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Capital Group’s Brian Lees is driving efforts to ask more questions of brokers, and for more data on where an order is shown before it executes, but can the buy-side handle the resulting deluge?

The current work you are doing on venue reporting analysis
Our first push was simply to try to collect information about ‘where’ we were executing and a little bit about ‘how’ we were executing, namely, did we post or did we take liquidity. So having done that, the question was where do we go from there? And as such, the topic of requesting more data on where we didn’t execute and what order types were used started to be raised by some representatives on the FPL Americas Buy-Side Working Group. Some participants had already started down this road with brokers, asking for information relating to post-trade about where their orders were sprayed out to by the algorithms and what types of orders were placed on exchanges and also which exchanges they were on, etc. So that’s where the conversation began and that’s where we reached out to Jeff Alexander and Linda Giordano, because Barclays had already spearheaded this conversation.

What we are looking to achieve either in real time or post-trade, is whether we can standardise a format for brokers to tell us how our order interacted with the market, including when the order was placed, what order types were used, where it was placed in the markets and whether or not we got hits. The concern with this is not so much can we get it, because if we sign enough non-disclosure agreements we can get the information from the brokers. Some brokers have concerns about that information getting out and somebody reverse-engineering their algorithms, but from the buy-side perspective, I think the biggest concern is whether we can manage the volume of data that we would get.

The resources to store and analyse data and make some sort of good use of it
With the original data that we were getting, on where the execution took place, we talked a lot about this with smaller firms who were using TCA vendors to help them analyse this information. With this type of information, if we went a step further, the brokers would not want us sending that out to TCA firms, because it shows their methodology for how their algorithms behave. I was in New York several weeks ago and took the opportunity to meet up with Jeff and Linda while we were there. We invited Jeff to join one of our conference calls for the buy-side committee, which he did, and he talked about what they’ve been proposing. He showed proposals for both the real-time collection of data, via FIX messages, actually proposing a whole new FIX message to be created for this purpose, which could then be sent in real time. Or, alternatively we could standardise a format for collecting the information post-trade which, as a spreadsheet, would then tell us what we want to see. We’re trying to standardise how you ask for the data and what format it is going to be in, by creating best practices for how to get the data from the brokers. That way the brokers don’t have to keep coming up with a different format for every client that asks for it. The best practices do specify that the ISO MIC codes would be the standard for identifying the exchange that you executed on, but we said nothing about what you should do with the data once you get it.

Exchange involvement in the conversation
We did talk to some exchanges when we were first trying to standardise how to identify the exchanges, because when we first standardised the MIC codes, they did not cover all the exchanges, this was due to the fact that they hadn’t all registered with the ISO organisation and we wanted them to.

We had a little bit of trouble in differentiating the dark order books from the lit order books and some of the exchanges that have both. These exchanges consider themselves a hybrid book, and they didn’t want to be known as two different things. We didn’t have a way to differentiate the dark and the lit flow without introducing yet another FIX tag. That back and forth added to the conversation as part of the registration authority’s decision to come out with the new market segment concept, which says you can have an exchange defined and have child MIC codes that differentiate different segments of the market. We’re beginning to start conversations with exchanges about this topic, but that’s the extent to which we’ve had any discussion with them.

Broker willingness to participate in the process
The first half of this, just getting the information about where you executed, the brokers didn’t have any problem, because it’s public record once it executes. When we started talking about the more detailed reporting, they did raise a concern about the information being sent out and NDAs so that, you, as a client, are not going to send the data out to a third party. But because other firms had already started down this road we talked about the purpose of this, which was just to have someone looking over their shoulder to make sure that they are acting in the best interest of the client and not potentially favouring rebates over best execution; they can’t really argue with that logic. Somebody should have some oversight as to whether or not the right decisions are being made.

Quant and prop traders share perspectives with Weng Cheah, Managing Director of Xinfin, about the evolution of high frequency trading.

It is unsurprising that we feel swamped by our rapidly changing industry. However, to bring some experience to these words, I had a number of conversations with quantitative and proprietary trading professionals who are responsible for managing money for themselves, or in a fund. Whilst it is not appropriate to name these individuals, the following reflects some of their perspectives.

