Barriers to Market Quality Barriers to Market Quality - The HFT Behaviors • The SEC breaks HFT behaviors down into four strategies1 – – – – • Market Making: like traditional market making, this strategy attempts to make money by providing liquidity on both sides of the book and earning the spread (along with rebates from posting) Arbitrage: trading when arbitrage opportunities arise (e.g. mispricing between Indices, ETFs or other instruments and underlying constituents) Structural: strategies seek to take advantage of any structural ‘vulnerabilities’ of the market or certain participants, and include latency arbitrage or quote stuffing Directional: these strategies attempt to get ahead of – or trigger – a price move, and include order anticipation and momentum ignition While market making and arbitrage “may be beneficial” to markets, they mask the negative impact of other HFT strategies2, typically qualified as Predatory HFT Strategies – – – – Quote Stuffing: the HFT trader sends huge numbers of orders and cancels Layering: multiple, large orders are placed passively with the goal of “pushing” the book away Order Book Fade: lightning-fast reactions to news and order book pressure lead to disappearing liquidity Momentum Ignition / Exploratory Trading: an HFT trader detects a large order targeting a percentage of volume, and front-runs it.3 4 1. 2. 3. 4. Concept Release on Equity Market Structure. SEC, 2010 Credit Suisse – AES Analysis, December 2012 Exploratory Trading – Adam D. Clark-Joseph, January 2013 Do HFTs anticipate buying and selling pressures – Nicholas Hirschey, December 2011 Barriers to Market Quality - Impact of HFT Behaviors • Predatory HFT Behaviors – – – – • “Beneficial” HFT Behaviors (or Opportunistic?) – • Increase intra-day volatility representing a tax on investors Impair price formation by exacerbating volatility Distort price discovery by manipulating true supply and causing market data issues Amplified by a herd-like behavior1 HFT market making is typically opportunistic and limited to large stocks (sparse in small and medium cap stocks), furthermore it declines on less active and less volatile days2 The combination of Predatory and Opportunistic HFT Behaviors leads to – – – Negative impact on the sustainability of Designated Market Makers (with obligations) who must participate in many undesirable trades and bear substantial inventory risks and capital costs Negative impact on liquidity of small and medium cap securities and securities in general on days of true market stress Larger volumes, resulting from over-intermediation, that lead marketplaces to support HFTs and further enable their strategies through fee strategies, co-location services, ultra lowspeed data feed, etc 1. A Dysfunctional Role of High Frequency Trading in Electronic Markets – Jarrow & Protter, March 2011 2. Should Exchanges impose Market Maker obligations – Anand & Venkataraman, November 2012 Barriers to Market Quality What is the Academic Research telling us about HFTs? • Research on HFTs’ impact on markets is prolific and can be characterized as follows: – – – • Lacks access to complete, reliable and granular data (the HOT Study being an exception) Biased conclusions (usually aligned with the interests of the sponsor/data provider)1 Uses decades old methodologies ill suited to fairly examining today’s market structure: • Periodic snapshots of prices fail to capture the full price path of today’s high velocity market • Use of mid-point pricing is a decades old technique used to compensate for market structure nuances (bid-ask bounce) in thinly traded markets • Cite volume and spread improvements while it is well known to practitioners that access to displayed liquidity is highly problematic and volume is driven by significant intermediation Analysis needs to be performed in a more granular way to identify what is truly happening in the markets2 1. 2. See Summary of Academic Papers in HOT Study Credit Suisse – AES Analysis, December 2012 Aequitas’ Safe Haven Preventing Predatory and Opportunistic HFT Strategies Predatory HFT Strategy • Aqeuitas Response Quote Stuffing • Description Flooding the market with orders and cancellations leading to a large number of new best bid / asks potentially lasting microsecond Objectives Walk someone in the book / leverage rebates Create false mid-points Cause stale prices & slow market data impacting others • Layering Quote Stuffing Segmentation, Matching Priorities and Fees Quote Stuffing only works when the party initiating it can subsequently trade under following conditions: counterparty is natural flow, speed advantage allows Top of Book position, rebates available Dark and Lux, where aggressive natural flow is expected to concentrate, negatively impacts these conditions: pegged orders, market maker and size priorities, no rebates but fees for resting orders • Layering Description Segmentation and Matching Priorities Placing numerous orders (buy / sell) at different price points Market makers and natural liquidity providers are to give an impression of strong buying / selling pressure or protected from aggressive HFT strategies by a speed bump to pre-position in support of other strategies in the Lux Book which will curtail signalling strategies on other venues Objectives Matching priorities in various Aequitas Books will curtail Drive price up/down to sell expensive / buy cheap and benefits of layering to pre-position orders trade out when the book reverts Fees Pre-position orders to take advantage of momentumignition strategy or rebates Rebate strategies are not enabled in Dark and Lux Aequitas’ Safe Haven Preventing Predatory and Opportunistic HFT Strategies Predatory HFT Strategy • Aqeuitas Response Book Fade • Description Volume disappearing on a specific venue or other venues after a trade on a specific venue Objectives Avoid and/or pass on (switching to active) adverse selection when not actually intending to trade at a certain price (often combined with layering strategy) Leverage latency arbitration amongst venues • Momentum Ignition Description Triggering other participants to trade quickly and cause a rapid price move Objectives Taking a profit after having taken a pre-position or by layering the book knowing the price is likely to revert and trading out afterwards Book Fade Segmentation and Matching Priorities Speed bump in Lux will make it more difficult for HFT firms to pass on adverse selection Matching priorities in various Aequitas Books will curtail benefits of layering to pre-position orders Smart Order Router Latency normalization across all venues • Momentum Ignition Segmentation and Matching Priorities Dark Book will not allow for such strategies Market makers and natural liquidity providers are protected from aggressive HFT strategies by a speed bump in the Lux Book which will curtail signaling strategies on other venues Matching priorities in various Aequitas Books will curtail benefits of layering to pre-position orders Aequitas’ Safe Haven Preventing Predatory and Opportunistic HFT Strategies Predatory HFT Strategy • Exploratory Trading Description Sending in small aggressive orders to obtain private information to forecast the price impact of predictable demand Objectives Trading ahead of predictable demand only when it is profitable to do so Opportunistic HFT Strategy • Market Making when it is profitable Aqeuitas Response • Exploratory Trading Segmentation True liquidity in Dark can not be tested Speed bump in Lux and high active fees will curtail these types of strategies Predatory HFT Strategy •Market Making when it is profitable Description Matching Priorities Provision of liquidity in large and liquid securities at the full Provide designated market makers with adequate discretion of the HFT impacting sustainability of true market compensation for their services by giving them execution makers priority Objectives Segmentation Generate earnings when profit opportunities are high and inventory risk is low while minimizing cost of capital Protect designated market makers from Predatory HFT Strategies with speed bump for aggressing flow in Lux