HFT Bashers – The Debate Continues

The following is a guest blog post from Greg Crawford, Editor of TabbFORUM


Summer doldrums?

Somewhere on Wall Street maybe, but not in the debate over high-frequency trading on TabbFORUM, the community website for leaders in the capital markets business.

Indeed, TabbFORUM readers know that high frequency trading (HFT) is always a topic of interest; and articles about HFT typically lead to a great deal of back-and-forth between proponents of the practice and those who see no value in it whatsoever.

Even so, we were pleasantly surprised to see the debate flare up last week around an article that Natan Tiefenbrun, commercial director at Turquoise (the London-based multi-lateral trading facility owned by the London Stock Exchange) penned last October titled Responding to HFT Bashers.  Tiefenbrun’s original piece, HFT Bashing touched off a great deal of debate; and rather than respond in the comment section of his article, he simply replied in a separate piece.

That article led to more reader comments than the original, and everyone seemed to have their say.

Until last week, that is…

The flare-up started innocuously enough with a comment about a story that CBOT volume in June had dropped more than 90 percent from June 2010 levels. Another reader cleared that up by pointing out that Reuters used an inaccurate comparison.

That’s when the fun began and the debate was on.

Now, there are more than 117 comments on the post. From quote stuffing to the flash crash to brokers adopting HFT technology across asset classes, the debate has expanded way beyond simply whether HFT firms add liquidity or just volume.

Indeed, one reader cited a recent speech by Andrew Haldane of the Bank of England in which he said that speed limits may be necessary to slow the trading ‘arms race’ and another brought Darwin into the mix.

Here’s a smattering of the recent comments:

“…the idea that anyone would argue about HFT dedication to standing in the way of a market freight train that was running out of control — well that is one of those historical narratives about market maker “goods” and “benefits” that has zero empirical evidence behind it.”

“…has kindly assigned all cost savings to the HFT crowd without considering what trade costs would be without the more predatory of these players…a comon (sic) mistake.”

“Traders need to take back the markets from the computers. Although everybody knows my position on HFT’s, if you don’t, I think they are the scum of the industry, nothing more then (sic) 2nd generation SOES bandits.”

“…in respect of surveillance and preventing market abuse ; interesting as most exchanges are self-regulated and positively adopt HFT = therefore they see no abuse !”

“Would someone please, please, please cite the study that shows how market makers historically have used profits from wide spreads to willingly lose money in bad markets?”

What’s abundantly clear – and not surprising to us at TabbFORUM – is that passions around high-frequency trading run high and TabbFORUM readers are nothing if not passionate.  And thoughtful.

There’s also a lesson in here about the value of community and providing avenues for people to debate issues that are important to them and the wider business world.

Gregory Crawford | Editor, TabbFORUM
115 Broadway, Suite 1204, New York, NY 10006
T: 646 747 3208 | M: 908 343 1936
gcrawford [at] tabbforum.com

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Do HFTs Increase Liquidity or Just Volume?

PropelGrowth Blog

On Monday, the TabbFORUM hosted “The Market Structure R[e]volution” conference. Congratulations to the Tabb team for an excellent program!

The first panel dove into issues around the flash crash and high frequency trading (HFT). Here are some of my thoughts on the panel discussion.

Do we need new obligations for the new breed of “market makers”?
Last year’s flash crash magnified problems with US market structure. While many pundits pointed fingers at the HFT firms for pulling liquidity during the crash, the panel made the point that we can’t reasonably expect liquidity providers to buy or sell at the wrong price during a freefalling market unless there is an equivalent upside.

The panel pointed out that equities market makers need both new incentives and new obligations. There must be clear business benefits for providing market maker services, many of which were eliminated with the advent of decimalization. The panel recommended that regulators re-define obligations and benefits for market makers in light of the current market.

The maker/taker pricing models established by the exchanges and ECNs create incentives for today’s liquidity providers, but these incentives may not encourage real liquidity and accessible depth. If we want to change the landscape and ensure that the markets have real liquidity, perhaps the regulators need to revisit these incentive models.

Do HFTs increase liquidity or just volume?
David Donovan brought up a question that is being echoed in many places. Are the HFT liquidity providers actually providing liquidity, or do they just create volume? Here’s a video where Greg Crawford interviewed Donovan on this subject after the conference: http://www.tabbforum.com/videos/donavan.

