

With the German algo ID mandatory from 1st April, I was prompted to scan the latest MiFID II texts in this regard. Member states must require exchanges to be able to identify the different algorithms used for generating orders (Art. 51.6) which, on a high level, sounds just like the German HFT Act. To make things even more complex, MiFIR requires investment firms to identify in... Read More

Identity crisis for algos

Yesterday saw the publication of the XETRA and Eurex rule changes relating to the German HFT Act in which they provide details of how to implement the new RegulatoryID. Under the new rules it will no longer be enough simply to differentiate between algo and non-algo orders (such as under the current CME regime). Starting from 1st April 2014, all orders sent by an exchange member... Read More

Regulatory front-running

Front-running is regarded as a form of market abuse and is banned accordingly. Although it is widely accepted that MiFID II will implement new regulation on algorithmic and high-frequency trading, that doesn’t seem to have stopped the law makers indulging in a little ‘front-running’ of their own. First, Germany passed its HFT Act ahead of schedule and now France... Read More

The long arm of the law

The buy-side has traditionally been spared from the burden of most regulatory trade reporting requirements, passing this responsibility on to their brokers who hold the exchange memberships. But this principle looks to have been challenged by BaFin, the German financial regulator, with the introduction of its High Frequency Trading Act. One of the aims of the law is to ensure that... Read More

Keeping to the letter of the law

Earlier this week BaFin, the German regulator, held a workshop on the German HFT Act. Global market participants gathered in Frankfurt to discuss and better understand the implications of the soon to be passed law. Questions around the definition of HFT, registration as an HFT firm when operating from abroad and the identification of algo orders were on everyone’s list. Fortunately... Read More

Dude, where is my level playing field?

At the heart of the European Union is the concept of a single market with a level playing field. Markets moving together, where trade and competition create benefits for everyone. Back in 2007, MiFID was a true testament to this when it introduced the idea of passporting regulatory oversight across Europe. Reading the latest regulatory news, there’s precious little to remind... Read More

One cliff avoided, another straight ahead!

The Italian Financial Transaction Tax (IFTT) passed into law over the Christmas holidays and shocked market participants around the world. Quite apart from the increase in tax levels compared to earlier drafts, the Italian government has invented an additional HFT tax based on the value of amended or cancelled orders (click here for more details). The French markets, luckily, didn’t... Read More

Unintended consequences, par excellence

The law of unintended consequences is not kind. It will strike wherever it pleases and sometimes even in places you wouldn’t expect. In an ironic twist, the order-to-trade ratio (OTR) may not calm markets as intended but reduce average trade size even further. The OTR, or some variation of it, is used by many exchanges to manage their message load. Generally speaking, OTR counts... Read More

Is the grass any greener on the other side?

On 30th October the CFTC’s Sub-Committee on Automated and High Frequency Trading Working Group 1 presented its definition of HFT to the CFTC Technology Advisory Committee. This is very interesting, as the European Parliament already published its version on 26th October. Let’s compare notes across the pond. Both approaches define HFT as a sub-category of algorithmic... Read More

Market standards and the warm embrace of regulators

On 30th October the CFTC held a Public Meeting of the Technology Advisory Committee. Among other things, the possibility of a new Quality Management System Standard for automated trading was discussed. The AT 9000 standard is aimed at market system quality for automated trading in the financial industry. A preliminary timeline tells us that an informal working group started in July... Read More

The liquidity genie

Following on from the warnings to the contrary from the UK Foresight publication (see previous blog Some things in life are bad…), we have had a reaffirmation (if one was needed) last Friday from the plenary vote that the European Parliament is going to proceed to target speculation and high frequency trading through their new rules and regulations. The magic of the “Liquidity... Read More

Spotting a heart-shaped cloud in the sky

Last week the Foresight Project published its written report on HFT (see previous blog Some things in life are bad…) which gave a balanced picture with carefully drafted conclusions. However, during a presentation of the report’s findings on 23rd October, there was one particularly interesting issue that caught my attention. One of the speakers referred to a case, presented... Read More

Some things in life are bad…

The next step in the MiFID parliamentary process is the EP plenary vote, to gain the backing of the entire house, scheduled for tomorrow, Friday 26th October. The EP is forging ahead, with little likelihood of further changes, it seems, though there is a debate on MiFID scheduled for today. Given where we are in the timeline of the parliamentary process for MiFID II legislation,... Read More

A sensible request deserves a sensible response

The German government and the European Commission want to mandate earmarking of every algorithmic order in order to identify the originating strategy. The reason being that market supervisors have a difficult job keeping up with all those technical innovations in financial markets. In the good old pit trading days traders were restricted by physical limitations, but in a world where... Read More

What you need to know before buying a German car

The latest draft of the German HFT ruling has some fairly serious implications for market participants and there is little time to prepare. The new law is expected to be finalised sometime in the middle of next year and the legislator expects the industry to comply within a three month grace period. Let’s look at some of the features added since the previous draft published... Read More

The voice of reason

Electronic trading has fundamentally revolutionised financial markets in the last few years. But events such as the flash crash and the recent trading malfunction at Knight Capital have given market participants and regulators cause to worry that Pandora’s Box has been opened. Much of the concern raised by politicians and regulators is down to uncertainty; there is little... Read More

And the winner is … a compromise!

