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“In my world,
                  ‘global’ means a broker that’s as comfortable
                           in Boston as in Beijing and Barcelona.”

                  UBS is an equities trading partner for your world.


                  As a top equities trader in the US and around the world,* UBS provides a consistently first-rate experience
                  whether you’re trading domestically or abroad. And with on-the-ground specialists and advanced tools
                  customized for over 130 local markets, we can serve you in whatever way you choose —through a single point
                  person or a team of experts.


                  We understand the world. Your world.



                  For more information, please contact us at www.ubs.com/yourworld




      *Source: AutEx 2008. In the U.S., securities underwriting, trading and brokerage activities and M&A advisor activities are provided by UBS Securities LLC, a registered broker-dealer that is a wholly owned subsidiary
      of UBS AG, a member of The New York Stock Exchange and other principal exchanges, and a member of SIPC. © UBS 2010. All rights reserved.




UBS ad.indd 1                                                                                                                                                                                                         9/9/10 2:23 PM
Elec&Algo Report_2010.qxp                                9/10/10               9:59 AM                 Page 3




          ELECTRONIC & ALGO TRADING REPORT                                                                                                                         WALL STREET LETTER SEPTEMBER 2010




                                                                                                                                        EDITOR’S NOTE
                                     www.emii.com                                                                                       Thank you for picking up a copy of Institutional Investor News’
                                                                                                                                        second annual Electronic & Algo Trading Report. The report,
                              EDITORIAL             PUBLISHING
                          STEVE MURRAY              ALLISON ADAMS                                                                       written by the editorial staff of Wall Street Letter, aims to bring you
                                  Editor            Group Publisher                                                                     the latest on this year’s hot topics as well as those key areas that are
                            TOM LAMONT              GAURI GOYAL
                             General Editor         Business Director (212) 224-3504
                                                                                                                                        just as important but not getting as much play.
                   VERONICA BELITSKI                ISMAELA BEST
       Executive Editor (212) 224-3297              Senior Marketing Manager (212) 224-3609                                            Two years removed from Sept. 15, 2008, the financial markets have
              JEANENE TIMBERLAKE                    LAURA PAGLIARO                                              withstood much berating from Congress, scrutiny from financial regulators and skepticism
      Managing Editor (212) 224-3638                Marketing Manager (212) 224-3896
                                                                                                                from the investing public. The world of electronic trading has also been through the
                    MEREDITH LEPORE                 VINCENT YESENOSKY
        Senior Reporter (212) 224-3318              Head of US Fulfillment                                      wringer, with executives facing questions from the Securities and Exchange Commission
                    CORRIE DRIEBUSCH                DAVID SILVA                                                 and the Commodity Futures Trading Commission on issues such as high-frequency
                Reporter (212) 224-3268             Senior Fulfillment Manager
                                                                                                                trading, predatory algorithms, flash trading, co-location, trade reporting and tracking, dark
                          PRODUCTION                REPRINTS                                                    pools, sponsored access, and more.
                               DANY PEÑA            DEWEY PALMIERI
                                  Director          Reprints & Premission Manager
                                                    (212) 224-3675
                                                                                                                This hasn’t slowed the industry at all. Case in point: algorithms are being used now more
                        COVER DESIGN                dpalmieri@iinvestor.net                                     than ever, even as regulators question their use by high-frequency traders.
                  SAMANTHA RALPH
                                                    CORPORATE
   Advertising & Marketing Coordinator                                                                          The buyside has always played a key part of the trading process but hasn’t always been the
                                                    GARY MUELLER
                          ADVERTISING               Chairman & CEO                                              squeakiest of wheels. Now, however, traders are starting to speak up as regulatory concerns
                       ADRIENNE BILLS               STEVE KURTZ                                                 pervade more of the buy-side firms’ business. We tapped several head traders to get their
    Associate Publisher (212) 224-3214              Chief Operating Officer
                                                                                                                perspectives on what concerns the buyside in a roundtable (page 16) that covers a host of
                         PAT BERTUCCI
    Associate Publisher (212) 224-3890                                                                          these issues.

    Customer Service: PO Box 5016, Brentwood, TN 37024-5016                                                     Of course, we couldn’t address the industry’s concerns without taking a look at the over-
    Tel: 1-800-715-9195 • Fax: 1-615-377-0525 • UK: 44 20 7779 8704
    Hong Kong: 852 2842 6910• E-mail: customerservice@iinews.com                                                the-counter derivatives market, which is facing an automated, electronic world for trading
    Editorial Offices: 225 Park Avenue South, New York, NY 10003.                                               and clearing that is just over the horizon. Regulators are still sussing out the best way to
    Tel: 1-212-224-3297 • Email: vbelitski@iinews.com                                                           regulate the industry, but that doesn’t mean the industry’s sitting on its hands. We’ve got
    Institutional Investor Hotline:
    (212) 224-3570 and (1-800) 437-9997 or hotline@institutionalinvestor.com
                                                                                                                the details on BNY Mellon Clearing’s plans to approach this market head on and talked at
    A Publication of Institutional Investor, Inc.
                                                                                                                length about how the firm thinks the clearing structure should be set up.
    © Copyright 2010. Institutional Investor, Inc. All rights reserved. New York Publishing offices:
    225 Park Avenue South, New York, NY 10003 • 212-224-3800 • www.iinews.com                                   It was no small feat determining what should be addressed. That being said, we hope you
    Copyright notice. No part of this publication may be copied, photocopied or duplicated in any               enjoy this year’s report. Feel free to contact any of us with feedback, questions or concerns.
    form or by any means without Institutional Investor’s prior written consent. Copying of this
    publication is in violation of the Federal Copyright Law (17 USC 101 et seq.). Violators may be
    subject to criminal penalties as well as liability for substantial monetary damages, including              Regards,
    statutory damages up to $100,000 per infringement, costs and attorney’s fees.

    The information contained herein is accurate to the best of the publisher’s knowledge;
    however, the publisher can accept no responsibility for the accuracy or completeness of such
    information or for loss or damage caused by any use thereof.
                                                                                                                Jeanene Timberlake
           From the publishers of:                                                                              Managing Editor
                                                                                                                jtimberlake@iinews.com

       TABLE OF CONTENTS
          NEXT-GEN EQUITY                                       CLEARING THE PATH:                               MULTI-ASSET CLASS ALGOS             THE FUTURE OF ANTI-                          BUYSIDE WORRIES FOCUSED
          ALGORITHMS TAKE HOLD                                  PREPARING FOR THE NEW                            EYE BIGGER STAGE                    GAMING : WHERE ARE WE                        ON REGULATION REFORM
          By Meredith Lepore                                    OTC DERIVATIVES REGIME                           By Corrie Driebusch                 GOING?                                       By Corrie Driebusch and
          Buy-side firms are looking for                        By Jeanene Timberlake                            Multi-asset class trading           By Jeanene Timberlake                        Meredith Lepore
          more sophisticated trading                            BNY Mellon Clearing’s                            strategies were expected to         Anti-gaming technology has                   Buy-side executives talk
          tools, and the sellside is                            Sanjay Kannambadi talks                          flourish into a big business,       become more sophisticated                    about the impact of
          stepping up to provide the                            about how his firm is                            but the electronic version of       as gaming strategies have                    regulation on their
          answer. Sell-side trading                             handling the uncertainty in                      the strategy is still catching      advanced. Dark pool                          businesses, plus their
          execs talk about the future of                        the OTC derivatives market.                      on. Sell-side executives spoke      operators and dark liquidity                 technology needs and what
          algo trading.                                                                                          about the requests they’re          aggregators discuss current                  they want most.
                                                                                                                 fielding in that arena.             and future solutions to the




                    4                                                        8                                      12 14 16
                                                                                                                                                     growing problem.




                                       ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
                                                                                                                                                                                                                              3
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         SEPTEMBER 2010 WALL STREET LETTER                                                                                                              ELECTRONIC & ALGO TRADING REPORT




         Next-Gen Equity Algorithms Take Hold
         By Meredith Lepore




              As the buyside becomes more advanced in its use of sophisticated
              trading tools, the sellside is speedily developing algos that are equipped
              with superior logic and liquidity seeking abilities, statistical ranking
              models and the ability to trade in international markets with limited
              market impact. Market participants on both sides stress that coming
              algos have to be prepared to execute successfully in more volatile
              markets, adhere to real-time transparency and reporting demands and
              work in countries with very diverse market infrastructures. According to
              an analyst, spending on advanced algorithmic trading technology will
              reach more than $1.3 billion in the next year.