The high quote-to-cancel rates create a challenging environment for investors looking for real liquidity. The quotes are barely accessible due to their short validity durations. The panel discussed various options that have been under consideration including quote-to-fill ratios, minimum order durations, and cancellation surcharges. No option seemed to be particularly attractive.

The question about liquidity versus volume is an important issue. I’ve heard estimates that nearly 70% of all volume in the equities market now comes from HFT strategies. If most of the volume is from the HFTs, then are they just executing against each other?

Another estimate places volume in the dark pools at 30%. Interesting correlation. This raises a question in my mind: is most of the “real” liquidity actually hidden away in the dark pools? The correlation of these statistics suggests that a substantial portion of institutional volume is probably being executed in the dark.

Do we need a level playing field?
In the video, Donovan says he’d like to see a level playing field where everyone gets the same data at the same time. But what would this level playing field look like? Do we take away all the technology advancements and slow down data feeds so that no one receives data faster than the slowest buy-side shop located on the west coast subscribing to an aggregated feed?

Or should some benevolent entity grant free technology to all the tech laggards to catch them up with the fastest HFT players? If a firm is able and willing to invest in the technology and infrastructure necessary to process data as fast as possible, then why shouldn’t that firm be able to profit from its investments?

This same buy-side contingent has made extensive investments in portfolio analytics, advanced risk analysis and other technology to help ensure that they get the best returns for their clients. Should we also share that technology with every retail investor to ensure that they can compete with the institutional flow?

Are all the HFTs the same?
The buy-side concern about HFT is real, and it is impacting investor confidence. But in many ways, HFT is getting a bad rap when really, there are many legitimate players, including buy-sides adopting these strategies.

Last year, Bernard Donefer published an outstanding essay about high frequency trading. He makes the point that “Referring to HFT as one undifferentiated practice obscures the benefits and risks in each business model. Many press criticisms leveled at HFT are really only relevant to specific (and sometimes already illegal) strategies and only serve to confuse the public.” http://www.tabbforum.com/opinions/there-is-no-such-thing-as-high-frequency-trading

This is a hot topic, and my opinion is only one of many voices. I’d love to hear your comments.

Warm regards,

Candyce

 

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The Challenges of High Frequency Trading in FX

I recently had an interesting conversation with Arzhang Kamarai from Tradeworx about the role of high frequency trading (HFT) in equities versus foreign exchange (FX or forex), which prompted me to write about the complexities in migrating HFT strategies to this asset class.

PropelGrowth BlogWikipedia defines HFT as “the execution of computerized trading strategies characterized by brief position-holding periods, in many cases taking advantage from [sic] microstructure inefficiencies. In high-frequency trading, programs analyze market data to capture trading opportunities that may open up for only a fraction of a second to several hours.”

Historically, HFT has been predominately focused on the equities market. It emerged as market structure changes created opportunities for arbitrage and as the market making and specialists businesses became less profitable. HFT grew quickly, and in 2010 accounted for as much as 70% of all equity trades in the US.

When HFT first emerged, the cost of entry was prohibitive for most players. But in the ensuing years, the cost for hardware, software, co-location, low latency connectivity and hardware acceleration have all declined. As the technology and infrastructure become more commoditized, more players enter the space, and that results in reduced profitability for everyone.

So the most sophisticated firms are increasingly looking to other instruments as profitability in equities declines.  At the same time, foreign exchange (FX) increasingly has been traded as a distinct asset class. The FX market has grown very quickly in the past few years, growing from an average daily volume of $1.5 trillion USD in 2001 to more than $4.5 trillion in 2010 according to Aite Group. Sang Lee from Aite says, “High frequency trading will represent 35% of the FX trading volume this year (2010).”

The FX market is an interesting space for HFT. It’s traded over the counter, and no single bank controls a substantial percentage of the market. The top 10 global banks control more than 77% of the market. However, according to EuroMoney, the market share controlled by the top three banks actually declined in 2010 over their 2009 market share. There are a number of multi-dealer platforms or ECNs, but these combined control less than 15% of the market. A fragmented and inefficient market is an ideal target for effective HFT strategies.

Each bank or ECN publishes its own prices — generally derived from an aggregated book that sources liquidity from Tier 1 banks and from EBS and Reuters. This creates some interesting opportunities for algorithmic arbitrage strategies.  A hedge fund or HFT firm could aggregate liquidity from multiple banks simultaneously to find attractive prices for aggressive algorithms.