Trading has changed dramatically in the last 25 years; firstly in that we are no longer physically present in the pit. One US-based hedge fund manager I spoke to went so far as to say that the industry had “never seen so much change in one person’s lifetime.”

This ‘electronification’ of the markets was the necessary catalyst to what has been a continuous evolution in trading, where technology has been a constant companion. However tempting it is to assume, one thing is certain, where we are today did not start by someone saying “I need to be microsecond quick to win.”

Information Process
The investment process tries to manage uncertainty by seeking information that can be sorted into a model through which we can understand the value of an asset. Information is at the heart of all investment, what is curious is that all investors do not select the same information.

There are those who will research the company and build fundamental models from the financial statements and returns as their basis for trading, and a tactical allocation model based on how macroeconomic trends could set their trade quantum.

However, there are also traders who would look at asset price history and examine price actions to set their strategy. As one US-based fund manager said “the price of corn knows more about corn than I do” reinforcing the idea that price is the source of all information.

Quantitatively they recognise that they can increase their absolute return without taking on any additional risk, by stepping up the frequency of trading. Although transaction costs are higher, this is more easily managed than market risk.

Emma Quinn, AllianceBernstein’s Head of Asia Pacific Trading discusses accessing liquidity through dark pools, aggregation and asset allocation.

Trading Volumes, Liquidity and Asset Allocation
I think that you’ll see trading volumes rise when you get an asset allocation back into equities, and people have more conviction in the markets. The reason that there’s just no liquidity in the markets is not because people are worried about exchange mechanisms or aspects like that, it’s about the macroeconomic environment and the allocation into equity.

I don’t think that we’re going to see volumes in other asset classes recover faster than allocation into equities as we’ve already seen that allocation change. People are either bullish or bearish, and are set for what they think is going to happen. And so we are in a position that people will just trade around their positions without making any significant move either way until we get some clarity on the macroeconomic environment.

The Rapid Expansion of Dark Pools and Access to Desirable Liquidity
We use dark pools to access liquidity for orders we would not normally place in the central limit order book. I think dark pools aid price discovery. There has to be post-trade transparency but once that happens you’ve actually got more transparency on a market than you normally would. In this sort of environment, because you’re not putting out so much into a central limit order book, what used to be 10% of average daily volume is now 30% of average daily volume, you’re obviously leaving more in a dark pool if your order size hasn’t changed. I do think dark pool liquidity aids you, as your expected cost is going to be lower and thanks to post trade transparency in dark pools the market sees a block trade that it would not have seen.

With regard to desirable liquidity, I think the onus is on the buyside to actually put in parameters that can minimize risk. Obviously, you don’t want to go into a dark pool blindly. The same thing could be said of going on to the central limit order book. The same thing can happen to you on a central order book as can in a dark pool, if you’re not smart about the way you trade in a fragmented environment you leave yourself open to be gamed.

Best Execution
We have an unbundled commission policy and as such our traders are not limited to paying based on a research vote. We have the discretion to use the broker that will give us the best execution outcome. This discretion is important and enables us to focus purely on the best execution outcomes for our clients.

Impact of Direct and Indirect Costs Imposed on Buy-side Traders by Liquidity Fragmentation
We spend a lot of time on quantitative trading strategies and both post and pre-trade cost analysis – we have pre-trade expected costs in our trader management system and we also look at post trade – both daily and weekly as it is not enough just to look at one trade in isolation as so many factors can contribute to whether you have got a trade right or wrong.

Some of the cost of fragmentation has already been borne by the buy-side and sell-side, such as having to have smarter systems and employ quantitative trading. Brokers are now wearing additional costs with some regulators looking to recoup the costs that come with the increase in surveillance costs for a fragmented market. The brokers may have made savings due to the fact that we now have multiple markets and with that came a compression on exchange fees, but they could well and truly be paying that out now to regulators.

Aleksander Weiler, Senior Portfolio Manager, Public Markets Investments, Canada Pension Plan Investment Board (CPPIB) talks to FIXGlobal about evaluating asset managers, best execution within FX and managing risk across portfolios.