         ADVANCED LOGIC                                                                                         example of this would be Deutsche Bank’s new algo, Super X,
         Algos will need to be equipped with the logic and liquidity seeking                                    which uses a statistical ranking model that analyzes the execution
         abilities to perform successfully in different kinds of multi-lateral                                  characteristics of each venue. In searching for the best place to
                                  trading facilities, which are seen as the                                     trade an order, it takes the traders’ constraints and stock
                                  main contributors to market                                                   information leakage into account. Kang said Citi’s algos are
                                  fragmentation. “We are dealing with algos                                     prepared to handle difficult volatility and can halt a trade if there
                                  trading in 30 dark pools and up to eight                                      is market movement outside of the
                                  exchanges. As a provider, you have to deal                                    expected range. Algos must also be able to
                                  with a marketplace that has trading venues                                    learn from past experience by factoring
          Hitesh                  with different qualities,” said Hitesh Mittal,                                transaction cost analysis into their strategy.
          Mittal                  head of liquidity management for ITG.                                            Minimizing the time between detection
         “Each venue behaves differently, so the algo does as well,” said                                       of events, ranging from news events,
         Young Kang, global head of algorithmic products at Citigroup. To                                       market data or a quote request, and the                           Young
                                                                                                                                                                                   Kang
         meet that goal, the programs will start to include more granular                                       actual placement of an order is essential.
         market data, such as a news feed from Dow Jones, said the                                              “Algos are now fully dynamic systems, using complex
         directors.                                                                                             mathematical models to drive both macro level decisions of
             Collecting more data for algos so they are equipped with                                           speed and urgency but also the micro level order placement. The
         statistical ranking models in their logic is a step that many firms                                    sophistication of these models will continue to adapt and evolve
         are working on to help change trading behavior on the fly. An                                          based on client demand and market structure change,” said

     4
                         ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
ICAP ad    9/9/10    2:34 PM    Page 1




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      Foreign exchange (FX) is the                        equities market ‘flash crash’. In highly                   side by enabling hedge funds and
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      on the electronic EBS platform on                       EBS was the first interbank                            versus bank-owned), and must
      May 6, 2010, the day of the US                      platform to permit access to the buy-                      address a number of technology and
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                                                                                                                                     presents, rigorous
           The day of the US equities ‘flash crash’ (May 6, 2010) traders using the EBS platform traded record
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          benefits of EBS and EBS Prime to hedge funds, CTAs, FCMs and proprietary trading firms who seek access to EBS’ unparalleled
          wholesale market liquidity.                                                                email: daniel.torrey@us.icap.com
Elec&Algo Report_2010.qxp       9/10/10    10:00 AM     Page 6




      SEPTEMBER 2010 WALL STREET LETTER                                                                   ELECTRONIC & ALGO TRADING REPORT




                               Owain Self, global head of algorithmic           and reviewed for compliance purposes.
                               trading at UBS.
                                                                                ALGOS IN INTERNATIONAL MARKETS
                               TRANSPARENCY                                     Algos that can be deployed in international markets, especially
                                 Next-generation algos will also need to        emerging markets, are the next frontier. The sellside is working on
                                 provide more transparency in these             building algos that are as similar as can be to the algos the traders
                                 volatile and highly regulated times.           have become used to but that also account for international
       Owain Self
                                 Calculating risk exposure will be on the to-   market nuances and risks. Traders are more willing to invest in
      do list for the next generation and real-time algos can provide           foreign markets if they are able to use the same methods they are
      visibility into an algo’s potential exposure and determine a trade’s      currently using for their portfolios, said Dan Pagano, v.p. of
      risk impact. Risk assessment will be especially critical with cross-      strategic alliances at Linedata.
      asset trades that have multiple legs in a single order and are done           ITG recently made its algo suite available in Israel, and both Citi
      in real-time. If the trade is being exposed too much, the algo can        and ITG will be launching algos in Brazil for the first time soon. UBS,
      be adjusted before the order is executed. “Clients need to see            Bank of America Merrill Lynch, Jefferies, Nomura and Deutsche
      slippage of orders in real time and where the orders are being            Bank have also started extending their algo suites for emerging
      executed,” said Kang. Citi is planning a roll out of its new service,     markets such as Japan, China, India, Greece, Australia, Canada,
      Citi Trade Viewer, which will help clients achieve these goals. The       Eastern Europe and Latin America. “It’s important to note that we
      desktop trading application, to be launched this fall, enables            are operating in an environment of rapid market structure change.
      traders to see every detail of an order in real time using visual         This is a global phenomenon, as regulators across the Americas,
      analysis.                                                                 Europe and Asia-Pacific are grappling with ways to evolve their rules
          ITG has increased their consultations with clients in the last few    and surveillance apace with the global markets and advanced
      years so clients really understand how the algo functions and             technology,” said Self. This requires the architecture of an
      what is the best way to use it, Mittal said. Transparency will also       algorithmic trading platform to be respectful of core regulatory
      help with regulation: data used in trading can be collected, stored       concerns, while always staying focused on serving investor clients.
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KnightCap.indd 1                                                                                                                                  9/9/10 10:33 AM
Elec&Algo Report_2010.qxp               9/10/10          10:00 AM            Page 8




         SEPTEMBER 2010 WALL STREET LETTER                                                                                                              ELECTRONIC & ALGO TRADING REPORT




          Q&A: BNY Mellon’s Sanjay Kannambadi

         ClearingThe Path: Preparing For
         A New OTC Derivatives Regime
                                                                                                                conversations we are having with clients. We are participating at
                                                                                                                industry forums like the ones held by the CFTC to hear and
                                                  A major driver of the recently
                                                                                                                understand the latest thinking and direction and share our input
                                                  passed regulatory reform was
                                                                                                                and opinions.
                                                  the recognition among market
                                                  participants and regulators that
                                                  a stricter regulatory framework
                                                                                                                WSL: The CFTC noted that as part of that
                                                  is necessary to govern the over-
                                                                                                                discussion it wanted to solve conflicts inherent in
                                                  the-counter derivatives market.
                                                                                                                mandating clearing of OTC derivatives. What
                                                  The Securities and Exchange
                                                                                                                conflicts do you see?
                                                  Commission and the
                                                                                                                KANNAMBADI: We certainly support transparency and openness in
            Sanjay Kannambadi                     Commodity Futures Trading
                                                                                                                the marketplace on behalf of our clients. To the extent they make
                                                  Commission are both working
                                                                                                                memberships in the clearinghouses restrictive, that will restrict the
           on rules that will detail the structure. The industry,
                                                                                                                marketplace and limit openness and fairness. That is something
           meanwhile, is working with what is available and preparing
                                                                                                                we are certain about and we have heard from our clients that they
           their businesses for the framework to come. Among those
                                                                                                                want us to clear their books of business.
           firms is The Bank Of New York Mellon, which launched a
                                                                                                                    As it stands today, some of the clearinghouses have very high
           futures commission merchant just this summer in order to
                                                                                                                artificial bars [for membership] for a variety of their own reasons,
           play a role in the whole process. Managing Editor Jeanene
                                                                                                                which do not qualify BNY Mellon Clearing to be a direct clearing
           Timberlake spoke with Sanjay Kannambadi, ceo of the
                                                                                                                member, so they expect us to go through other clearing members,
           new venture, BNY Mellon Clearing, about what exactly
                                                                                                                and that doesn’t make any sense. We are the largest asset servicer
           that role will be, what the concerns are from a regulatory
                                                                                                                in the world with $22 trillion in assets under custody and
           perspective, and where the complexities lay.
                                                                                                                administration for plan sponsors and asset managers, and if we
                                                                                                                are going to represent them, we need to be members of those
                                                                                                                clearinghouses.
         WSL: What concerns are you hearing from clients                                                            One problem we have heard discussed about an open construct
         related to OTC clearing?                                                                               is that management of risk is paramount and entities that do not
                                                                                                                have the size and capacity like the large dealers to manage risk
         KANNAMBADI: We’ve been talking to key clients over the last few                                        may create issues. But at the end of the day, one of the key points
         months, and from a [futures commission merchant’s]                                                     is that as long as margins are set and [collateral is] collected
         perspective, many of the conversations we are having are based                                         appropriately, that is the first level of defense. The clearing
         on getting our perspective and clarification around what is                                            members are not the only defense mechanism there. The clearing
         happening with respect to the Dodd-Frank Act and the potential                                         members do come into play, but that is not the first level of
         rules to be written.                                                                                   defense; it’s the margin you are collecting. In a default or worst-
            There is lots of information in the marketplace; some is                                            case scenario, there is no reason why you cannot allocate or
         conjecture, only part of it is fact based. So, there is a level of                                     auction a portfolio to clearing members or other parties in the
         clarification that all of us are seeking and those are the                                             marketplace, such as the buyside, for example. When you talk


     8
                         ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
Elec&Algo Report_2010.qxp            9/10/10          10:00 AM            Page 9