But it’s much more complicated than equities trading. For one thing, banks have to manage their risk, and so they watch order flow carefully. They may widen spreads or even stop publishing prices to a given customer if they sense predatory trading practices. So if an HFT firm wants to play in the FX market, it will need to develop flexible technology that allows it to respect relationships with the banks and play nice, allowing the banks to effectively hedge their risk. Firms that play fairly will be rewarded with better prices and deeper liquidity.

In addition, each bank and ECN offers different types of pricing and order types. Where one bank might stream firm prices, another might send indicative prices that are not executable. Most FX data is delivered in pulse intervals rather than continuously, and by the time the order arrives, the price may have moved substantially. So HFT firms will have their work cut out for them in developing liquidity aggregators, determining pricing, and creating smart order routers that are sensitive to distinctions in the various price feeds and to the relationships with the counter-parties.

HFT in the FX space requires substantial investment in technology and infrastructure. In FXCM’s S1 filing for Initial Public Offering, they state, “FX brokers cannot rely on standardized and inexpensive infrastructure solutions that are available to online equities brokers… This requires large investments of time and money but can result in points of competitive differentiation.”

MarketFactory.com has a helpful infographic that describes the differences between technology needs for HFT trading in equities and FX.

I’d like to hear your thoughts.  Do you think HFT will increasingly target the FX space?  What do HFT firms need to think about as they consider this asset class?  What do the dealing banks need to consider as they adapt their systems to handle this order flow?

Warm regards,

Candyce

 

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Five Quick Social Media Tips for IBs and CTAs

Last week, Phil and I spoke at the National Introducing Brokers Association (NIBA) New York conference. We discussed the topic of lead generation and how IBs (introducing brokers) can use social media to grow their businesses. After the session, we had opportunity to talk to a number of IBs and CTAs (commodity trading advisors) about the challenges they encounter in building their businesses. Most rely PropelGrowth Blogheavily on cold calling, seminars, and referrals to generate new business.

The common complaint we heard over and over is that these IBs and CTAs lack the time and resources to dedicate to building a presence online. As we looked at several of their websites and LinkedIn profiles, we discovered some consistent issues:

  • Their websites often include a lot of educational content, but there is no lead capture mechanism to identify prospects who are using that content. The only lead capture form on most sites is the “open an account” page.
  • Many IBs are using email marketing, but they send out newsletters that don’t include links back to the website, so they can’t track click-throughs to figure out which articles people are reading in their newsletters.
  • Most of the IBs are using LinkedIn, but few have detailed profiles, and even fewer link their profile to blogs.
  • Very few IBs or CTAs are blogging.
  • Many are avoiding putting out information on the web or social media because they don’t understand the NFA rules around promotional content and are concerned about being out of compliance.

I understand that IBs are dealing with time and resource constraints, but using the web to market your businesses is not really optional anymore. I urge all IBs and CTAs to seriously consider several steps:

  1. Update your LinkedIn profile to add detail about what you’re doing. The first thing most people will do when you reach out to them asking them to invest in your fund is look you up on the web. Your LinkedIn profile will probably be the first thing they check. Add content that inspires confidence in you as a trusted advisor. Otherwise, why should your prospect trust you with their money?
  2. Seriously reconsider blogging. Again, investors need confidence that you’re the right CTA or IB to manage their money. If you blog about your principles, approaches, results (within NFA and CFTC guidelines), you can inspire them to have confidence that you know what you’re doing. Even if you only write one blog entry a week, you can start to build up content over time that will inspire trust in your investors.
  3. When you use email marketing, think about what you want to accomplish. Include links to content on your site. Put the main part of your newsletter on the website, and use summaries or abstracts in your emails with a unique link to each article. That will allow you to track who clicks and which articles are the most popular with your readers.
  4. Add some lead capture components to your website that only ask for a name and email address. This allows you to begin nurturing a relationship with a prospect before they’re ready to open an account with you.
  5. Read the NFA rules and get familiar with the promotional guidelines. Focus your content on education rather than pitches. Here are the links to the NFA guidelines:

http://www.nfa.futures.org/nfamanual/NFAManual.aspx?RuleID=9063&Section=9

http://www.nfa.futures.org/NFA-faqs/compliance-faqs/promotional-material/index.HTML

Warm regards,

Candyce

 

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White paper on FX eCommerce / Single-Dealer Platforms

One of the key services PropelGrowth offers is developing content for our clients’ lead generation and lead nurturing efforts. As part of this, we often write detailed white papers, articles, executive briefings, e-books and other marketing and sales collateral.