Evaluating Asset Managers
We are looking for people and groups who have a sustainable edge and we use all the tools available to ascertain their suitability. That involves an understanding of the investment process and the investment team. This is supplemented by quite a detailed analysis of the track record as well as its veracity.

We spend a fair bit of time looking at risk in all its various dimensions. Typically, that devolves into examining the risk process, people and structure as well as the management of the balance sheet and the debt capital of the fund and how the equity capital is structured in terms of the investor base. Most asset managers are medium-sized enterprises, so an understanding of business structure and sustainability are required.

It is necessary to be able to evaluate expected return and expected risk and it is important for us to ensure that a manager’s definition of profit is as close as possible to ours. While you want someone with a good and sustainable expected return and reasonable and bounded amount of risk, there also needs to be a value proposition that sees a fair split in the profit between us, the capital provider and the manager, the risk taker.

For trading-oriented strategies, we use a number of analytical tools, specifically Excel and Matlab. In addition, a wide range of supporting data is used. We also use risk engines internally such as RiskMetrics and Barra.

Best Execution
We invest in a wide range of managers from those doing systematic, long-term investments to those doing systematic short-term high frequency trading as well as discretionary traders. Regarding best execution within FX, we are looking for people who are aware of both their footprint and the transaction costs that they are incurring; specifically, people with electronic execution and the capacity to execute in all time-zones.

Additional venues offer potentially greater liquidity to managers, which is important especially where managers are running multi-billion dollar portfolios. Not all currencies are equally liquid, bringing additional sources of liquidity that can be accessed in a less obvious fashion. This allows managers to not only get the trade done, but also execute in a quiet fashion that doesn’t disturb the market. We also like the fact that these venues are often technology based, allowing managers to perform finer and better transaction cost analysis, which is important because one of the great things about FX is its deep liquidity and 24-hour trading. However, not all currencies are traded equally at all times during the day. Getting a euro-dollar trade done during European business hours is relatively easy and low cost, but trading something like a minor emerging market currency outside its liquid hours can be quite expensive.

This in turn leads to heavier investment in technology. Managers need to upgrade their infrastructure to accommodate multiple feeds as they need smart routers, improved data storage capability and intercom connectivity with the various brokers or groups. All this means that the old days of picking up the phone to get an order done by your FX broker has been mostly replaced by a heavy rack of servers and top-notch IT people, though phones and people still matter for market colour and depth.

Best execution requires maintenance of a transparent chain of tracking orders from signal generation to execution. FX is not regulated in the same way as a stock exchange but you need to be aware of what is happening just because restrictions on various markets are changing every day. From that point of view, managers need an increased awareness of what is happening in the marketplace and an ability to alter their trading behavior if necessary. This in turn has emphasized the role of technology in best execution.

Citi’s Salvador Rodriguez and Daniel Mathews explain how best execution has evolved alongside MiFID and how the latest proposals are likely to affect buy-side and sell-side trading desks.

How is best execution under MiFID II different from MiFID I and from pre-MiFID? Where have we come?

Daniel Mathews, Citi: Although we are referring to MiFID II, we are at the early stages of the MiFID II legislative drafting process. The European Commission (EC) published its proposals last October,T and there will be a number of amendments proposed by the European Parliament over the coming months. The Council of the European Union (EU) will also table amendments and ensuing agreement between the EC, the European Parliament and the Council of the EU (27 member states) will then be required. It is not yet clear what MiFID II and MiFIR will look like in final form as there are a number of key areas which are acknowledged by both sides to need addressing. What is clear is that there will be significant changes to the drafting that is on the table at present.

Salvador Rodriguez, Citi: With the MiFID II process we have seen closer alignment between buy-side and sell-side interests. There is more cooperation between the buy-side and sell-side with a view to what may or may not come out of MiFID II; and this in itself, is a clear improvement from the earlier iterations, which is encouraging for the business at large.

DM: Certainly, the meetings we have had with the buy-side indicate that they are taking far more interest in what MiFID II will mean for them; they want to participate in the debate and are keen to understand what we are doing from a sell-side perspective.

Tools and strategies that have become accepted best execution for many brokers are now under review (e.g. broker crossing and the Systemic Internaliser (SI) regime). How difficult will it be to provide comparable offerings within the SI framework?

