Buy-side Perspectives Issue 7 | Page 29

Equities well as BATS LIS which is due to launch in December and BATS Periodic Auction Book that launched in October 2015. Credit Suisse is a supporter of the Turquoise platform, and has its default smart order router turned on to interact with that platform, among others. “These initiatives can be seen as part of a move to prepare for the MiFID II world of 2018,” Cousens added. Best execution The concept of best execution is another area of focus for Credit Suisse. While best execution has been a familiar term ever since MiFID introduced an obligation on the sell-side to seek it in 2007, under MiFID II that commitment is being reinforced by a shift of the regulator’s attention to the buy side. In particular, buy-side best execution policies are being subjected to greater regulatory scrutiny. At K&KGC’s 14th London Equities Alpha Trader Forum in October, one senior buy-side trader reported a ‘fact-checking visit’ from the FCA, in which a representative of the UK’s financial regulator wanted to know in great detail about the firm’s best execution policy. In general, the regulator is demanding a more detailed, lengthy best execution policy which can explain trading decisions with a level of clarity greater than ever before. Cousens says that Credit Suisse does attempt to counter this factor by providing more for the buy side than previously in terms of data. Specifically, the firm uses its data to help advise the buy side on how to achieve performance enhancements. But perhaps the best silver lining may be provided by unbundling of payments for research and execution, which stands to benefit the smaller players as well as the larger ones. “Small buy-side firms can focus their execution on a few key providers with best execution and unbundling, concentrating on the areas where they stand to do better,” he said. “The more they concentrate, the more data it will generate for them. That data can then be used to improve their performance even further.” Another potential problem with best execution is the way regulators may choose to interpret best execution obligations. For example, does best execution simply refer to ‘best price’? In Europe, it is understood that the regulator is expecting more nuance and explanation of what the trader was