Keep the pedal to the metal

Earlier this week ESMA called for delays to the MiFID II implementation deadline. So it’s goodbye to punishing timelines and we can all get our lives back! But hold on, before we breathe a collective sigh of relief, things are not quite that simple. Most importantly, it is not ESMA that can decide on a delay, but the European Commission (EC). Even if Steven Maijoor, ESMA’s... Read More

Best ex transparency moves to the next level

The draft technical standards for MiFID II require exchanges to publish quarterly execution quality reports (RTS 6). Sell-side firms are expected to digest these and update their best execution policies accordingly. Additionally, sell-sides must publish their own execution quality reports annually (RTS 7), which obviously should be digested by the buy-side. While sceptics might... Read More

Return of the concentration rule

A long time ago in a galaxy far, far away… It is a period of calm, with primary exchanges enjoying relatively little competition thanks to concentration rules enforced in many EU countries requiring all equity business to be conducted on exchange. The arrival of a new disruptor, in the form of MiFID I, is about to turn their lives upside down forever. The blanket ban on concentration... Read More

More rules, more problems?

Fixed income, commodity and currency (FICC) markets are dominated by the big boys, the professional traders and investors. In this proverbial ‘champions league’ of markets, retailers are restricted to cheering from the side-lines. Perhaps because it has been assumed that these highly sophisticated professional traders can fend for themselves, the regulators have not... Read More

Staying local in a global world

With the continuous increase in regulatory oversight, many market participants raised concerns about extraterritoriality and the risks to cross-border trading early on. Despite the efforts of regulators around the globe to push equivalence and reciprocity arrangements, the risk of ‘Balkanisation’ of markets still seems very real. Considering the CME is set to open its... Read More

SEF and agency make a perfect MATch

From next Tuesday, February 18th, US market participants will be required to trade fixed-floating interest rate swaps denominated in dollars or euros for standard benchmark tenors on a SEF. Long part of Dodd-Frank’s Title VII statute, this trade execution mandate now comes about and follows the CFTC’s certification of Javelin’s MAT submission last month. During... Read More

Swaps regulation arrives – with a bang and a whimper

The swaps industry has for some time been fixated on October 2nd, the final date for compliance with SEF rules. But really the key date for market participants is when MAT (the “made available to trade” rule) kicks in and that, according to the industry consensus, is not likely to be before February 2014. With many of the 19 new SEFs only submitting their applications... Read More

Is there a doctor in the house?

These days there is no shortage of discussion among practitioners and legislators on how to develop financial markets in the future. And sometimes, like with any old bickering couple, all it takes is a third party perspective to find some common ground, which in this case might just be the academics. As proud supporter of the Sixth Erasmus Liquidity Conference taking place in Rotterdam... Read More

Take a break

Financial markets are global and closely interconnected. While this is largely beneficial for all market participants, it can also create spillover effects with unintended consequences. An academic study argues that liquidity can affect related instruments and create a feedback loop, or, put more pessimistically, a vicious circle. In simple terms, if liquidity evaporates in a derivative,... 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

Obituary: Do-good Chi-X Europe

Young start-ups with highly disruptive business models usually have the luxury of having idealistic mission statements. Just remember Apple Inc. and the promise to “think different” or Google Inc. and their slogan “Don’t be evil”. In my view, Chi-X Europe was directly in that category when, many years ago, Peter Randall was screaming from the rooftops... Read More

Much ado about nothing

ESMA is currently considering providing guidelines on fee structures. This sounds to me like the regulators are reviewing the maker-taker pricing model. MTFs introduced maker-taker pricing to Europe about four years ago, whereby liquidity providers receive a rebate for executing their passive orders, while liquidity takers will pay a fee for executing aggressive orders. Usually,... 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

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

Are we still fighting for a truly integrated Pan-European market?

The harmonisation and consolidation of European markets was truly a hugely successful project for European financial markets within the last few years. We enjoyed massive innovation, growth and new opportunities. Think about it, without MiFID, Chi-X, BATS, European Multilateral Clearing Facility (EMCF), and the Fragulator we would still have to pay ridiculous high exchange fees... 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

More psychobabble?

The power of ‘thin slicing’ is a phrase used in psychology to explain the human’s ability to make sense of situations based on the thinnest slice of experience. I don’t know if this really works but Brussels appears to be doing exactly that. In an attempt to prevent systemic risk and another Flash Crash, the latest leaked MiFID II document (dated 7th October)... Read More

How Organised is your Trading Facility?

One of the primary aims of the review of MiFID is to provide more appropriate regulatory coverage for the multitude of different trading facilities and methods of execution that have emerged over the last 4 years. Currently, under MiFID, trading venues or platforms are classed as Regulated Markets (RMs), Multilateral Trading Facilities (MTFs) or Systematic Internalisers (SIs). A... 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

Brussels falls short!

The global securities markets have experienced a couple of weeks of extreme volatility. Unfortunately, just as they did in 2008, panicked politicians have once again got involved. On August 12th a ban on short-selling was announced by the primary venues in Spain, Belgium, France and Italy with the intention of taming the markets. Short-selling occurs when traders borrow shares and... Read More

Cheaper flights?

At times I’ve got the impression that many of the European MTFs seem to compare themselves to cheap, no-frills airlines. The emergence of MTFs post-MiFID brought lower explicit costs, with incumbent providers like the LSE forced to lower their own rates to compete. In much the same way, the arrival of Ryanair and easyJet on the scene must have put pressure on British... Read More

On the bench

It was great to go back to Spain as one of the speakers at the ‘Leadership Roundtable’ organised by Global Investment Technology in Barcelona last week. The event, focusing on MiFID and the European trading landscape, was attended by a select audience of around 30 senior executives from MTFs to global heads of electronic trading and clearing entities. It’s... Read More

Regulators consider putting the brakes on exchanges

MTF chiefs fear that a regulatory move to standardise controls could potentially see the incumbent exchanges with the power to suspend trading on their platforms. ESMA, one of the European Commission’s new supervisory watchdogs, is homing in on exchange controls and recently sent a questionnaire to trading firms, exchanges and multilateral trading facilities in order to better... Read More

It’s not all about you!

I came across an interesting report published by the European Capital Markets Institute (ECMI) and CFA Institute entitled Restoring Investor Confidence in European Capital Markets. This piece of research is intended to defend the position of the European retail investor. One of the key points ECMI makes is that the initial MiFID legislation hasn’t benefited the end investor.... Read More

Bringing transparency to the BCN – what are your views?

A recent article in The Trade News reported: MiFID II will introduce a new regulatory regime for broker crossing networks (BCNs). Are they not subject to adequate oversight as it stands? Brokers and exchange operators have divergent views on this matter but what counts is the opinion of regulators, who have at least two reasons for tightening up BCN regulation. First, MiFID outlines... Read More

What effect will MiFID II have on market structure?

In the first of our PMQs (Programme Managers’ Questions), I examine the section of the EC’s Public Consultation paper on the Review of MiFID concerned with Developments in Market Structures. With the Consultation Paper, the EC sought market input on a number of aspects of market structure reform – the creation of OTFs (what are these, you may well ask?), automated... Read More

Freaking out about market abuse

The behavioural economics book, Freakonomics, includes a chapter entitled Why do drug dealers still live with their moms? which talks about ‘foot soldiers’, small street crack dealers in Chicago. These individuals, apparently, have a one in four chance of getting killed and they will be arrested around six times during the course of their ‘careers’. All these... Read More

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