I just finished a first draft of a white paper describing single dealer platforms or FX eCommerce systems, which are designed for market makers and dealers in foreign currency trading. The paper discusses FX aggregation, pricing, auto-hedging, position-keeping, smart order routing and internalization. This was a challenging project for a number of reasons.

  • FX trading is significantly more complex than equities, which is where I cut my teeth.
  • The white paper was targeted to a sophisticated audience of executives who know FAR more about trading currencies than I could learn in a lifetime.
  • I had to weave in the importance of using an event-driven architecture and a complex event processing (CEP) platform to demonstrate the value of this kind of technology without getting technical since my audience is more of a business audience than a technical audience.

Fortunately, our client, Progress Software, is very well-informed and was able to walk me through a number of product demonstrations and white board discussions so I could learn the product and market. But I also had to do a tremendous amount of primary research to produce the document. I learned some interesting things in the process of my research. Here are a few tidbits:

FX single dealer platforms aggregate liquidity from dozens of sources, identify base pricing, determine and publish pricing to clients, manage positions, handle order flow, automatically hedge positions, route orders to counterparties, and internalize client orders.

The FX market is highly fragmented, with hundreds of dealing banks, ECNs, and interdealer brokers all publishing prices and competing for order flow. Pricing approaches are not standardized. Liquidity may be reflected as streaming quotes, live resting orders, indicative prices, request for quotes, or request for streams.

Every FX deal involves two currencies – one being bought and the other being sold. This means that the dealer takes a position with every execution of a customer order, and those positions have to be hedged promptly to reduce risk. However, prices offered by other banks can shift rapidly, and quotes are not always firm, which makes routing orders and ensuring execution more complicated. The life span and nature of each price varies by venue and sometimes by message. Some venues want a “last look” option allowing them to take a look at the markets before they automatically execute an order. This might result in them rejecting an order at a quoted price even if the price was valid when the order was sent.

Most FX market data is delivered in pulse intervals instead of continuously, and substantial activity can occur outside of regular data distribution intervals, which also affects the validity of prices, especially in a high frequency trading environment.

Geography also plays a role. Since the dealing banks are geographically distributed around the globe, prices have a varying amount of latency when they first arrive, adding more complexity that has to be considered by the pricing engine, smart order router, auto-hedging and risk management.

This is a fascinating market with a lot of complexity that makes it very interesting for someone as geeky as me. As I researched the problem and wrote the white paper, it became increasingly clear that an event-driven architecture really is the ideal approach for creating an FX trading system.

Once the white paper is published, I’ll provide a link in the event that you’re interested in the subject. This has been a fun project, and I’m looking forward to doing more work on this topic. Based on this initial research and writing, we’ll be able to create quite a bit of derivative content for Progress Software’s content marketing and thought leadership programs including articles, executive briefings, slide decks, videos, blog posts, etc.

I recently hosted a TrendSpotters episode on FX ecommerce. You can listen to it here.

Warm regards,

Candyce

 

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Market Access Rule – It’s Not Just About Naked Access

I’ve recently attended two events, talked to numerous experts, and read as much as I can find about the SEC’s Market Access Rule (Rule 15c3-5). One prevailing assumption on the street right now is that this rule only applies to firms that provide “naked access” or unfiltered, sponsored access directly to a trading venue.

But that is not accurate. While this unfiltered or “naked” access was the SEC’s primary concern, the rule affects ANY order that is sent by a customer to an exchange, ATS, or dark pool using the broker’s MPID involving equities, equity options, ETFs, debt securities, and security based swaps. As Gary LaFever of FTEN pointed out, “follow the MPID” (think “follow the money”).

So that means that if your broker-dealer allows any customers to access a market using your firm’s MPID, then you must comply with the requirements of the rule, regardless of whether that customer is a broker-dealer itself and also regardless of what platform the customer uses to send the order – whether through your order management systems, direct market access (DMA) platforms or through their own direct connections to the execution venue. The rule applies to any broker-dealer providing access including sponsored, direct, “naked,” or through an agency broker. Here is a quote from the rule:

“In all cases, however, whether the broker-dealer is trading for its own account, is trading for customers through more traditionally intermediated brokerage arrangements, or is allowing customers direct market access or sponsored access, the broker-dealer with market access is legally responsible for all trading activity that occurs under its MPID.”

