Buy-side Perspectives Issue 10 | Page 31

Changing of the Guard In this new marketplace, the role of participants such as high-frequency traders and market making firms will change and their importance as intermediaries will become more apparent. These proprietary trading firms commit their own capital to supply liquidity using sophisticated algorithmic techniques, providing automated pricing in thousandths of a second, while also delivering semi-automated pricing on less-liquid instruments such as small-cap stocks and ETFs. Today some of these firms are authorised by the FCA as systematic internalisers (SIs), but in the future all OTC liquidity providers for equities will need to be authorised as such. For the more technologically advanced firms, this represents a real opportunity, but MiFID II also signals the end of the broker crossing network (BCN) regime, which has evolved in Europe and Asia largely as a result of the absence of regulation around trading venues. The relative lack of regulation has meant that application of best execution rules has sometimes been opaque, and while BCNs have tried to distinguish themselves based on the access to liquidity and protection against ‘toxicity’, the differentiation between many venues has been unclear. In the future, a multilateral trading venue must be authorised as an ATS in the US, a PTS in Japan, a multilateral trading facility (MTF) or an organised trading facility (OTF) in Europe—creating a more transparent model and making it easier to measure toxicity and opportunity cost. SYSTEMATIC INTERNALISERS (SI) VERSUS THE BROKER CROSSING NETWORK (BCN). Potential Advantages Potential Disadvantages • Unlike a BCN, an SI will offer pre-trade transparency • Information is provided to the SI • Tailored liquidity—less toxic business means better quotes • Orders are no longer multilateral, so clients cannot cross directly • No incentives—an SI cannot rebate for trading, otherwise it would be subjected to payment for order flow constraints • No benefit to resting orders against an SI (Principal Trading book) • Transparency of counterparty —you don’t know who you are trading with in a BCN • Sls have the ability to ‘last-look’ —can choose whether to fill an order or not • Expectation SIs will offer multiple quotes in price and size • Sls are not obliged to trade • Quotes above SMS are private 4 Autumn 2017 THE IMPACTS OF A NEW LIQUIDITY PARADIGM www.buysideintel.com 31