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[ I N T E R V I E W | J A M E S B A U G H ] [ I N T E R V I E W What have been the positive chang- es brought about by regulatory change? JB: One of the key objectives of reg- ulatory change was to encourage greater transparency and there has been a benefit from the new re- 60 // TheTrade // Summer 2019 J A M E S B A U G H ] “The concern is that the market has become more fragmented and complex, and invariably, with that costs increase, which is always going to be an issue.” receive, you have to look at a quant fund very differently versus an institutional client, in terms of the types of liquidity they want to in- teract with and how we make sure that we are providing access to that type of liquidity. This will season and develop over time, and that's where coming together with your underlying clients and understand- ing their needs is very important. This isn't a one-size-fits-all oppor- tunity and will be a slower burn, in terms of how banks and SIs, like Citi, will look to differentiate over time. How will the role of the broker develop in future as the market structure continues to evolve? JB: Given the increasing complex- ity, the role of the broker will be- come more relevant and important in helping the buyside to source liquidity. We are very proactive in terms of how we are looking to develop our business and allo- cate resources to take advantage of structural changes as a way to differentiate ourselves in a market that has become fairly commodi- tised. What needs to play out is that consolidation of liquidity; it is something that is well-discussed, but actually we haven't neces- sarily seen some of those brokers as negatively impacted as some might have you believe. But we are definitely seeing a consolidation of flow driven by the underlying client being able to declutter and manage what is a very different set of regulatory obligations. | porting regime and that has been useful in driving some conver- sations in other products, like exchange traded funds (ETFs). The other key positive develop- ment here is the buy-side and sell- side coming together, the buy-side becoming much more focused on broker performance and meeting their best execution obligations. That is encouraging the sell-side to sharpen their focus and make sure they are providing best outcomes, access to unique liquidity and that they are able to work together on optimising trading performance. That can only be to the benefit of the end investor.  On the buy-side the unbundling of research and execution pay- ments has been positive in terms of allowing the heads of dealing on the buy-side desk to concentrate more on best execution, rather than having to cut cheques. There are, however, still many challenges left. The concern is that the market has become more fragmented and complex, and invariably, with that costs increase, which is always going to be an issue when trying to provide an efficient service to the end investor. I sometimes think that gets over- looked by the regulator. How do you view any further reg- ulatory change or amendments to MiFID II playing out? JB: We don’t anticipate a massive sea change in the near future, but there are some fairly significant developments that we may see and have to be ready for. One is the impact of the public tick regime on both lit venues, more specifically periodic auctions, and on SIs. As we understand it, towards the end of this year or early next year, SIs are going to have to adhere to the public tick regime in all sizes, which means SIs will be signifi- cantly limited in their ability to price improve unless that busi- ness is above large-in-scale LIS, Similarly, if you are no longer able to match mid-price in periodic auctions, and given the majority of business is done below LIS using peg-to-mid-order-types, we have to start thinking about the impact this might have on the liquidity landscape and how to get that type of business executed. The frustration for the market is that this is not just focusing on mid-price or price improvement per se, this is more about being able to match intra-tick where there are an odd number of ticks in the spread, so you can still match at mid-price but only if there is an even number in the spread. It does seem a little bit nonsensical trying to implement these sorts of changes that could have a fairly significant impact in being able to trade at fair value. Thinking about the SIs, we think the LPs may suffer if they are not able to offer price improvement unless they evolve their models. For bank SIs it is slightly different because price improvement itself is not the determining factor in terms of how we get business done, but it is going to lead to certain changes to the liquidity dynamics that we need to cater for. That is something we need to think about in the rela- tively near term. The other area of interest is around the market-on-close business, where we have seen liquidity very much concentrated on the close. The numbers will tell you that some of the more liquid names, not just on LSE but on oth- er primary markets, see 30%-35% of the daily volume traded on the close. We are now engaged with a number of alternative platforms which are looking at ways in which they can provide solutions or ways to get that market-on- close business done away from the primary. Again, this could see some structural changes in the relatively short term. However, as an indus- try we need to be thoughtful about how we approach this, because what you invariably end up doing here is diluting the actual reference price itself. It’s also worth noting that a number of institutions are also looking at benchmarking away from the close which in in itself is an interesting move and one to watch. Issue 60 // TheTradeNews.com // 61