DM: One of the current challenges is understanding how the SI regime will operate under Ferber’s proposals and understanding the unintended (or intended) consequences of the amendments, such as ‘all OTC trades must be conducted under the SI regime’. The scope of the SI only extends to liquid stocks, so what happens to non-liquid stocks? Can we trade them outside an SI? Will all risk trades need to be executed within SI and therefore within published firm quotes, even though a risk trades to client may warrant a price outside firm quotes? At the moment, there are many unanswered questions raised from Ferber’s proposals concerning what the SI regime actually means for us and our clients.

SR: As Dan has alluded to, many of the requirements have fallen into the lap of the sell-side. From a trader’s point of view, the tools, strategies and decisions around how to execute a trade will probably not change significantly. Traders will continue to send VWAP or participate with volume-type orders. Naturally, there are pending questions around how risk is employed and whether firm capital can be used within an OTF environment. As a broader business, how clients and orders interact with risk, and how we internalize house flow, are wide-ranging questions. There is no one clear answer; it is a multi-layered problem and there are still grey areas to be resolved.

From which of the MiFID updates will institutional investors notice the biggest change in execution quality and/or strategy?

SR: The MiFID proposals will clearly affect everyone. Under the Commission’s proposals, a BCN would be an OTF and an SI is not a venue. I think this needs to be unpacked. Legally the classifications are fairly clear – you can trade on either a trading venue (RM, MTF, OTF) or OTC and if the latter then to the extent the trading is systematic and frequent then the firm must be an SI. As Dan says though, Ferber’s amendments have muddied the waters so that it’s not clear how an SI is intended to function. Our job is to figure this out through dialogue with our buy-side clients, and we have been seeing many of them recently on market structure road shows, explaining where the current process is at and the areas still to be resolved.

Schroders’ Head of Asian Trading, Jacqueline Loh, shares her thoughts on trading in Asia, offering comments on which markets are primed for change, how to find value in dark pools and whether unbundling is as useful as people say it is.

Asian Fragmentation

Fragmentation arising from multiple sources of liquidity is a necessary step in the evolution of best execution and in the long term, fragmentation will increase the quality of trade executions in Asia. What it means for the buy-side is investment in infrastructure spending to develop new order routers and the like, so we can electronically seek out and have exposure to multiple liquidity sources. For the sell-side, it means acceptance that there will be more competition for the same block of business in the marketplace. It means different things for different buy-side firms as well.

Investor IDs

When I think about the investor ID markets in Asia, I am not sure any model is particularly productive because ID markets make it administratively more difficult to trade. IDs can make best execution very difficult to implement, especially if cash and stock checking is the primary consideration. Some of the ID markets, namely Taiwan and Korea, allow trading through omnibus accounts and that seems to be the way it is evolving. The ID markets are slowly going away, but having said that, the most productive example is probably China because the brokers seem to have a handle on exactly how much cash and stock you have in your account, and therefore how much you can sell and buy. You cannot overspend or oversell, and it is relatively easy to take part in IPOs.

Trade allocation used to be a problem with investor IDs; for example, explaining to compliance and regulators why the prices are not exactly the same between accounts. In these cases the use of omnibus accounts really help. Executing through omnibus ID means you know exactly what is in an account and do not experience many of the issues associated with overselling or settlement. It is a lot cleaner.

With retail-heavy markets, anonymity is the primary consideration for us. We tend to trade more using electronic means and make use of dark pools in retail-heavy markets. In addition to that, the algos we use will be more price-specific, rather than volume-participation models, which are more price impacting.

Best Execution, in the Dark?

You would think that dark pools would have more success in markets where spreads are currently wide and there is a need to be anonymous, which would imply ASEAN markets. In practice, however, it has had more success in Hong Kong, and that is because there are more users of electronic trading there. Perhaps the users are a little more sophisticated as well insofar as they are willing to take accountability for their executions. Which is, in fact, what defines electronic trading.