       ELECTRONIC & ALGO TRADING REPORT                                                                                                           WALL STREET LETTER SEPTEMBER 2010




      about allocating and auctioning [a portfolio], the more parties                                        only entity that can hold margin is an FCM. How that will all work
      there are, the better. Further, suggesting that the same parties                                       out, we don’t know. Because the FCM already takes in margin
      involved in risk management of these instruments during the                                            today, we already have the infrastructure to take in margin and
      market crisis should provide expertise in the new construct is a                                       segregate it. So, depending on how rules are on the non-cleared
      conflict by itself.                                                                                    side, we will perhaps have to play a role there.
         Clearinghouse structures have been in place for a long time in
      the futures markets. You can always argue futures are different,                                       WSL: In the midst of all the discussion about the
      but at the end of the day, the [Dodd-Frank Act] is trying to                                           rules, is anyone working on the nuts and bolts of
      normalize those factors to make those products more standardized                                       how this system will function? And is this an issue
      so they can be cleared. That is the spirit of the bill— transparency                                   at all?
      and central clearing—so there is some level of structure in the
      marketplace for regulators and all the relevant parties.                                               KANNAMBADI: Yes, we are working on the flows with the
                                                                                                             clearinghouses. We have been working with [the International
      WSL: You just launched the FCM business, BNY                                                           Derivatives Clearing Group] on that, for example. Presumably
      Mellon Clearing, so what is the bank’s vision in terms                                                 there are going to be variations of flows amongst the different
      of how the unit will fulfill the needs of your clients                                                 clearinghouses. Whether it will all be centralized through one
      in the cleared and non-cleared business as some of                                                     single workflow or not is not known at this point, but down the
      this activity starts to shake out?                                                                     road, I would expect it to be standardized.
                                                                                                                There are going to be complexities either way. It’s a work in
      KANNAMBADI: BNY Mellon Clearing represents a logical extension                                         progress and over a period of time the process will improve itself.
      of our business model. We intend to meet the growing needs of                                          The important thing I think people need to understand and
      clients who trade futures and derivatives and are seeking a global                                     recognize is that there is precedence for some of this, it’s not like
      clearing partner with proven operational, financial and risk                                           we’re starting from scratch. From our perspective it’s very clear: we
      management expertise. Regarding the shakeout, central clearing                                         need to make sure this process is simple for our clients.
      and where the FCM fits seems to be clear, but [on the OTC side,]
      everything is dependent on how the rules are written.                                                  WSL: Both the CFTC and the SEC are just starting to
          Typically, in a central clearing environment, most                                                 look at new rules, so what are you doing now to
      clearinghouses will require clearing members to provide clearing                                       tread water, so to speak?
      services. In the majority of cases, if you are clearing client business
      you need to be an FCM. We will play that role. In addition, our                                        KANNAMBADI: We are talking to all the key constituents in the
      clients are recognizing that in a cleared environment the bulk of                                      marketplace and trying to better understand their individual
      the operations and risk is shifting from the dealer to the FCM.                                        processes as it relates to the clearinghouses. We are doing that in
      According to the bill, clients get to decide which clearinghouse to                                    the U.S. and globally as the global model also develops. We are
      use for clearing. Once the trade is executed and is accepted for                                       staying in touch with all the key market players and organizations
      clearing, the clearinghouse becomes the client’s counterparty with                                     so we are up to speed on the latest developments ourselves and
      the FCM as the key intermediary. So clients will need to establish                                     we’re working with clients to give them our perspective on how we
      those FCM relationships upfront. This is an important role that we                                     think the bill and rules will play out.
      as an FCM will play.                                                                                      We are getting ready for central clearing. We are IDCG clearing
          On the uncleared side of the equation, there are some                                              members, and we’re going through the test phase and will be
      questions outstanding. For example, swaps are also included in                                         clearing trades for clients by the end of September. So we are
      [the bill]. One question that remains is if you are a swaps dealer                                     going through the connectivity test and things like that.
      and you’re dealing in non-cleared swaps, how is the margin                                                We are also looking at other clearinghouses and mechanisms
      process going to work and who decides that? I think it’s the                                           being discussed in the marketplace, such as the [CME Group’s]
      regulators, between CFTC and the [Federal Reserve Bank] that will                                      interest rate swap marketplace. We are also talking to
      make the decision on the margin percentage, but then who gets to                                       [LCH.Clearnet] and all the other players. At the end of the day, we
      hold the margin? [Swaps dealers] have to give the option to clients                                    as an FCM will look to clear books of business wherever our clients
      to segregate it or not. If a client decides they want their margin to                                  want to clear. In the whole scheme of things the FCM is a neutral
      be segregated, then the swap dealer needs to segregate it but the                                      party, it’s all client-driven.


                      ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
                                                                                                                                                                                                    9
ALGO-PipelineArticle   9/9/10   2:37 PM   Page 1




                                                          SPONSORED ARTICLE




        FROM ACTIONABLE
        TCA TO CUSTOM
        STRATEGY DESIGN                                  Carla Gomes, Ph.D., research analyst, Pipeline Financial Group, Inc. and
                                                      Henri Waelbroeck, Ph.D., director of research, Pipeline Financial Group, Inc.



       Most trading desks have tried to introduce Transaction Cost                            prove to be very difficult when the
                                                                                              circumstances of the trade are not
       Analysis (TCA) into their process, but for over a decade they have                     known. Pipeline’s most recent
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       found it frustrating and ineffective. In general, trades are broken
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       up into multiple placements and sent to a variety of brokers                           can be applied not only to post-trade
                                                                                              back-testing, but also to live trading
       under different market conditions and with different limit prices.                     and custom strategy design.
       Inevitably, the end shortfall performance results are biased and
                                                                                              A new actionable TCA framework can
       any inference made from them is compromised.                                           distinguish algo performance from the
                                                                                              use of limits or trading schedules
      The pervasiveness of high frequency          evaluate brokers, algorithms and           Trading schedules and limit prices, if
      trading and increased awareness of           execution venues in order to select the    used appropriately, can enhance alpha,
      the costs of trading large institutional     most efficient. It usually consists of     but if used incorrectly, can exacerbate
      orders have raised the stakes for            implementation shortfall comparisons       trading costs. In standard TCA,
      traders, who now face an ever more           between competitors, sometimes             implementation shortfall costs are
      fast-paced environment with a wider          accounting for trading difficulty          measured as totals. Hence, the
      set of trading tools and venues to           measured as a function of order size,      separate impact on overall
      choose from. Traders need to know            liquidity and volatility. It is widely     performance of the algorithm, the
      whether they are being taken                 acknowledged that trading alpha,           trading schedules and the selected
      advantage of and which algorithms are        market conditions, speed selection and     limit prices cannot be identified.
      the most effective. Without reliable         limit prices also have a considerable      Pipeline’s enhanced TCA determines
      TCA, how are they to know?                   impact on the outcome of a trade. Yet,     the significance of every component
                                                   these are seldom considered in             of shortfall costs. It provides an
                                                   standard TCA. This limitation is far       assessment of the trade-offs
      TCA is meaningful only in relation to        from trivial when a trading desk needs     associated with each decision element
      the context of a trade                       to determine the providers that deliver    and it determines the most
      The relevance of TCA to strategic            the best execution, yet each one           appropriate selections. For speed
      trading decisions has grown with the         receives a systematically different        selection, market impact is weighed
      pressure on trading desks to reduce          order flow. Inferences on the quality of   against alpha capture to decide
      costs. In general, TCA is employed to        execution, even from a single broker,      whether an execution with urgency is
ALGO-PipelineArticle   9/9/10   2:37 PM   Page 2




