The TRADE 58 | Page 72

[ I N - D E P T H | S Y S T E M AT I C I N T E R N A L I S E R S ] logic in our routing process. When we are trading aggres- sively, we are only looking at where it is likely we will get the smallest amount of price impact, and we see quite big differences between the market maker destinations, which as mentioned we also com- pare with lit markets. A small element of price improvement from a market maker won’t be enough to tempt us, we really care about the impact that could manifest from that interaction on an ex-post basis. Jonathan Finney: I would emphasise Ben’s point there. Not all brokers are the same and not all market makers are the same, so we see very different types of evalu- ation and results. What Jefferies is doing in collating and analysing data and evolving behaviour based on the results of this analysis, represents one end of the SI evaluation spectrum. With regards to how this landscape has evolved over the past year, overall volume does not appear to have changed dramati- cally. However, the composition of liquidity sources certainly has changed. To that point, SIs are not the only alternative source of liquidity but they represent the single greatest opportunity for evaluating equity market makers. Given the bilateral nature of the SI, ironically this has achieved the transparency that MiFID II was aiming for. Matthew at Liontrust, via Ben at Jefferies, knows that he is trading with Citadel Securities and he can evaluate us on our merits. I think people have been surprised at how slow ELP SI growth has been but we are definitely seeing the buy- and sell-side becoming more comfortable interacting with market makers as they are able to access more data. I would point out that there are only four market makers currently reporting their monthly data to Rosenblatt Securities and TABB Group and having this data available supports the evaluation pro- cess. Market makers are very different. For example, Citadel Securities specialises in risk-warehousing po- sitions, larger quote sizes, benign market impact and a diverse security universe. Having a robust evaluation framework is important in assessing these factors. MM: On the issue of transparency, if we had decid- ed not to interact with SIs, then I would actually be trading with them on lit exchanges anyway, possibly at worse prices, smaller size and potentially with a larger market impact. That is up for debate, but when I inter- act bilaterally, I know exactly who I am trading against so that I can hold that venue to account. 72 // TheTrade // Winter 2018 HM: What have you found to be the most important factors when evaluating ELP SIs? MM: Firstly, I need to decide if their model makes fundamental sense and if it is adding liquidity that would be beneficial for me to interact with. I then look at price, size and market impact - those three factors are key. For the buy- side, I think market impact and size has become a lot more important this year. I’m not looking for a twentieth of a tick price improve- ment, I’d rather have larger size and lower market impact. It’s strange to say it as a trader who is addicted to getting the best price - but the best price is not always best execution for me. If I can get good liquidity and not impact the market, then I am usually a happy bunny. The importance of those two factors has definitely increased over the past couple of years for the buy side in my opinion. Fill rates are another factor to be aware of. I hear of SI fill rates between around 95-99%, but what happens when you don’t trade against them? That’s harder for the buy-side to monitor. One thing is for sure, with the proliferation of execution venues that we have ex-