AIMA Dublin The Impact of MiFID on the content, costs and uses of market data 24 October 2007 “The essential guide to screwing up your business” Jeff Randall • Keep reminding your customers how lucky they are. • Stick to a proven formula. Assume infallibility. • Don’t meet your customers • Believe your own story. Isolate yourself. • Never take any time out to think • Indulge in continuous use of blackberries and mobile phones • Fall in love with administration and bureaucracy • Be afraid of the future. It’s uncomfortable and will show the world how little you know 2 MiFID & Reuters Response Key issues – exchange traded markets • The proportion of volume traded electronically will continue to grow rapidly • Regulatory change will be a key driver of client investment and opportunity in ‘08 and ‘09 • Efficiency and risk management will drive even greater adoption of STP, • Algorithmic trading has created new trading opportunities, resulting in volume growth that will outstrip headcount growth • Banks and brokers will seek to monetize more aggressively their OTC prices and data • Growth in the volume of market data will mean that it will no longer be possible to broadcast everything IDN growth 3 month trended traffic rates since 1987. 100000 90000 Updates per Second 80000 70000 60000 50000 40000 30000 3 month trend (updates per second) 20000 10000 0 Jan 1987 Jan 1988 Jan 1989 Jan 1990 Jan 1991 Jan 1992 Jan 1993 Jan 1994 Jan 1995 Jan 1996 Jan 1997 Jan 1998 Jan 1999 Jan 2000 Jan 2001 Jan 2002 Jan 2003 Jan 2004 Jan 2005 Jan 2006 01 May 1987 - 28 Jun 2006 3 MiFID & Reuters Response September 2006 – Peak at New York Open Reuters receiving 61,000 messages per second 4 MiFID & Reuters Response September 2007 – Peak at New York open Reuters receiving 132,400 messages per second 5 MiFID & Reuters Response Exchanges were “institutions” 6 MiFID & Reuters Response Old Markets Learn New Tricks - Profits 7 MiFID & Reuters Response MiFID 8 MiFID & Reuters Response Markets in Financial Instruments Directive Increase market efficiency through increased transparency and competition MiFID Objectives MiFID Objectives Provide protection for the retail investor 9 MiFID & Reuters Response A common regulatory framework across Europe Markets in Financial Instruments Directive 01 Apr 2004 01 Jul 2004 01 Oct 2004 01 Jan 2005 01 Apr 2005 01 Jul 2005 01 Oct 2005 01 Jan 2006 01 Apr 2006 01 Jul 2006 01 Oct 2006 01 Jan 2007 01 Apr 2007 01 Jul 2007 01 Oct 01 Nov 2007 2007 MiFID Level 1 passed by European Parliament Extended Consultation on implementation measures MiFID Level 2 Implementation measures finalised and published by the Commission Deadline for Transposition of MiFID into local law 9 months allowed for implementation Deadline for MiFID implementation Most MiFID obligations apply to all financial instruments: Data retention and transaction reporting, Client Classification, Conduct of Business rules, Best Execution within Investment Firms, Distribution of research and advice, Client order handling rules, 10 MiFID & Reuters Response 7 days to go. Status of Transposition As at 1st October out of 27 states: • 15 states had notified the European Commission that they have transposed Level 1, • 13 states had notified the European Commission that they have transposed Level 2. The following states had not notified transposition of Level 1 or 2: •Czech Republic •Estonia •Finland •Hungary •Italy •Netherlands •Poland •Portugal •Slovenia •Spain • • • Greece having notified of transposition of Level 1 but not Level 2. Cyprus having notified of only partial transposition of Level 1. Latvia having notified of only partial transposition of Level 1 & 2. 11 MiFID & Reuters Response Fragmentation and Consolidation • MiFID Transparency obligations will result in fragmentation of equities trade data • Price fragmentation may occur but not initially • Professionals will need consolidated pricing & trade data for each stock • Will “Dark pools of liquidity” increase the importance of post trade data? • Access to complete market data will be more expensive • Reuters will be a publication venue for trades and prices, but not an MTF LSE Deutsche Bourse Euronext Paris .L .PA .DE Reuters Consolidated View based on all venues 12 MiFID & Reuters Response OMX Stockholm .ST .M BOAT New Data feeds • • • Venue Fee in Euros Delayed data Comment LSE 5.17 FOC after 15mins The OTC trade reports will automatically be available in the LSE Domestic or International product. The LSE OTC trade report service will carry both UK and European OTC trade reports and will become feeliable (GBP3.50 in April 2008) Euronext 7 FOC after 15mins Initially free, becomes feeliable 01-Jan-2008 Deutsche Boerse 8 FOC after 15mins Initially free, becomes feeliable 01-Feb-2008. There is also a EUR3 per user bpm fee for snapshot