                                                          SPONSORED ARTICLE


       worthwhile. For limit price selection,      Pipeline’s Alpha Pro suite, a new         impact and post-trade reversion, but
       to check whether there are                  generation of customized trade            also in terms of adverse selection vs.
       opportunities for tactical price            strategies, leverages this TCA            opportunistic savings. The latter is
       selection, execution price savings are      framework to associate an optimal         identified by the analysis of
       weighted against opportunity costs          strategy to each trade arrival            participation rates under different
       from incompletion due to the price          Equipped with the detailed knowledge      market conditions and tracking
       limit. Also, algorithm performance can                                                performance against the Participation
                                                   of the alpha loss profiles at the time
       be evaluated in parallel in terms of                                                  Weighted Price (PWP). Additionally,
                                                   of the trade, Pipeline can facilitate
       adverse selection and opportunistic                                                   the performance results provide
                                                   efficient trading by recommending or
       savings. With this knowledge, traders                                                 guidance to the best approaches in
                                                   deploying best-fitting execution
       can devise forward-looking solutions                                                  terms of speed and limit price
                                                   strategies that enhance alpha capture.
       and be more effective making the                                                      management in accordance with the
                                                   Orders with weak alpha loss are
       right decision at the time of the trade.                                              specific objectives of each manager.
                                                   executed with tactical limits, which
                                                                                             These enhancements to standard TCA
                                                   are more effective if deployed
                                                                                             transform it from a post-trade
       Portfolio managers have distinct            automatically rather than manually.
                                                                                             reporting product into an actionable
       order creation strategies leading to        Orders with considerable alpha loss
                                                                                             trading tool that provides direction to
       different short-term alpha patterns         are executed with front-loaded
                                                                                             custom strategy design.
                                                   strategies with reduced timing costs.
       Just as an institution can implement
       several strategies from a wide range        With customization of trading
       of well-known styles of fund                strategies, the opportunities for         Summary
       management, including growth, value,        delivering the best execution do not      • An evidence-based selection of best
       market neutral, indexed, etc., a single     end here. A close collaboration             execution algorithms requires
       portfolio manager may also use a            between portfolio manager, trader and       dependable TCA that accounts for
       multitude of strategies with his own        broker can further leverage this            the trading environment. Pipeline
       distinctive investment style and skill.     comprehensive body of knowledge by          attends to this need with an
       Typically, orders originating from long-    determining the specific benchmarks,        enhanced TCA that identifies
       term strategies may create                  the goals to be met and then refining       separately all sources of trading cost
       opportunities for tactical trading,         the design of execution strategies          and lays the groundwork for optimal
       whereas orders more focused on              accordingly.                                trading strategy design.
       short-term returns usually require                                                    • Assessing potential alpha loss is at
       more aggressive trading, early on or at                                                 the core of the daily trading decision
       later stages of the trade. As a result,     Pipeline’s post-trade analysis enables
                                                                                               process, but quite challenging when
       the order flow sent to the trader is        dynamic strategy performance
                                                                                               the sources of order flow are very
       very diverse in terms of short-term         evaluation and fine-tuning
                                                                                               diverse and not fully understood.
       alpha loss profiles and that may            Pipeline’s comprehensive TCA is not         Post-trade quantitative analysis can
       require very different execution            limited to the validation of trading        provide validation to the selection of
       strategies. Although some orders are        strategies; it also provides all the        limit prices and trading schedules
       sent with very specific instructions        necessary information to identify           with immediate insight into the alpha
       and goals, there are still many cases       opportunities for fine-tuning each          characteristics of the order flow.
       where the trader has considerable           strategy. Gradually, some drivers may
                                                                                             • Pipeline’s Alpha Pro uses this
       discretion. A quantitative post-trade       lose importance whereas others may
                                                                                               knowledge to direct each
       analysis such as Pipeline’s can help        become more relevant and, as a
                                                                                               distinguishable trade profile into its
       the trader do a better job by providing     result, trade profiles may also change.
                                                                                               best-fitting scheduled trading
       detailed information on the short-term      Short-term alpha loss is one of the
                                                                                               strategy. Alpha Pro strategy design
       alpha loss profiles that characterize       components of implementation
                                                                                               is dynamic as it capitalizes on
       each portfolio manager’s investment         shortfall that is estimated to validate
                                                                                               recurring, forward-looking TCA.
       style. Each alpha profile is associated     trade classification and determine
       with specific trade arrival settings of     whether characteristics of the order
       order creation time, order size, market     flow have changed or remained the
       capitalization etc., which comprise the     same. Execution performance is
       set of relevant predictors.                 evaluated not only in terms of market
Elec&Algo Report_2010.qxp              9/10/10          10:00 AM            Page 12




         SEPTEMBER 2010 WALL STREET LETTER                                                                                                             ELECTRONIC & ALGO TRADING REPORT




         Multi-Asset Algos Eye Bigger Stage
         By Corrie Driebusch



                   The marriage between options and equities has flourished in the
                   multi-asset class algorithm arena, and now the industry is looking
                   forward to offerings that are next in line. Both buy-side trading
                   firms and sell-side algorithm providers expect some growth in
                   multi-class algorithms, specifically in foreign exchange and futures
                   in the next year or two.


             Currently the most popular multi-asset class algorithms remain                                        Harrell Smith, head of product strategy at Portware, said the
         options- and equity-tied algorithms. “Options and equities are a                                      slow pick-up in multi-asset algos beyond options has been an issue
         natural marriage,” one hedge fund manager said. Goldman                                               of lagging demand. Nevertheless, funds
         Sachs, Barclays, Jefferies, ITG and Knight Capital Group all offer                                    that trade globally are driving demand for
         pairs trading strategies that tie options and equities. For instance,                                 algorithms that can handle foreign
         Knight’s two offerings are a delta-neutral, or delta-adjusted,                                        exchange. Smith noted that in addition to
         strategy and a volatility offering. The former allows a client,                                       options, FX algos are also viewed largely
         typically a convertible arbitrage hedge fund, to execute an option                                    as “useable” for algorithmic trading.
         at a particular delta while simultaneously executing a delta hedge                                    Portware already has a suite. Hitesh                           Harrell
                                                                                                                                                                               Smith
         in the underlying equity. Volatility algorithms allow traders to                                      Mittal, head of liquidity management at
         purchase an option at a particular volatility regardless of price                                     Investment Technology Group, said ITG has focused a lot of its
         while purchasing the underlying security at the same time.                                            energies on its algorithm that incorporates equities and foreign
             Joe Wald, managing director at Knight, noted that these                                           exchange for stocks listed on both the Toronto Stock Exchange
         time-saving tools have proven incredibly important in an                                              and either Nasdaq Stock Market, NYSE Amex or the New York
                                  especially fragmented market. “You’re                                        Stock Exchange. ITG is looking at whether to launch similar
                                  trying to maximize alpha that is heavily                                     algorithms between other marketplaces, such as Europe.
                                  dependent on executing both legs of the                                          Mittal also sees futures, a natural hedge for equities, as
                                  strategy—if you’re wasting time or                                           another potential asset class to be embraced by algorithms. “It
                                  inefficient on getting the hedge on,                                         makes perfect sense to me to do [a futures and equities trade] in
                                  you’re really giving up alpha there,” he                                     tandem versus one guy yelling over to another guy across the
                                  explained. One New York-based hedge                                          room,” Mittal explained. “It’s an obvious one the market should
                        Joe Wald
                                  fund manager who trades both equities                                        move very quickly to.” In May ITG rolled out equity index futures
         and options agreed, saying the only multiple-asset class                                              trading capabilities in its portfolio algorithm Dynamic
         algorithm he uses is a delta-hedge strategy. “It’s not very sexy,                                     Implementation Shortfall. Mittal said it wasn’t based on client
         but it’s widely used,” he noted, adding that he is not looking for                                    demand, rather a belief that this is the next step for the industry.
         other algorithms at this time.                                                                        “We see this growing in the future,” he said.


    12
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         SEPTEMBER 2010 WALL STREET LETTER                                                                                                             ELECTRONIC & ALGO TRADING REPORT




         The Future Of Anti-Gaming:
         Where Are We Going?
         By Jeanene Timberlake


         The concept of anti-gaming technology and the logic that is used                                      Systems. “In the early days, people talked of penny jumping and
         to build it is getting more attention these days in light of an                                       front-running.” In the first instance, a specialist, knowing of a large
         increasingly microscopic focus on trading and market structure.                                       institutional limit order to buy, would buy the same stock for a
         “Anti-gaming” is the keyword in nearly any conversation that                                          price one penny above the institution’s bid, hoping to move the
         discusses dark liquidity, high-frequency trading or buy-side algos.                                   price up and create an opportunity to make money back on the
         Several firms have been quietly perfecting the technology, which                                      sale. In the latter, illegal instance, a broker receives a buy order
         essentially intends to protect a buy-side order from being picked                                     and before filling the order, places a buy order for the same stock
         off at a higher price than market realized prices in order to make                                    in a proprietary account; the broker then
         money on a sale at the NBBO.                                                                          places the customer order, hoping to push
             The technology ranges in approach and application, but all                                        the price up to later sell the stock that was
         works toward the goal of limiting buyside interaction with                                            purchased.
         predatory sell-side flow. Firms are using post-trade methodologies,                                       Gaming today is more sophisticated in
         reviewing data on a delayed schedule, but also have added in real-                                    light of the increased use of algorithms and
         time techniques. Some variations being developed will feature                                         the prevalence of dark pool trading.                        Mario Giannone

         monitoring activity at the point of sale and the ability to monitor                                   According to Mario Giannone, head of market surveillance and a
         for gaming across the market as opposed to looking at activity                                        software developer at Liquidnet, “peeking” is a problem common
         taking place in a single shop.                                                                        in pools where trades are negotiated between counterparties. In
             Already, there are concerns that regulators may try to restrict                                   that situation a buy-side and sell-side member match up, and after
         gaming activity, though it’s unclear how rules would work. One                                        the buy-side member indicates he is ready to trade, the sell-side
         factor that would make regulation difficult is that gaming isn’t                                      counterparty is no longer there. “They can see a match and they
         illegal or unethical, it’s a natural part of trading that traders have                                know there is someone of size on the other side,” he said, adding
         to master to a certain extent. “True gaming happens when firms                                        that while once may be accidental, multiple “peeks” often are not.
                                  are identifying supply and demand                                            Gamers may also try to test a price by buying little bits of a
                                  imbalances in the marketplace and then                                       particular stock at a time to test an institutions limit price and
                                  take market action to effect price based on                                  determine the size. Eran Fishler, director of research at Pragma,
                                  their assessment, but identifying                                            said one clue is when an institution gets a fill in a dark pool at a
                                  supply/demand imbalances and using that                                      price which is higher than the prices realized in the market prior
                                  to one’s advantage is the job of every                                       to the fill and after the sale, the price immediately reverts back to
                           Doug   trader,” according to Doug Rivelli, ceo of                                   more favorable levels. The danger in both cases is that the sell-side
                          Rivelli
                                  Pragma Securities.                                                           member may go out to the public market and move the price
                                                                                                               before going back to the pool to complete the trade, if the buy-
         NOT YOUR GRANDMA’S GAME                                                                               side interest is still there.
         Anti-gaming technology started gaining traction and credibility as
         more trading moved electronic. Larger institutional orders are the                                    PLAYING DEFENSE
         typical targets, and the games are not new, according to Henri                                        Since no one expects gamers to go away, the consensus for now seems
         Waelbroeck, v.p. and director of research at Pipeline Trading                                         to be that the only option is to block the gamers once detected. Firms