In our experience, dark pools make a difference in terms of liquidity, however, the question is what creates that difference? Is it the electronic trading system feeding through the dark pool that provides the benefit or is it the dark pool, itself? I would say it is the former, but that may depend on each user. routers. I hope the Securities and Exchange Board of India will consider further change including allowing stock crossings and clarifying the rules regarding P-Notes.

Richard Nelson, Head of EMEA Trading for AllianceBernstein, shares his perspectives on navigating volatility, prospects for developing exchanges, new regulation and the balance between transparency and best execution.

FIXGlobal: How much does volatility affect the way that you trade and what are you using to measure volatility on the desk?

Richard Nelson, AllianceBernsteinRichard Nelson, AllianceBernstein:
We use an implementation shortfall benchmark, so the longer we take to execute an order, the wider the range of possible execution outcomes. Volatility, in particular intraday volatility, increases that potential range, so you could see very good or very poor execution outcomes as a result. In reaction to that, we take a more conservative execution strategy or stretch the order out over a longer time period. And, for instance, if we get a hit on a block crossing network, we will not go in with as large a quantity as we would in a less volatile market. In that way we try to dampen down the potential effects that volatility might have on the execution outcome.

FG: How is AllianceBernstein using technology to improve performance and cut costs on the trading desk?

RN: It plays quite an important part and has done so for quite a while. We are pretty lucky in that we have a team of quant trading analysts. Most of them are in New York, but we have one here on the desk in London, and they help us to analyze the changing market environment and recommend the best ways we can adapt to it. Our usage of electronic trading has increased in the last year, we benefit from the quant trading analysts looking at the results we are achieving with our customized algorithms. We are more confident about getting good consistent execution outcomes because they are monitoring the process and making the necessary changes to ensure the results are what we are expecting. This, in turn, increases the productivity of the traders I have on the desk. They can place their suitable orders into these algorithms and let them run which allows us to focus on trying to get better outcomes on our larger, more liquidity-demanding orders.

On top of that, as market liquidity has dropped significantly, we are trying to make sure we reach as much potential liquidity as possible, and ideally we want to do that under our own name rather than go to a broker who then goes to another venue. We believe that going directly into a pool of liquidity is better done under your own name rather than via a broker because we can then access the ‘meaty’ bits of the pool rather than the ‘froth’. We are looking into ways of doing that but one of the problems is that, potentially, you get a lot of executions from a number of different venues, which results in multiple tickets for settlement. Our goal is to access all these potential liquidity pools, yet also control our ticketing costs, which are a drag on performance for clients.

FG: Was it an intentional change to increase electronic trading or was it a byproduct?

RN: It was a little of both. Our quant trader has been with us for two years and when he first arrived he had to sort out the data issues that exist in Europe and to clean things up. Once the data integrity was sorted out, we looked at different ways of employing quantitative analyses. Having somebody here who is constantly monitoring the execution outcomes means we can proceed down this path with real confidence. As a London firm, we were a little behind in our adoption of electronic trading, but now we are in the middle of the pack in terms of usage. It makes sense from a business and productivity perspective that there are many orders that do not need human oversight, which are best done in algorithms.

The third in its series of white papers looking at issues raised by the new market integrity legislation in Australia, Beauty and the Best - the perils an

Matteo Cassina of Citadel Execution Services Europe comments on the development of a European consolidated tape as well as a unified concept of best execution.

The long awaited proposals on the review of the Markets in Financial Instruments Directive (MiFID) were published in October 2011. The so-called MiFID II and MiFIR proposals aim to address, among other things, changes in the European market structure and competition between trading venues. Whilst the proposals, in their current form, do not provide as much detail as market participants had hoped, they represent a unique opportunity to address fundamental issues impacting the efficient functioning of Europe’s equity markets.

The EU legislative process is such that the European Parliament and the European Council will agree their negotiating positions, before embarking on a trialogue process mediated by the European Commission. The final legislative text may not be ready for implementation until as late as 2014, but this timeframe represents a good opportunity for the rules and their impact to be given adequate consideration. In particular, the issues of best execution and consolidated tape need to be given greater prominence during this review process, if policymakers are to honour the original objectives of MiFID, protect the retail investor and ensure Europe’s equity markets become efficient and competitive.

