Friday, June 26, 2015

Benchmarks, Global Warming and Swimming to the Isle of Wight

The FCA has published their Monthly Regulation Round Up.
It's a good way to remain abreast of what's up.
You can subscribe here:
http://www.fca.org.uk/news/june-2015

A couple of issues of note:

Fair and Effective Markets Review (FEMR).
FEMR made a number of findings and published 21 recommendations designed to ensure that wholesale Fixed Income, Currency and Commodity (FICC) markets are fair and effective.

The final findings are now available (from the BoE).
http://www.bankofengland.co.uk/markets/Documents/femrjun15.pdf

Benchmarks

Well, first there was one: Libor
...and what a kerfuffle that made with the "Wheatley Review"
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/191762/wheatley_review_libor_finalreport_280912.pdf

...and then there were some standards...
IOSCO Standards for Financial Benchmarks.
https://www.iosco.org/library/pubdocs/pdf/IOSCOPD415.pdf

...and then there were 7 more to add to the fold...

The benchmarks being brought into scope are:
Sterling Overnight Index Average (SONIA)
Repurchase Overnight Index Average (RONIA)
ISDAFIX (soon to be renamed the ICE Swap Rate)
WM/Reuters (WMR) London 4pm Closing Spot Rate
London Gold Fixing (soon to be replaced by the LBMA Gold Price)
LBMA Silver Price
ICE Brent Index


I think all of the above are fairly familiar....but for me, I was not aware of the State Street tie in with WMR. 
The WM Company (WM being World Markets, interestingly, a State Street business.):
http://wmcompany.com/wmr/Services/ClosingSpotRates/index.htm
http://wmcompany.com/pdfs/WMReutersMethodology.pdf


Now for those of us familiar with the closing price process (Mark to Market, margining etc.) the importance of all the above makes sense. However, with the renewed interest in this sector it does highlight further potential conflicts of interest. Hence...

FCA's CP15/18: Fair, reasonable and non-discriminatory access to regulated benchmarks
http://www.fca.org.uk/news/cp15-18-frand-access-benchmarks?RRU0615&section=investment-managers

Then of course, with all ths happening at the UK level...whats going on at the EU level?
More here:
http://ec.europa.eu/finance/securities/benchmarks/index_en.htm

This is 'dangerous' stuff. What is in scope and what is out of scope? To make matters worse there doesn't appear to be consensus between the Parliament / Council and Commission.

In conclusion it leaves me wondering 2 things:
1. Regulators want "Champagne Benchmarks" whilst the industry has a "Beer Budget". Great benchmarks, committees, supporting data and process etc all comes at a cost....which leads to;
2. Have we lost sight of the golden goose? Somewhere in here there is a fine line between "materiality and proportionality". Sure, asset managers / users need great benchmarks...but if the operational risks and responsibilities and not to mention the regulatory risks deter contributors...have we really improved the quality and robustness of a benchmark? Sometimes a Mini is perfectly adequate to travel from A to B. We don't always need a Rolls Royce (as nice as that may be).

Anyway, enough about Benchmarks for today. Obviously always interested for any thoughts and feedback on the topic. My interest is now that we've arrived here, where is this segment going and how will it get there?

A little bit of surfing...
I enjoyed this...I started with Global Warming but found myself drawn in...
http://www.bloomberg.com/graphics/2015-whats-warming-the-world/

Minimum wage / Base salary.
I like what this CEO has done in terms of addressing the "minimum wage" debate.
The article doesn't actually say what the lowest salary is, but it does say about 30 people can see a pay rise upto the new 70K as a minimum salary level.
No science to support it, but lets say 30 people on average get a lift of 25K (some more, some less). At a cost of 750K, and lets allow some loading, so say 1 myn, that looks like a worthwhile gesture and investment. I can think of a lot of other projects that wouldn't get as good a return for a 1myn investment.
The problem is, we still don't account for things like intellectual capital, employee churn etc. The 'soft' metrics are still not measured in hard dollar or operational risk terms.
http://www.foxnews.com/us/2015/04/15/seattle-boss-raises-entire-company-minimum-wage-to-70000/?utm_source=zergnet.com&utm_medium=referral&utm_campaign=zergnet_485717

...and finally...
After International Derivatives Week (https://idx2015.fia.org/) I was tempted to do a little swim for a good cause.  crossing from one land mass (UK) to another (The Isle of Wight).
http://www.swimmingthesolent4mnd.com/

Sea Temperature (circa a toasty 17.5 degrees)
http://www.seatemperature.org/europe/united-kingdom/ryde-september.htm


Any feedback always welcome.

Have a great week-end one and all!

Scott.
www.clearingandsettlement.blogspot.com




Friday, June 5, 2015

Back to blogging, Flash Boys, Order Handling, Order Types...and Knowledge a system, not a goal.


cartoon

G'day All,

Well, it's been a while between drinks, oops, blog posts, but time to start collecting some thoughts again.

