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Equities trading focus | Market structure | James Hilton


automated, it has introduced further competition into the execution space. Automated crossing networks are now operated by brokers, MTFs, and the exchanges themselves, allowing traders to cross stock without displaying their size. Our studies indicate that


trading in this manner has a clear, positive impact for the end investor. For orders using time- and volume-based tactics, those that were exposed to the dark performed a full 3.3bps better when measured against IS and 0.8bps better versus VWAP. Some detractors have argued this practice is damaging to market quality and should at least be restricted to the largest orders only; but, in our studies we have found that there is no evidence that higher levels of crossing activity adversely affect the market. In fact, we found evidence of a positive impact on several measures of market quality, including spreads and autocorrelation. We also showed that posting visible quotes


2.5 2.0 1.5 1.0 0.5


for even small orders causes market impact, undermining any argument for a minimum size restriction.


Clear and measurable benefits With the knock-on effects of changes to the market’s structure coming into focus, it stands to reason that the regulatory framework will need to adapt. Many common-sense reforms have been put forward or are underway. However, other proposals seem designed to roll back new forms of execution in order to reduce the competitive pressure on established business interests. The lobbying efforts of the exchanges clearly reflect this anti-competitive sentiment. They have strongly pushed for minimum trade sizes and caps for crossing networks. The research papers they fund to bolster their position employ questionable methodology, such as declaring that on-exchange crossing networks are “lit”, while off-exchange crossing networks are “dark”, or conflating macro


Fig 1: Credit Suisse transaction cost index B


A C D A


B C D


2007 2008 2009 2010 2011 2012 2013 Source: Credit Suisse Trading Strategy, Jan 2007 – May 2013


Best Execution | Summer 2013


Composite cost index Transaction cost index


J.P. Morgan acquires Bear Stearns


Global financial crisis Greece debt crisis Euro crisis


trends in volatility with market structure changes when it proves convenient. They argue that the above-mentioned restrictions would improve market quality, but the only obvious effects would be to force volume back to the old regimes, restore market concentration and transfer money directly from pension funds to the bottom line of exchange profits through increased investor costs. The market by and large knows this. For example, Pensions Europe – an association of funds representing the workplace pensions of 83 million Europeans – put it succinctly when they noted that these and other proposals: “offer trading venues the opportunity to take undue commercial advantage from pension funds’ investment activities…affecting the returns on investments and, ultimately, the contributions paid to workplace pension beneficiaries.” The European markets


have undergone an enormous transition since 2007. MTFs have driven down exchange fees and crossing networks have enabled investors to trade without distorting the market. While entrenched interests have painted these developments negatively – warning of deteriorating market quality with subjective or questionable claims – the net result of increasing competition is clear and measurable: a significant reduction in costs, with the benefits going to the end investor. It would be a shame to roll that back. n


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