A key benefit of regulation is that it drives standardization of behaviour but thus far, this has not materialised (in the retail broker community in relation to best execution requirements). Large institutions have the capabilities to take advantage of the proliferation of alternative trading venues and are benefitting from cost reductions by being able to execute their orders in the venue which offers the lowest price for a security at a given time. The majority of retail investors, however, are still either unaware of, or do not have, the opportunity to access alternative trading venues. This means they do not always benefit from prices equal to, or better than, those available in primary venues.

While the principle of best execution is reiterated in MIFID II, it is not included in MIFIR which means that — once again — best execution is a principle, not a rule and therefore open to interpretation at the national level. This is in stark contrast to the best execution model in the US, where the requirements to achieve best execution are much more stringent. Currently, a retail broker in Europe can chose to route all of its trading to one single venue, on the basis that it has a good commercial relationship with that venue, or that it is too costly for the broker to connect to multiple venues. The broker may choose to send all orders to a venue with the highest chance of getting the best price, without necessarily guaranteeing that it is the best price at that moment in time. This is an unfair outcome for the retail investor and MiFID II/ MiFIR proposals, regrettably, do not go far enough to redress this.

Enforcing best execution will take time and will depend on broader market harmonization, but now is the time for regulators and retail investors to demand a more compelling definition of best execution. In particular, greater clarity is required around the execution policies provided by retail brokers to their clients. These policies are documents in which retail brokers explain how their best execution obligations are fulfilled under MiFID. Trading venues and brokers should also be required to provide execution quality statistics, detailing how well they performed in achieving best execution. This much needed clarity would, for example, result in firms having to justify — to both regulators and clients — why certain trading platforms are listed on their best execution policy and, why others have been omitted. In short, how and why some orders are routed to specific venues and not to those with the best price.

AllianceBernstein’s Global Head of Quantitative Trading, Dmitry Rakhlin, discusses the problem of fragmentation and what makes a good aggregator, along with Ned Phillips of Chi-East, Greg Lee of Deutsche Bank, Steve Grob of Fidessa and Instinet’s Glenn Lesko.


Dmitry Rakhlin, AllianceBernstein

How does aggregation improve trading and best execution?
Institutional traders usually demand (remove) liquidity from the markets, which in turn creates market impact. Being able to interact with aggregated liquidity (e.g. all available liquidity) lowers this market impact. Aggregated liquidity also gives a trader the ability to interact with many more liquidity sources randomizing the way the liquidity is taken from the market. This decreases the amount of information leakage and protects the trade from being exploited by predatory strategies.

Does aggregation spell the end of fragmented markets?
No. The US equity market is highly fragmented, yet all liquidity centers are interconnected, which allows traders to build various aggregator strategies. No doubt, there is cost and complexity associated with this. Fragmentation also introduces so called latency arbitrage and a potential increase in information leakage (the information leakage can be drastically reduced by using appropriate trading strategies).

The positive aspect of fragmentation is that it creates rich market microstructure (traditional exchanges and exchanges with inverted fee structures, block crossing networks, auctions, conditional order types, aggregators of retail liquidity, etc.). These choices give the buy-side the ability to match their investment strategies to the appropriate liquidity sources and ultimately benefit by being able to trade more nimbly and at lower cost.

From your perspective, is aggregation about greater access to liquidity or reducing trading costs?
Both.

Ned Philips, Chi-EastNed Philips, Chi-East

How does aggregation improve trading and best execution?

A good aggregator brings order to fragmented markets by concentrating order flows, and liquidity, from a large number of matching venues. It is a tool that allows all participants to access multiple venues from one easily accessible point, reducing the technology costs and other difficulties involved in monitoring different trading venues.

Does aggregation spell the end of fragmented markets?

No. Even if one good aggregator attracts a majority of trading flows, it would not represent a throw-back to a single exchange monopoly. Aggregators are there to make the process of using multiple markets easier and more efficient and can only exist as long as participants have a choice of matching venues.

What are the risks inherent in aggregation and how can an aggregator ensure improved execution?

Theoretically there is a risk that an aggregator will be so successful that it monopolises the market but competition and risk management would keep things in check.

An aggregator ensures improved execution by concentrating liquidity which reduces spreads and improves execution.