    14
                        ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
Elec&Algo Report_2010.qxp            9/10/10          10:00 AM            Page 15




       ELECTRONIC & ALGO TRADING REPORT                                                                                                           WALL STREET LETTER SEPTEMBER 2010




      are doing this now by combining technology for intraday detection                                      better [than the institution placing the trade]... What I would like to
      with old-fashioned data mining with the goal of finding trading                                        think is that presumption is fundamentally wrong. No trader
      patterns, whether within specific dark pools or for specific clients.                                  should resign himself or herself to the idea that others are better
      Fishler said Pragma studies post-execution data for executions its                                     informed than they are,” he added. That line of thinking is what
      clients make in the 40 or more venues it provides access to on a daily,                                started Pipeline on the development path of its Algorithmic
      weekly and monthly basis. “We want to study [the executions] and see                                   Switching Engine, launched in 2007. It applies the analytical power
      which destinations play host to gamers. So, we look at the return pre-                                 high frequency traders use to help determine what will happen in
      and post-fill at the destination,” he said, which is where the firm will                               a stock to predict a particular algorithm’s performance and
      notice whether the price reverts consistently.                                                         combines that with the institutional trader’s own knowledge of the
          Pragma monitors a variety of other factors as well to root out                                     strategy being deployed. On top of that, Pipeline recently
      anomalies. Dark pools with anomalies are blacklisted until Pragma                                      introduced Alpha Pro, which combines a firm’s trading history with
      can determine whether the anomalies are due to valid market                                            real-time conditions to create a custom strategy for traders.
      activity or gaming. The answer to that question determines                                                 Pragma’s approach will also look to use gamers’ strategy of
      Pragma’s next step, which can be as severe as deciding not to                                          trying to identify orders. The firm is developing an algorithm that
      connect to a certain venue any more, although Fishler said in                                          will attempt to detect gaming that is happening relative to the
      some cases they can target gaming down to the counterparty level.                                      trader using the algo as well as gaming that may be happening
          Giannone said his firm also monitors historical data that is                                       elsewhere in the market and plan trade executions around that.
      gathered from 35 different programs that survey his firm’s                                             “Whether I’m trading or not, the next generation will understand
      systems. “We gather information and look for patterns among our                                        what I am doing and what the market is doing,” said Fishler.
      members,” he said, noting it takes place on a T+1 basis to monitor                                     Figuring out where gaming is happening outside your own world is
      for outliers that may occur among members. “If any members are                                         always difficult because you never really know what is happening,
      doing something much more frequently than the rest of the                                              Rivelli added. This algorithm should go a long way to solving that
      community [compared to a community benchmark]... we will                                               issue, though he cautioned that these types of strategies should still
      proactively investigate that,” he added.                                                               be used in concert with other detection techniques.
          In both cases, these historical views are backed up by real-time                                       Liquidnet’s Giannone said his firm is in the process of rolling
      systems. Giannone noted members of his pool are encouraged to                                          out an enhancement to real-time capabilities that will move
      complain if they see any type of suspicious activity but the pool also                                 detection to the front-end. He noted that right now, real-time
      does its own monitoring. “We’re hoping to catch it before a member                                     monitoring will alert the pool operator that suspicious activity has
      complains, of course,” he said. “If we think it’s a bad trading                                        occurred, tipping off staff to monitor particular activity and
      protocol, we may even, intraday, block a member from matching                                          flagging the trades for further investigation and possible
      again. One reason would be to alleviate frustration, but another is                                    disciplinary action. The new capabilities, being developed in-
      to give time to investigate what happened,” he added, noting that                                      house, will monitor for gaming scenarios that, if engaged, will be
      enough evidence will earn a permanent suspension for the gamer.                                        acted on automatically. “If someone is breaking protocol, the
          Pragma’s real-time monitoring and anti-gaming help determine                                       system automatically takes action without investigation,” he said.
      what activity is happening as part of gaming and what might be a                                       Members engaging in the negative activity would receive alerts
      real strategy. If it is determined that the activity can be attributed to                              and the third alert would result in an instant block from trading.
      a gamer, the firm will stop trading or put limit prices on the trade, a                                “We would still investigate, but in terms of being proactive, this is
      move Fishler characterized as the “main tool” for prevention.                                          the Holy Grail.”
                                                                                                                 There is some concern that regulation could be under
      FROM DEFENSE TO PREVENTION                                                                             consideration to limit gaming in the U.S. similar to that which
      Providers don’t have the same concepts in mind when looking at                                         exists in the U.K. requiring pools to provide prevention technology.
                             the future, but there is agreement that one of                                  Operators of global pools would likely be more prepared in that
                             the best tools for the future is to use gamers’                                 case. Still, the prospect is considered unlikely in the U.S. in light of
                             own techniques to combat them. “Anti-                                           the fact that gaming is still within the rules. “There’s an important
                             gaming technology has developed as                                              differentiation between gaming based on an assessment of
                             defensive mechanisms,” said Pipeline’s                                          supply/demand versus actually knowing [information] and front-
                             Waelbroeck. “The defensive approach makes                                       running it. As long as a trader is taking market risk, it’s difficult to
            Henri Waelbroeck the assumption that someone else knows                                          regulate a trading strategy,” Rivelli said.


                      ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
                                                                                                                                                                                                    15
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         SEPTEMBER 2010 WALL STREET LETTER                                                                                                              ELECTRONIC & ALGO TRADING REPORT




         Buyside Worries Focused On
         Regulation Reform
          Regulatory issues have been a growing concern for industry participants of late, including those on the buyside, thanks to the
          sheer volume of new regulatory activity expected in the next few years. Chief among those concerns are the far-reaching
          implications of the recently passed Dodd-Frank Act, which touches nearly every aspect of the financial markets and permeates
          nearly every asset class. The following participants spoke about those concerns and how they’re dealing with it now, as well as
          their technology issues, how they’re handling volatility and what they want now in response to questions from reporters
          Meredith Lepore and Corrie Driebusch.



                                FROM THE BUYSIDE                                                                is now playing catch-up to this new, quickly changing environment.
                                                                                                                Right now, I don’t think there is one major concern, but many
         BASIL WILLIAMS, ceo of Concordia Advisors. Williams oversees                                           smaller issues that the industry is focused on. [For example], the
         the daily investment and business operations of the firm. Prior to                                     [National Market System] issue. The Securities and Exchange
         being named ceo, he was president and head of fixed-income                                             Commission is proposing a new Rule 613 that would require
         trading. Williams began his career at Merrill Lynch.                                                   national securities exchanges and national securities associations
                                                                                                                (self-regulatory organizations) to act jointly in developing a NMS
         JONATHAN KANTERMAN, managing director at Stillwater                                                    plan to develop, implement, and maintain a consolidated order
         Capital Partners. Kanterman has more than 16 years of investment                                       tracking system, or consolidated audit trail, with respect to the
         management experience and has worked at firms such as                                                  trading of NMS securities.
         Valenzuela Capital Partners and Woodford Gayed Management.                                                 [There is also] the “large trader rule,” which would require high-
                                                                                                                frequency and other large-volume traders to code their trade tickets
         JUDITH MOSES, portfolio manager at Evercore Wealth                                                     with a unique identifier.
         Management. Moses has more than 19 years of experience in the                                              For the circuit-breaker issues, we need to help stop flash crashes
         investment management industry. Prior to joining Evercore, she was                                     and [find] ways to speed recovery if they do occur, bust erroneous
         v.p. at U.S. Trust, Bank of America Wealth Management and                                              trades when crashes happen, etc.
         before that she was with the Charter Financial Group.                                                      Algorithm flow catching up to phone orders is another issue. The
                                                                                                                fact that the volume of shares that buy-side traders send to sales desks
         KEVIN CRONIN, director of global equity trading at Invesco.                                            and to the equities markets using algorithms will soon be the same.
         Cronin has spent more than a decade at the helm of global trading for                                      Probably the biggest issues are the unknown results of The Dodd-
         investment firms. He has testified on multiple occasions in front of                                   Frank (Wall Street Reform and Consumer Protection) Act, which
         the Securities and Exchange Commission on a variety of subjects.                                       grants the SEC an entire array of new powers. The unknown usually
                                                                                                                results in the most apprehension.
         STEVE SACHS, director of trading at Diamond Hill Investments.
         He previously held the same position at SGI/Rydex.                                                     CRONIN: It’s not easily contained to one issue—it’s really the whole
                                                                                                                picture. After the flash crash, you have a number of people trying to
                                                                                                                rush to judgment on what went wrong and who’s responsible. As I
         WSL: What is the biggest regulatory concern facing                                                     look at the world I can’t help but think the biggest risk for all of us is
         the industry?                                                                                          to overregulate an environment that’s not today very well-known.
         KANTERMAN: I think this is one of the most historic times for the                                      For example, look at high-frequency trading. A lot of us have
         industry, with new levels of technology driving growth, efficiency                                     concerns about high-frequency trading. But there are a number of
         and productivity, coupled with the resulting need for proper                                           different participants in the marketplace that would be considered
         regulation. As is traditionally the case, regulatory oversight lags and                                high-frequency traders and their place in the market is very good. It