The rule creates a number of thorny issues that broker-dealers need to address. For one, the rule requires broker-dealers to establish controls and supervisory procedures that ensure that the orders don’t exceed that customer’s credit and capital thresholds. These thresholds need to be applied across multiple markets and multiple asset classes. The asset classes included are equities, equity options, ETFs, debt securities, and security based swaps. Since most firms trade these instruments on multiple trading platforms and provide access to the markets through multiple silos, the rule will create an integration requirement that many brokers have not yet fully understood.

The rule requires pre-trade risk controls to be applied in order to prevent the entry of any order that exceeds the credit or capital thresholds or that does not meet other compliance obligations. While most order management systems already apply certain risk checks to prevent erroneous orders and ensure compliance with some regulatory requirements, they generally do not have an integrated view of the client’s overall position, exposure, or credit and capital thresholds. So the broker will need to aggregate positions and open order exposure across the trading platforms and across the affected asset classes.

In addition, the broker-dealer must have direct and exclusive control of the pre-trade risk controls that enable the broker-dealer to prevent non-compliant orders from being entered. There are some exceptions to this, but it will directly affect brokers who allow clients to trade using their own black boxes or third party trading platforms.

Here is a link to the rule:  http://www.sec.gov/rules/final/2010/34-63241.pdf.

Here is a link to a PDF file containing an FAQ published by FTEN and NASDAQ OMX:

http://www.nasdaqtrader.com/content/ProductsServices/Trading/FTEN/marketaccessrulefaq.pdf

We’ll be spotlighting MAR in an upcoming TrendSpotters episode. Stay tuned.

Disclaimer: I’m not an attorney or a compliance expert, and this blog post is strictly my opinion and should not be construed as legal or compliance advice. I wrote this post strictly to bring your attention to some of the issues, but this is certainly not an exhaustive list of areas financial institutions should consider when looking at MAR compliance. Nothing on this blog should be construed as the practice of law, legal advice, compliance advice or investment advice.


Warm regards,

Candyce

 

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High-Touch Trading Remains High Value

I’ve been doing some interesting research to develop some thought leadership content for a client. While I normally work more with clients who support high frequency trading, this client facilitates high-touch trading and work flows dominated by voice and chat communications.

In the past decade, there has been a lot of focus on direct market access, algorithmic trading, high-frequency/low-latency trading, and enabling straight-through-processing for automated trading. But while high-frequency and low-latency trading is growing very quickly, high-touch trading still dominates in most asset classes. Even in equities trading, high-touch is still very important. According to the Tabb Group, in 2010, 39% of US and 62% of EU buyside equities trading was high touch. Other asset classes have even higher percentages of high-touch trading.

High-touch sales traders and dealers can still deliver better results for clients who are looking to execute multi-asset trades, use idea-driven strategies, or take advantage of specialized trading expertise. “Throughout our interviews, buy-side traders told us they need the colour, trading expertise, flow and access to risk capital offered by their brokers’ sales trading desks,” says Miranda Mizen, principal and head of European research at Tabb Group.

While the profit margins in low touch automated trading get thinner every year, clients will still pay a premium when they need the expertise of a human who can work their orders. According to Matt Simon at Tabb Group, “Idea-driven funds will pay a premium for services and sales trader coverage and spend nearly 30% more in their average blended rate versus a typical mutual fund company.”

High-touch trading depends on relationships, voice communication, and the expertise of traders and analysts. It requires a great deal of collaboration. As multi-asset strategies become more common, that need for collaboration is only going to grow more intense, and sell side firms are going to have to change to accommodate the new demands placed on them by clients. For some firms, this will mean reorganizing the trading floor. For others, it will demand more collaboration tools such as unified communications, video conferencing, trading system integration, and enhanced trader productivity applications. The sales traders who succeed in this environment are going to need to broaden their thinking, learn more about other asset classes, and identify new ways to add value for their clients.

It’s a new world, but one in which the high-touch sales trading desk can still add significant value.

Warm regards,

Candyce

 

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