Old news now, but I did want to put some thoughts down about flash boys.
First of all, I do not want to recommend the book. I would hate to encourage anyone to buy the book as I don't think it is meaningful enough to advance the debate around best market practice and the role of HFT.

Sure, there are parts of it that are a good read but I do think it is a wasted opportunity to have added some real perspective to the debate.

For me there are 2 stories going on in the book. One about market access and low latency and then another story about enforcing proprietary rights, sometimes over open source code. I feel throughout the book Lewis fails to take the time to distill and demark the issues he is trying to address. E.g. Software and Hardware are often bundled together. It just leaves me feeling this book was rushed to press prematurely.  

Lets set aside the sad story of Sergey Aleynikov. That leaves a tale of HFT.
The story of building Spread Networks line from Chicago to New Jersey is nice, but nothing new. To me it is no different to a toll road. We all use them. We know we have the option not to, but sometimes, lets say time is money. But again, is this so different from having a line of sight from the old trading booth onto the pit floor?

By the middle of the book we start to get into the detail of order handling and order types...and it is here that Lewis, in my view, fails to go deep enough or to clarify the issues he is trying to address.

For example...what is front running? Lewis implies all HFTs, by virtue of having access to technical infrastructure, front run the market.  

"In common usage there are at least two meanings to the term. One common meaning is as shorthand for "front-running demand," which is what happens when someone tries to figure out whether your mutual fund or your pension fund is buying or selling stock, realizes that it will change supply-and-demand dynamics for the stock, affecting the price, and front-runs that demand to profit.

Imagine if someone made a reasonable guess you needed milk, raced ahead of you to the only store in town to buy up all the milk before you got there, and then offered to sell you milk at a higher price than the store sold it to him; this is one example of front-running demand, just as described in "Flash Boys." (It's also called "trading ahead.") Another common meaning is "front-running a customer order," a type of insider trading, where a stock broker believes his own customer's order will change supply-and-demand and tries to profit from that"
By In the markets Published on Amazon.com

The next bit that I thought could have been just as useful was a deeper exploration into order types. Again, we just get a scratching of the surface with a bit of fear mongering thrown in. Hardly advances the cause.

I did however find this run down of order types more useful:
https://www.kcg.com/uploads/documents/KCG_Demystifying-Order-Types_092414.pdf

I am often amazed at the quality of analysis done by the people at Nanex.
This paper specifically investigates exploratory trading that attempts to determine whether the bid/ask spread is about to shift up or down a level.
http://www.nanex.net/aqck2/4136.html

The last part of the book is just a slavish devoted sales pitch for the IEX exchange and their business model. Looks like Mr Lewis took the bait: hook, line and sinker.

Their story here:


http://www.iextrading.com/

So, my takeaway is that regulatory scrutiny around equity execution is not going to fade away. I think it will remain front and center for the coming years and the regulatory lasso will probably tighten under the guise of harsher interpretation of 'best execution'.

TR14/13 - Best execution and payment for order flow.
https://www.fca.org.uk/news/tr14-13-best-execution-and-payment-for-order-flow

Right, enough of a Flash Boys rant.

A few other snippets below. More to follow.

In terms of logisitics, I will post this blog (obviously) at:
www.clearingandsettlement.blogspot.com
I will also post it on the LinkedIn Group CCP Clearing Houses.
https://www.linkedin.com/grp/home?gid=2026241
I will also try and "push" this out via my contacts list.

If you would like to be included...please just ping me a note.
If you'd like to be excluded...sorry for the spam and please just ping me a note.

...and for  bit of fun, I recently did this (Fat Boy Slim and Zoe Ball observed)..
A spot of charity fun on the 'beach' (?)...the Brighton Big Balls run.
http://www.brightonbigballs.com/

Whatever your pleasure...have a great week-end.

Scott.
www.clearingandsettlement.blogspot.com


Policy

EFAMA has today published a response to the second FSB/IOSCO consultation on the assessment methodologies for identifying non-bank, non-insurer (NBNI) globally systemically important financial institutions (G-SIFIs).
http://www.efama.org/Pages/EFAMA-argues-against-the-perceived-systemic-nature-of-the-asset-management-industry--.aspx
*** I'm not so comfortable with extending the net over Asset Managers.

Building a Capital Markets Union.
http://ec.europa.eu/finance/consultations/2015/capital-markets-union/docs/green-paper_en.pdf

EU REFORM A view from TheCityUK
http://www.thecityuk.com/research/our-work/reports-list/eu-reform-a-view-from-thecityuk/

Stuff.
I did used to like Scott Adams and Dilbert very much. Now I think some of the material is not so fresh. That said, he does still hit the nail on the head. I notice he has also started blogging. I enjoyed this post:

In terms of my practical application I see knowledge and learning as a system, not a goal. We all travel various paths in our careers. It is how you transfer your skills and knowledge across disciplines and how we learn to communicate in the right context with other practitioners that is part of the fun of the journey.

The opposite of talking isn't listening.
The opposite of talking is waiting.
- Fran Lebowitz.