    16
                         ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
ELECTRONIC & ALGO TRADING REPORT                                                                                                            WALL STREET LETTER SEPTEMBER 2010




needs to be well-understood and not a rush to judgment to                                               focus is almost post-mortem of how orders are managed.
appease some faction of the market that says something has to be
done. Many of the things that led us to May 6 are not as easily fixed                                   SACHS: First and foremost are the tools we need to better serve our
by putting circuit breakers or disallowing market orders.                                               shareholders. A big driver of [technology changes] is also responding
                                                                                                        to market structure—how we’re forced to trade these days versus
MOSES: While the recently passed Frank-Dodd Bill will certainly have                                    days in the past. The fact is there are 40-plus execution venues out
a far reaching and, at this point, indeterminable impact on the                                         there where a stock may or may not trade.
financial services industry, of immediate concern to those of us in                                     Given that, and given the short-term noise in
wealth management is the uncertain tax regime. It is a challenge to                                     the market, and given the illusion of liquidity
                        make investment decisions when one doesn’t                                      out there, most of what we’ve done is getting
                        know what the capital gains or dividend tax                                     better tools to find the liquidity we need to
                        rates will be next year. Will Congress allow                                    make transactions. We can trade 4-5 billion
                        President George W. Bush’s tax cuts to expire,                                  shares of volumes in the markets in a given
                                                                                                                                                            Steve Sachs
                        in which case our clients will be looking at a                                  day but I don’t think [the markets] are any
                        possible dividend tax rate of 39.6%? I have                                     more liquid than they were years ago. If anything they’re less liquid;
                        heard numerous possibilities being discussed,                                   the depth of book has disappeared. What we need is a tool set to
 Judith Moses
                        including dividend and capital gains rates of                                   connect anywhere and everywhere and to be able to monitor how
20%, 25% or 28%, an extension of the Bush tax cuts for one year,                                        our tools are doing in those marketplaces, what sort of gaming is
                                                                                                        taking place.
keeping the tax cuts for those earning less than $250K, etc. There is
the same uncertainty with regard to estate taxes.
                                                                                                        MOSES: Technology is an integral part of our business and advances
                                                                                                        in technology have made it possible for us to easily invest in all
WILLIAMS: For certain operators in the hedge fund arena, SEC
                                                                                                        asset classes, equities, fixed income, currencies, options, futures,
registration is a burden. A less certain question is bank capital
                                                                                                        etc. Technology has lowered transaction costs and improved price
requirements and the lending activity of alternative asset managers.
                                                                                                        discovery and liquidity to name a few benefits. But we have also
What will requirements mean to banks and bank clients?
                                                                                                        seen some of the negatives of technology as evidenced by the flash
                                                                                                        crash in May.
SACHS: I think we’re at a point where the pendulum has swung way
                                                                                                            Now that the majority of equity [trading] is done electronically,
too far and we need a complete overhaul of our financial system.                                        off the exchanges, there are not designated market makers whose
For the last five years since [Regulation] NMS we have moved to a                                       responsibility is to provide an orderly market in stocks. One can see
market structure that no longer serves the fundamental investor.                                        how a disorderly situation could occur if participants in electronic
The market is full of tactical trading strategies. My biggest concern is                                exchanges who typically provide liquidity, but are not required to,
a lot of one-off solutions, from the uptick rule to circuit breakers.                                   step back from trading and liquidity disappears. Our responsibility
We need to take a step back and take a look at the whole market.                                        to our clients is to use technology to help us construct and manage
The SEC is beginning to do that with the concept release, but now                                       well-diversified portfolios while minimizing transaction costs. In
what happens? Will there be follow through?                                                             addition, we must protect and manage the risk that advances in
                                                                                                        technology pose to our clients’ portfolios.
WSL: What type of technology issues are you focused
on right now?                                                                                           KANTERMAN: I think the biggest issues right now stem from the
CRONIN: We don’t fashion ourselves as high-frequency. Our time                                          uncertainty. Companies don’t want to spend on new technology
horizon is not six seconds. We’re not trying to solve for pico- or                                      and services until they have more clarity on the regulatory and
nanosecond. But on the other hand, because the market has                                               compliance issues in the pipeline. Most of the industry is in a
become comprised of so many of these picosecond and                                                     holding pattern until they know exactly what will be needed. Then
nanosecond participants, we have to understand well how this arms                                       there will be a wave of spending on new technology and upgrades
race is going to play out. We have to understand how our orders are                                     to match the new landscape. These types of dramatic changes and
being handled. [For instance, what happens] if we send an order to                                      advancements happen every 10-15 years.
one place [that] subsequently sends it to another place that
subsequently sends it to another? Who can see those orders and                                          WSL: What’s your take on recent market volatility and
what potential information leakage can be from that? [We need to                                        how it is affecting your business?
know] how technology works with respect to transaction cost in                                          WILLIAMS: It has been good for our business. We are looking to
particular, and also in terms of what dark pools we can go to. The                                      trade relative value, so when there are high levels of volatility, there

                ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
                                                                                                                                                                                              17
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Electronic & Algo Tading Report

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Electronic & Algo Tading Report