data, and an EUR1 user per user pm fee for non-pros OMX N/A FOC after 15mins Free for at least 6 months, at which point the commercials will be reviewed Wiener Börse 10 FOC after 15mins Data will be free until 01-Jan-2008 Irish Stock Exchange N/A FOC after 15mins MiFID data will be added to the existing Irish SE Level 1 service BOAT will charge €120 per person per month with free access to 2hour delayed data Chi-X, Plus Markets & Xontro data will be accessible free of charge Borsa Italia, Vienna Stock Exchange, Bratislava SE have yet to announce charges 13 MiFID & Reuters Response Reuters as a publication venue “.r” RIC for all publication to a Reuters venue Reuters Trade Publication: • Leverages the technology behind Reuters Trade Notification Service • Compliance with FSA’s Trade Data Monitor functions and MiFID Level 2 transparency obligations • Publication via a FIX enabled API, or via a GUI • Minimal cost for publication 14 MiFID & Reuters Response Consolidation From 1st November the “.x” RIC will provide on existing Reuters desktops: • Initially in 1,200 of the most liquid European stocks • Will expand to cover all stocks defined by CESR as eligible • Best bid/offer from multiple venues & all trades as they happen • Separate display of all recent trades • Access cost dependant on the cost of contributing feeds. Day one coverage will cover 13 venues including LSE, Euronext, Deutsche Bourse, OMX, Virt-x, Chi-X, Boat & Reuters. 15 MiFID & Reuters Response Best Execution 16 MiFID & Reuters Response Best Execution • Applies across all asset classes, although application to dealer markets not as clear as for equities. • Take into account factors other than price (latency, likelihood of execution, settlement costs…..) • Firms to establish an execution policy, • Evidence compliance with that policy, • Validate that policy at least annually. Beyond Equities “whether the client legitimately relies on the firm to protect his or her interests in relation to the pricing and other elements of the transaction…” Commission Working Document – ESC-07-2007 Status of portfolio managers? 17 MiFID & Reuters Response Best Execution – RDTH In all asset classes, Reuters also offers Reuters DataScope Tick History (RDTH) for compliance and regulatory requirements • RDTH will allow firms to retrieve all underlying tick by tick data to: • Determine and establish best execution venues. • Maintain compliance on a daily post trade basis • Prove compliance up to 5 years after the trade should regulatory agency probes come into effect • RDTH will allow firms to validate the quality of execution provided by the venues within their policy by: • Comparing the tradable market of the venue chosen versus what could have been achieved across all other venues. • RDTH will also store the .x RIC composite for future comparison The focus of RDTH is to provide firms access to all underlying tick by tick data across all asset classes on a global basis to assist compliance officers with daily comparative market level intelligence by venue to achieve regulatory compliance. 18 MiFID & Reuters Response Best Execution – RTCA In Equities Reuters will offer Reuters Transaction Cost Analysis (RTCA) • RTCA will allow firms to evidence compliance with their execution policy by: • reference to benchmarks calculated using the price & trade data from the execution venues identified in that execution policy. • this will be facilitated by choosing the relevant RIC identifiers in RTCA for the price & trade data from those venues. • RTCA will allow firms validate the quality of execution provided by the venues within their policy by • comparison of the execution quality of the venues chosen versus what could have been achieved across all venues. • this will be facilitated by comparison against benchmarks calculated using the composite ".x" RIC. Although the initial focus for RTCA is on Equities coverage of other asset classes would be possible if comparative trade and pricing data were to be made available. 19 MiFID & Reuters Response Reuters Transaction Cost Analysis Hosted Infrastructure RTCA Server & Database TCA Report Client Download pdf Report via Web 5 End of Day Prices, Raw Trades Data & Benchmarks 2 1 Web & FTP Servers We b or S e cu re F TP U plo ad Reuters Tick History • Historical hosted Transaction Cost Analysis Service • Broad range of Benchmarks • Historical Trade and Order Analytics • Scenario Analytics 20 MiFID & Reuters Response TCA Report 4 3 Order & Trade Data Standardised Trade Report Reuters Transaction Cost Analysis – Summary and Drill Down Reports • Summary Cost analysis • Segmentation Analysis provides • Drill Down to carry out analysis • Trader Performance • Volume Consumption • Fill Analysis • Individual trades and orders 21 MiFID & Reuters Response 22 MiFID & Reuters Response