The TRADE 53 | Page 94

[ F I N A L T H O U G H T S | H AY L E Y M C D O W E L L ] Hayley’s Comment *Formerly the Hayley Mail Systematic Internaliser confusion rumbles on Consequences of SI regime remain a huge concern for the industry with tech and liquidity worries at the forefront. I t was in February at The TRADE’S MiFID II event in London the controversy surround- ing systematic internalisers (SIs) first came to light. Speaking to an audience of hundreds of buy-side traders and market participants, Kay Swinburne MEP, told dele- gates the European Commission were indeed aware of plans to network SIs under the new regime in order to operate as broker crossing networks, which will be banned as of 3 January next year. Fast-forward several months and following several exchanges between the European Commis- sion and the European Securities and Markets Authority, regulatory texts have been amended to shut down any potential trading loop- hole. So now it’s official, banks operating as SIs will not be able to recreate broker crossing networks 94 TheTrade Autumn 2017 through matching client orders as an exchange operator would. Despite this, rather than eliminat- ing concerns around the regime, market participants have started to question its impact. Predictions on the number of reg- istered SIs once MiFID II comes into effect have topped 100, with some investment banks opting to register multiple SI platforms for different desks offering liquidity across asset classes. TABB Group predicted in equity products alone there will likely be upwards of 20 SIs operating before the MiFID II deadline. With this in mind, market participants are tasked with interacting with as many of the SIs in operation as possible, but many buy-side firms continue to use leg- acy systems. Without aggregation technologies, it will be a struggle for firms to interact with all SIs. Interestingly, experts general- ly agree order flow from broker crossing networks will not shift to SIs following MiFID II imple- mentation. Once broker cross- ing networks are banned it will leave a big hole in liquidity, and it remains unclear how much of that flow will go to lit order books, SIs or other venues. What is clear though, is that there will be a large amount of liquidity fragmented across multiple venues. The full effects of the regime will remain unknown until 3 January, but the potential consequences of it remain a huge concern for the industry. Personally, I thought once the potential loophole had been shut down the drama and controversy surrounding the SI re- gime would die down significantly. But, as it seems with all things MiFID II, the drama continues.