  • 2. “In my world, ‘global’ means a broker that’s as comfortable in Boston as in Beijing and Barcelona.” UBS is an equities trading partner for your world. As a top equities trader in the US and around the world,* UBS provides a consistently first-rate experience whether you’re trading domestically or abroad. And with on-the-ground specialists and advanced tools customized for over 130 local markets, we can serve you in whatever way you choose —through a single point person or a team of experts. We understand the world. Your world. For more information, please contact us at www.ubs.com/yourworld *Source: AutEx 2008. In the U.S., securities underwriting, trading and brokerage activities and M&A advisor activities are provided by UBS Securities LLC, a registered broker-dealer that is a wholly owned subsidiary of UBS AG, a member of The New York Stock Exchange and other principal exchanges, and a member of SIPC. © UBS 2010. All rights reserved. UBS ad.indd 1 9/9/10 2:23 PM
  • 3. Elec&Algo Report_2010.qxp 9/10/10 9:59 AM Page 3 ELECTRONIC & ALGO TRADING REPORT WALL STREET LETTER SEPTEMBER 2010 EDITOR’S NOTE www.emii.com Thank you for picking up a copy of Institutional Investor News’ second annual Electronic & Algo Trading Report. The report, EDITORIAL PUBLISHING STEVE MURRAY ALLISON ADAMS written by the editorial staff of Wall Street Letter, aims to bring you Editor Group Publisher the latest on this year’s hot topics as well as those key areas that are TOM LAMONT GAURI GOYAL General Editor Business Director (212) 224-3504 just as important but not getting as much play. VERONICA BELITSKI ISMAELA BEST Executive Editor (212) 224-3297 Senior Marketing Manager (212) 224-3609 Two years removed from Sept. 15, 2008, the financial markets have JEANENE TIMBERLAKE LAURA PAGLIARO withstood much berating from Congress, scrutiny from financial regulators and skepticism Managing Editor (212) 224-3638 Marketing Manager (212) 224-3896 from the investing public. The world of electronic trading has also been through the MEREDITH LEPORE VINCENT YESENOSKY Senior Reporter (212) 224-3318 Head of US Fulfillment wringer, with executives facing questions from the Securities and Exchange Commission CORRIE DRIEBUSCH DAVID SILVA and the Commodity Futures Trading Commission on issues such as high-frequency Reporter (212) 224-3268 Senior Fulfillment Manager trading, predatory algorithms, flash trading, co-location, trade reporting and tracking, dark PRODUCTION REPRINTS pools, sponsored access, and more. DANY PEÑA DEWEY PALMIERI Director Reprints & Premission Manager (212) 224-3675 This hasn’t slowed the industry at all. Case in point: algorithms are being used now more COVER DESIGN dpalmieri@iinvestor.net than ever, even as regulators question their use by high-frequency traders. SAMANTHA RALPH CORPORATE Advertising & Marketing Coordinator The buyside has always played a key part of the trading process but hasn’t always been the GARY MUELLER ADVERTISING Chairman & CEO squeakiest of wheels. Now, however, traders are starting to speak up as regulatory concerns ADRIENNE BILLS STEVE KURTZ pervade more of the buy-side firms’ business. We tapped several head traders to get their Associate Publisher (212) 224-3214 Chief Operating Officer perspectives on what concerns the buyside in a roundtable (page 16) that covers a host of PAT BERTUCCI Associate Publisher (212) 224-3890 these issues. Customer Service: PO Box 5016, Brentwood, TN 37024-5016 Of course, we couldn’t address the industry’s concerns without taking a look at the over- Tel: 1-800-715-9195 • Fax: 1-615-377-0525 • UK: 44 20 7779 8704 Hong Kong: 852 2842 6910• E-mail: customerservice@iinews.com the-counter derivatives market, which is facing an automated, electronic world for trading Editorial Offices: 225 Park Avenue South, New York, NY 10003. and clearing that is just over the horizon. Regulators are still sussing out the best way to Tel: 1-212-224-3297 • Email: vbelitski@iinews.com regulate the industry, but that doesn’t mean the industry’s sitting on its hands. We’ve got Institutional Investor Hotline: (212) 224-3570 and (1-800) 437-9997 or hotline@institutionalinvestor.com the details on BNY Mellon Clearing’s plans to approach this market head on and talked at A Publication of Institutional Investor, Inc. length about how the firm thinks the clearing structure should be set up. © Copyright 2010. Institutional Investor, Inc. All rights reserved. New York Publishing offices: 225 Park Avenue South, New York, NY 10003 • 212-224-3800 • www.iinews.com It was no small feat determining what should be addressed. That being said, we hope you Copyright notice. No part of this publication may be copied, photocopied or duplicated in any enjoy this year’s report. Feel free to contact any of us with feedback, questions or concerns. form or by any means without Institutional Investor’s prior written consent. Copying of this publication is in violation of the Federal Copyright Law (17 USC 101 et seq.). Violators may be subject to criminal penalties as well as liability for substantial monetary damages, including Regards, statutory damages up to $100,000 per infringement, costs and attorney’s fees. The information contained herein is accurate to the best of the publisher’s knowledge; however, the publisher can accept no responsibility for the accuracy or completeness of such information or for loss or damage caused by any use thereof. Jeanene Timberlake From the publishers of: Managing Editor jtimberlake@iinews.com TABLE OF CONTENTS NEXT-GEN EQUITY CLEARING THE PATH: MULTI-ASSET CLASS ALGOS THE FUTURE OF ANTI- BUYSIDE WORRIES FOCUSED ALGORITHMS TAKE HOLD PREPARING FOR THE NEW EYE BIGGER STAGE GAMING : WHERE ARE WE ON REGULATION REFORM By Meredith Lepore OTC DERIVATIVES REGIME By Corrie Driebusch GOING? By Corrie Driebusch and Buy-side firms are looking for By Jeanene Timberlake Multi-asset class trading By Jeanene Timberlake Meredith Lepore more sophisticated trading BNY Mellon Clearing’s strategies were expected to Anti-gaming technology has Buy-side executives talk tools, and the sellside is Sanjay Kannambadi talks flourish into a big business, become more sophisticated about the impact of stepping up to provide the about how his firm is but the electronic version of as gaming strategies have regulation on their answer. Sell-side trading handling the uncertainty in the strategy is still catching advanced. Dark pool businesses, plus their execs talk about the future of the OTC derivatives market. on. Sell-side executives spoke operators and dark liquidity technology needs and what algo trading. about the requests they’re aggregators discuss current they want most. fielding in that arena. and future solutions to the 4 8 12 14 16 growing problem. ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195. 3
  • 4. Elec&Algo Report_2010.qxp 9/10/10 9:59 AM Page 4 SEPTEMBER 2010 WALL STREET LETTER ELECTRONIC & ALGO TRADING REPORT Next-Gen Equity Algorithms Take Hold By Meredith Lepore As the buyside becomes more advanced in its use of sophisticated trading tools, the sellside is speedily developing algos that are equipped with superior logic and liquidity seeking abilities, statistical ranking models and the ability to trade in international markets with limited market impact. Market participants on both sides stress that coming algos have to be prepared to execute successfully in more volatile markets, adhere to real-time transparency and reporting demands and work in countries with very diverse market infrastructures. According to an analyst, spending on advanced algorithmic trading technology will reach more than $1.3 billion in the next year. ADVANCED LOGIC example of this would be Deutsche Bank’s new algo, Super X, Algos will need to be equipped with the logic and liquidity seeking which uses a statistical ranking model that analyzes the execution abilities to perform successfully in different kinds of multi-lateral characteristics of each venue. In searching for the best place to trading facilities, which are seen as the trade an order, it takes the traders’ constraints and stock main contributors to market information leakage into account. Kang said Citi’s algos are fragmentation. “We are dealing with algos prepared to handle difficult volatility and can halt a trade if there trading in 30 dark pools and up to eight is market movement outside of the exchanges. As a provider, you have to deal expected range. Algos must also be able to with a marketplace that has trading venues learn from past experience by factoring Hitesh with different qualities,” said Hitesh Mittal, transaction cost analysis into their strategy. Mittal head of liquidity management for ITG. Minimizing the time between detection “Each venue behaves differently, so the algo does as well,” said of events, ranging from news events, Young Kang, global head of algorithmic products at Citigroup. To market data or a quote request, and the Young Kang meet that goal, the programs will start to include more granular actual placement of an order is essential. market data, such as a news feed from Dow Jones, said the “Algos are now fully dynamic systems, using complex directors. mathematical models to drive both macro level decisions of Collecting more data for algos so they are equipped with speed and urgency but also the micro level order placement. The statistical ranking models in their logic is a step that many firms sophistication of these models will continue to adapt and evolve are working on to help change trading behavior on the fly. An based on client demand and market structure change,” said 4 ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
  • 5. ICAP ad 9/9/10 2:34 PM Page 1 SPONSORED ARTICLE HIGH FREQENCY TRADING AND FX By Daniel Torrey, head of New Business-Americas, ICAP Electronic Broking Foreign exchange (FX) is the equities market ‘flash crash’. In highly side by enabling hedge funds and world’s most liquid market and volatile conditions, trading volume on Commodity Trading Advisors (CTAs) to EBS exceeded $383 billion (single trade in the spot FX market through presents significant opportunities count), representing nearly 255,000 the pre-screened credit of an EBS for traders searching for alpha in transactions. EBS provided orderly prime bank. new asset classes. efficient, effective access to prices at Before entering the FX market, OTC FX functions well as a self- all price points, even during the most high-frequency trading firms need to regulated market, as illustrated by the volatile 10 minutes of the trading day understand the different FX trading EUR/USD price action that occurred (see chart). venues available (e.g. independent on the electronic EBS platform on EBS was the first interbank versus bank-owned), and must May 6, 2010, the day of the US platform to permit access to the buy- address a number of technology and integration issues. EUR/USD price action on EBS - 6 May 2010 They will also need to modify their exchange- 5/6/2010 EUR/USD 1.2710 Bid based equities trading 1.2700 Offer Interrupt strategies and algorithms 1.2690 Deal 1.2680 before they are ready for 1.2670 FX. A robust software 1.2660 1.2650 development and testing 1.2640 environment, and a 1.2630 1.2620 rigorous simulated trading 1.2610 environment are also 1.2600 critical. 1.2590 1.2580 Access to high quality, 1.2570 granular market data is 1.2560 1.2550 essential, and FX-specific 1.2540 risk management 1.2530 1.2520 systems must be 1.2510 introduced. 1.2500 1.2490 However, despite the 1.2480 challenges that entry to 18:05:00 18:10:00 18:15:00 18:20:00 18:25:00 18:30:00 18:35:00 18:40:00 18:45:00 18:50:00 18:55:00 19:00:00 high frequency FX trading presents, rigorous The day of the US equities ‘flash crash’ (May 6, 2010) traders using the EBS platform traded record amounts of volume ($383 billion). Market participants executed trades [red diamonds] at all price points preparation and planning amidst significant price swings, with virtually no gapping, even in the most active minutes of trading. will result in fewer frustrations on going live. Daniel Torrey heads EBS New Business-Americas for ICAP Electronic Broking (IEB). Dan and his team’s primary focus is selling the benefits of EBS and EBS Prime to hedge funds, CTAs, FCMs and proprietary trading firms who seek access to EBS’ unparalleled wholesale market liquidity. email: daniel.torrey@us.icap.com
