The TRADE 60 | Page 57

[ I N T E R V I E W | J A M E S B A U G H ] James Baugh, head of EMEA equities market structure at Citigroup, talks to The TRADE about the impact MiFID II has had on European market structures, the changing relationship between the buy- and sell-sides, and what further regulatory changes may be in store. What is your view on the way in which market structures have changed since the introduction of MiFID II? James Baugh: MiFID II has been fairly broad in terms of its impact on the European equity markets despite the sell-side already having to manage for MiFID I, especially when you consider some of the obligations that are now bestowed upon the buy-side, such as unbun- dling, meeting transparency and best execution requirements. In regards to execution, the wider market impact has been on the liquidity landscape which has seen further fragmentation, adding additional complexity to the workflow. This isn’t just about connecting to every new liquid- ity destination but more about understanding the impact on the parent block when interacting with certain types of flow and also in knowing the client’s benchmark to know how best to work that business in what is a very different liquidity environment. Here we look at two things. One is in regards to what we would describe as liquidity sourcing, understanding where we access liquidity to find best outcomes for our clients. The way in which that has evolved has really been more to do with how we outsource liquidi- ty, that perhaps firms like ourselves matched using broker crossing networks pre-MiFID II. Now that we can no longer systematically match client-to-client business, we have to think about how we get that business done. There are three sub-themes that we consider and those include the rise of periodic auctions, the growth in liquidity providers - those market makers that are registered as systematic internalisers (SIs) - and also the continued growth in electronic block trading and the wider use of conditional orders. The other aspect that we look at is liquidity provisioning: how to provide clients with efficient ac- cess to our house inventory while facilitating access to our systematic internaliser as a way to optimise the amount of business we can in- ternalise to manage market impact and execution costs, albeit client- to-house, rather than client-to-cli- ent, as it was pre-MiFID II. What we are also starting to see is a consolidation of flow to fewer, larger brokers and that has been driven, in part, by some of those obligations on the buy-side, mean- ing that they need to simplify their own workflows so that they can better monitor and manage best execution. a couple of percentage points in terms of the overall share of mar- ket. It's likely that the trend will continue, however, the question is how far can it go? If we think about what is a relatively fluid regulatory environment right now, it's difficult to think too far ahead as to what might or might not happen. But if we take the liquidity providers (LPs) and the market makers, it's worth also appreciat- ing that these firms were already price makers in broker crossing networks (BCN) pre-MiFID II and therefore what we are seeing here is a reverse of that flow, perhaps in a much more positive way where the buy-side has greater transpar- ency of who they are interacting with.  So, when we talk about the rapid rise of the LP SIs, I would caution against some of the regulatory scrutiny, knowing that pre-MIFID II these firms were already doing a significant amount of business within the BCNs. How do you view the emergence of new trading venues, such as periodic auctions and systematic internalisers (SIs)? How will that pan out in future? JB: First and foremost, we have to appreciate that the channel shift in liquidity has been relatively muted so far; we are only talking about Have there been any unexpected developments or changes to market structure since the introduction of MiFID II? JB: There has been a lot of discus- sion around some of the unin- tended consequences of MiFID II, particularly considering that the key regulatory objective was “We have to appreciate that the channel shift in liquidity has been relatively muted so far; we are only talking about a couple of percentage points in terms of the overall share of market.” Issue 60 // TheTradeNews.com // 57