Whoever said the political processes to formulate MiFID II and MiFIR were complicated and boring? Look at it from the right angle and it can be every bit as exciting as the knockout rounds of a FIFA World Cup tournament. In the World Cup football teams compete against each other and only the winner progresses. The last team remaining in the competition takes home the trophy. Politics,... Read More

Germany’s “Best of …” HFT law

A Europe-wide consolidated regulatory framework can have many advantages for the financial industry. Laws such as MiFID II, MAD II and EMIR create a level playing field that simplifies competition on a pan-European scale. However, in the last couple of months a number of national legislations have been enacted that make the playing field a bit more uneven, again. There are, for... Read More

The horse hasn’t bolted, yet!

The Flash Crash catapulted circuit breakers into the public spotlight and showed how they (or rather the lack of them) can impact financial markets. Since then, in Europe at least, discussions have been relatively quiet. European markets are perhaps less prone than others to such massive price swings for two reasons. Firstly, Europe does not have the trade-through rule and, secondly,... Read More

Sacrificial lambs and unintended consequences

Andy the Trader: I heard tick size is a topic in MiFID II, again. Haven’t we been through this already? Yes, you’re right. FESE and LIBA brokered an agreement between most European equity trading venues and sell-side firms in 2009. But the topic appears again in the latest proposed amendments for MIFID II (Article 51) and on ESMA’s work program. Andy the Trader: Once again,... Read More

Scream if you want to go slower

If you read the blogs, the tweets and the industry press, and attend the conferences, you could be forgiven for believing that all traders of financial instruments are completely consumed by the crazy race to zero. Some commentators say the game will run and run in an ever decreasing battle for nanoseconds. Others say that to simply chase and trade latency is not a viable or scalable... Read More

Keep calm and carry on

The debate around HFT and the impact on financial markets is getting more and more heated. The latest contribution is by Charlie Munger claiming that HFTs “have all the social utility of a bunch or rats admitted to the granary” and that “computer algorithms work a lot like legalised front-running of orders”. Maybe it is about time to ask everyone to keep... Read More

Good intentions – bad results

Lobbying  in Brussels can be such a dirty business. Hidden agendas and vested interests are dominating the daily business. Thus, I was very pleased when Finance Watch (a non-industry lobby group, the lobbying arm of Occupy Wall Street, if you will) engaged in their mission to “making finance serve society”. However, the dream of a better world was crushed last week... Read More

Liquidity and the regulation of markets

Last week’s TradeTech in London included a talk about liquidity by David Lawton, the FSA’s Acting Director, Markets, during which he discussed all the hot potatoes that MiFID II has to offer.  For a change, this was not another piece of 500 millisecond nonsense but included some sensible and well considered arguments. Here are the highlights of his key points: •  ... Read More

Block Trade: Endangered species or old habit?

Currently, MiFID favours block trades by granting them privileges that regular sized trades do not receive. A block trade between two institutional investors is treated rather like a Sumatran elephant that is way up on the red list of threatened species. Regulators protect block trades by allowing for pre-trade transparency waiver and delayed post-trade reporting. At the other... Read More

Regulation, regulation, regulation!

As market participants are still reeling from the attack on HFT and technological innovation in the latest draft amendments to MiFID II, let’s take a look at the rapporteur Markus Ferber’s draft changes to the proposed MiFIR EU regulation. The biggest change is that the OTF category, previously proposed in an attempt to regulate OTC trading on broker crossing systems, now looks... Read More

Treat the cause, not the symptom

The current MiFID II draft proposes a minimum duration for any order of 500 milliseconds (see Should have gone to Specsavers!). Politicians seem to believe that installing a minimum duration for orders will halt the HFT ‘madness’ and bring some much needed calm to the market. Unfortunately, it looks like they are going to treat only the symptoms and not the cause. Trading... Read More

Self-test – am I a HFT strategy?

The European Parliament has issued its rapporteur report for MiFID II, as discussed in The Rapporteur’s Story and Should have gone to Specsavers! The current proposal includes a definition of high-frequency trading strategy. Furthermore, it proposes to regulate HFTs more strictly. That scared me a little bit. After all, I do some trading in my spare time so I followed the definition... Read More

Should have gone to Specsavers!

On first reading of the draft report from the rapporteur on MiFID II it is unclear from the wording if the ban on direct electronic access is only in the context of high-frequency trading. Surely this must be the case, otherwise we may as well all pack up now. Additional draft amendments to the MiFID text worthy of note are: •    the timeline is crystallising with the final... Read More

The Rapporteur’s Story

Here’s a taster of what could be coming in the Q1 report from the rapporteur for MiFID II – EU lawmaker wants draft securities law beefed up. Looks like, as we expected, HFT could take the hardest hit and OTFs may be limited to non-equities. Thanks to Tor for spotting this article.  Read More

Another kind of movie night

Let’s face it, a meeting of the Committee on Economic and Monetary Affairs (European Parliament) regarding MIFID II and EMIR is hardly a topic suitable for a movie night. So I wasn’t really that excited to watch their latest discussions on Monday evening in Strasbourg via the internet. However, after seeing the new MiFID movie poster, I was inclined to tune in and watch some... Read More

To Ping or not to Ping?

Headline items for investment firms from the ESMA Guidelines on systems and controls in an automated trading environment for trading platforms, investment firms and competent authorities are listed below: •    comply by 1st May 2012, subject to FSA adoption •    guidelines are based on existing MiFID current industry best practice with little need for any change envisaged... Read More

ESMA publishes its Final Report on Automated Trading guidelines – effective by 1st May 2012

22nd December 2011 – ESMA published its final report on guidelines on systems and controls in an automated trading environment for trading platforms, investment firms and competent authorities. In issuing these guidelines, ESMA rolls out a comprehensive regime governing the operation of electronic trading systems by a regulated market, a multilateral trading facility (MTF)... Read More

Are you sitting comfortably?

A few interested parties settled down on Monday afternoon to watch a live broadcast on EPTV from the Committee on Economic and Monetary Affairs (ECON) – the first European Parliament open hearing on ‘MiFID Review: objectives for MiFID/MiFIR 2′. This debate is part of the open decision-making procedure around the MiFID II draft legislation, published in October,... Read More

Europe’s Hotel California

With the proposed new framework of MiFID II due to increase the supervisory powers of the European regulators, it’s been particularly alarming to watch as the EU’s heads of state try to solve the eurozone’s sovereign debt crisis. Greece’s Prime Minister, George Papandreou, threw a real spanner in the works when he announced his intention to hold a referendum... Read More

MiFID II Digest

While the 10 key takeaways from MiFID II may have given Steve indigestion, we are busy tucking in to the smörgåsbord of recently published MiFID II documents and snacking on all the published articles on the subject. From my reading so far, most looks as expected from the previous version that was leaked in August, with the following worthy of note: Organised Trading Facilities (OTFs)... Read More

Toto, I have a feeling we’re not in Kansas any more!

After much speculation it seems that another North American player will now be dominating the European trading landscape. It is surprising to learn that Kansas-based BATS Global Markets will pay the equivalent of £230 million (using today’s exchange rate) for the acquisition of Chi-X Europe. The latter firm has around 50 employees so the BATS deal suggests they are willing... Read More

Investors warm to the dark side

Interesting article today in efinancialnews comments that in the year to August there has been a marked increase in the overall use of dark pools compared to execution on exchange for equities. The review of MiFID is mentioned and, yes, the ability of Organised Trading Facilities (OTFs) to use discretion and prevent HFT participation on their platforms may be key to execution quality.... Read More

MiFI Leaks!

With reports of a draft of the revised Markets in Financial Instruments Directive circulating in Brussels in recent days, I’d like to bring you up to speed with how we are progressing in the MiFID II back-shop! We are now looking at a marked up copy of Directive 2004/39/EC – the revised Directive a new Regulation (ref tbd) that establishes uniform requirements in relation... Read More

ESMA consults on HFT

ESMA has recently published a consultation paper on its proposed guidelines for “highly automated trading” – HFT, in other words. The guidelines follow recent studies into HFT by the global regulator IOSCO (the International Organization of Securities Commissions) and the UK Treasury. ESMA’s previously stated goal for dealing with the latest ‘bogeyman’... Read More

‘Guns don’t kill people – people kill people…’

This oft quoted statement used in gun control debates attempts to apportion responsibility to a person operating a firearm rather than demonizing the firearm itself.  In applying licensing laws to firearms it would seem challenging, at the very least, to license every gun manufactured or already in existence and thus legislation is often centred on the individual.  This echoes... Read More

How does HFT resemble agriculture?

High Frequency Trading (HFT) is one of the hottest topics under discussion in the review of MiFID. Many of us might not be experts in HFT, but I doubt if our European Parliamentarians are either. They will be voting on HFT and whether increased regulation of this activity is needed in order to guard against the systemic risk they so desperately want to avoid. However, let’s not... Read More

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