  • 6. Elec&Algo Report_2010.qxp 9/10/10 10:00 AM Page 6 SEPTEMBER 2010 WALL STREET LETTER ELECTRONIC & ALGO TRADING REPORT Owain Self, global head of algorithmic and reviewed for compliance purposes. trading at UBS. ALGOS IN INTERNATIONAL MARKETS TRANSPARENCY Algos that can be deployed in international markets, especially Next-generation algos will also need to emerging markets, are the next frontier. The sellside is working on provide more transparency in these building algos that are as similar as can be to the algos the traders volatile and highly regulated times. have become used to but that also account for international Owain Self Calculating risk exposure will be on the to- market nuances and risks. Traders are more willing to invest in do list for the next generation and real-time algos can provide foreign markets if they are able to use the same methods they are visibility into an algo’s potential exposure and determine a trade’s currently using for their portfolios, said Dan Pagano, v.p. of risk impact. Risk assessment will be especially critical with cross- strategic alliances at Linedata. asset trades that have multiple legs in a single order and are done ITG recently made its algo suite available in Israel, and both Citi in real-time. If the trade is being exposed too much, the algo can and ITG will be launching algos in Brazil for the first time soon. UBS, be adjusted before the order is executed. “Clients need to see Bank of America Merrill Lynch, Jefferies, Nomura and Deutsche slippage of orders in real time and where the orders are being Bank have also started extending their algo suites for emerging executed,” said Kang. Citi is planning a roll out of its new service, markets such as Japan, China, India, Greece, Australia, Canada, Citi Trade Viewer, which will help clients achieve these goals. The Eastern Europe and Latin America. “It’s important to note that we desktop trading application, to be launched this fall, enables are operating in an environment of rapid market structure change. traders to see every detail of an order in real time using visual This is a global phenomenon, as regulators across the Americas, analysis. Europe and Asia-Pacific are grappling with ways to evolve their rules ITG has increased their consultations with clients in the last few and surveillance apace with the global markets and advanced years so clients really understand how the algo functions and technology,” said Self. This requires the architecture of an what is the best way to use it, Mittal said. Transparency will also algorithmic trading platform to be respectful of core regulatory help with regulation: data used in trading can be collected, stored concerns, while always staying focused on serving investor clients.
  • 7. Execute at the Oasis Liquidity found. Discover a new category of algorithms designed specifically to source small- and mid-cap liquidity. Oasis is a unique and focused smart order execution strategy that handles obstacles related to thin and difficult to trade names. Combined with Knight’s leading market share in stocks that trade less than two million shares per day — now you’re executing at the Oasis. Find out what Knight can do for you To find out: phone +44 (0) 20.7997.7818 | US +1.212.479.2335 email oasis@knight.com www.knight.com © September 2010 Knight Capital Group, Inc. All rights reserved. Knight Equity Markets LP and Knight Capital Markets LLC are off-exchange liquidity providers. Oasis is offered through Knight Direct LLC. TradeWeb BlockData - Market Rankings are based on trade volume reported by Broker Dealers (Knight Equity Markets, Knight Capital Markets and Knight Direct LLC). YTD through Mar 31, 2010. To learn more about Knight Capital Group, Inc. (NYSE Euronext: KCG) go to www.knight.com KnightCap.indd 1 9/9/10 10:33 AM
  • 8. Elec&Algo Report_2010.qxp 9/10/10 10:00 AM Page 8 SEPTEMBER 2010 WALL STREET LETTER ELECTRONIC & ALGO TRADING REPORT Q&A: BNY Mellon’s Sanjay Kannambadi ClearingThe Path: Preparing For A New OTC Derivatives Regime conversations we are having with clients. We are participating at industry forums like the ones held by the CFTC to hear and A major driver of the recently understand the latest thinking and direction and share our input passed regulatory reform was and opinions. the recognition among market participants and regulators that a stricter regulatory framework WSL: The CFTC noted that as part of that is necessary to govern the over- discussion it wanted to solve conflicts inherent in the-counter derivatives market. mandating clearing of OTC derivatives. What The Securities and Exchange conflicts do you see? Commission and the KANNAMBADI: We certainly support transparency and openness in Sanjay Kannambadi Commodity Futures Trading the marketplace on behalf of our clients. To the extent they make Commission are both working memberships in the clearinghouses restrictive, that will restrict the on rules that will detail the structure. The industry, marketplace and limit openness and fairness. That is something meanwhile, is working with what is available and preparing we are certain about and we have heard from our clients that they their businesses for the framework to come. Among those want us to clear their books of business. firms is The Bank Of New York Mellon, which launched a As it stands today, some of the clearinghouses have very high futures commission merchant just this summer in order to artificial bars [for membership] for a variety of their own reasons, play a role in the whole process. Managing Editor Jeanene which do not qualify BNY Mellon Clearing to be a direct clearing Timberlake spoke with Sanjay Kannambadi, ceo of the member, so they expect us to go through other clearing members, new venture, BNY Mellon Clearing, about what exactly and that doesn’t make any sense. We are the largest asset servicer that role will be, what the concerns are from a regulatory in the world with $22 trillion in assets under custody and perspective, and where the complexities lay. administration for plan sponsors and asset managers, and if we are going to represent them, we need to be members of those clearinghouses. WSL: What concerns are you hearing from clients One problem we have heard discussed about an open construct related to OTC clearing? is that management of risk is paramount and entities that do not have the size and capacity like the large dealers to manage risk KANNAMBADI: We’ve been talking to key clients over the last few may create issues. But at the end of the day, one of the key points months, and from a [futures commission merchant’s] is that as long as margins are set and [collateral is] collected perspective, many of the conversations we are having are based appropriately, that is the first level of defense. The clearing on getting our perspective and clarification around what is members are not the only defense mechanism there. The clearing happening with respect to the Dodd-Frank Act and the potential members do come into play, but that is not the first level of rules to be written. defense; it’s the margin you are collecting. In a default or worst- There is lots of information in the marketplace; some is case scenario, there is no reason why you cannot allocate or conjecture, only part of it is fact based. So, there is a level of auction a portfolio to clearing members or other parties in the clarification that all of us are seeking and those are the marketplace, such as the buyside, for example. When you talk 8 ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
  • 9. Elec&Algo Report_2010.qxp 9/10/10 10:00 AM Page 9 ELECTRONIC & ALGO TRADING REPORT WALL STREET LETTER SEPTEMBER 2010 about allocating and auctioning [a portfolio], the more parties only entity that can hold margin is an FCM. How that will all work there are, the better. Further, suggesting that the same parties out, we don’t know. Because the FCM already takes in margin involved in risk management of these instruments during the today, we already have the infrastructure to take in margin and market crisis should provide expertise in the new construct is a segregate it. So, depending on how rules are on the non-cleared conflict by itself. side, we will perhaps have to play a role there. Clearinghouse structures have been in place for a long time in the futures markets. You can always argue futures are different, WSL: In the midst of all the discussion about the but at the end of the day, the [Dodd-Frank Act] is trying to rules, is anyone working on the nuts and bolts of normalize those factors to make those products more standardized how this system will function? And is this an issue so they can be cleared. That is the spirit of the bill— transparency at all? and central clearing—so there is some level of structure in the marketplace for regulators and all the relevant parties. KANNAMBADI: Yes, we are working on the flows with the clearinghouses. We have been working with [the International WSL: You just launched the FCM business, BNY Derivatives Clearing Group] on that, for example. Presumably Mellon Clearing, so what is the bank’s vision in terms there are going to be variations of flows amongst the different of how the unit will fulfill the needs of your clients clearinghouses. Whether it will all be centralized through one in the cleared and non-cleared business as some of single workflow or not is not known at this point, but down the this activity starts to shake out? road, I would expect it to be standardized. There are going to be complexities either way. It’s a work in KANNAMBADI: BNY Mellon Clearing represents a logical extension progress and over a period of time the process will improve itself. of our business model. We intend to meet the growing needs of The important thing I think people need to understand and clients who trade futures and derivatives and are seeking a global recognize is that there is precedence for some of this, it’s not like clearing partner with proven operational, financial and risk we’re starting from scratch. From our perspective it’s very clear: we management expertise. Regarding the shakeout, central clearing need to make sure this process is simple for our clients. and where the FCM fits seems to be clear, but [on the OTC side,] everything is dependent on how the rules are written. WSL: Both the CFTC and the SEC are just starting to Typically, in a central clearing environment, most look at new rules, so what are you doing now to clearinghouses will require clearing members to provide clearing tread water, so to speak? services. In the majority of cases, if you are clearing client business you need to be an FCM. We will play that role. In addition, our KANNAMBADI: We are talking to all the key constituents in the clients are recognizing that in a cleared environment the bulk of marketplace and trying to better understand their individual the operations and risk is shifting from the dealer to the FCM. processes as it relates to the clearinghouses. We are doing that in According to the bill, clients get to decide which clearinghouse to the U.S. and globally as the global model also develops. We are use for clearing. Once the trade is executed and is accepted for staying in touch with all the key market players and organizations clearing, the clearinghouse becomes the client’s counterparty with so we are up to speed on the latest developments ourselves and the FCM as the key intermediary. So clients will need to establish we’re working with clients to give them our perspective on how we those FCM relationships upfront. This is an important role that we think the bill and rules will play out. as an FCM will play. We are getting ready for central clearing. We are IDCG clearing On the uncleared side of the equation, there are some members, and we’re going through the test phase and will be questions outstanding. For example, swaps are also included in clearing trades for clients by the end of September. So we are [the bill]. One question that remains is if you are a swaps dealer going through the connectivity test and things like that. and you’re dealing in non-cleared swaps, how is the margin We are also looking at other clearinghouses and mechanisms process going to work and who decides that? I think it’s the being discussed in the marketplace, such as the [CME Group’s] regulators, between CFTC and the [Federal Reserve Bank] that will interest rate swap marketplace. We are also talking to make the decision on the margin percentage, but then who gets to [LCH.Clearnet] and all the other players. At the end of the day, we hold the margin? [Swaps dealers] have to give the option to clients as an FCM will look to clear books of business wherever our clients to segregate it or not. If a client decides they want their margin to want to clear. In the whole scheme of things the FCM is a neutral be segregated, then the swap dealer needs to segregate it but the party, it’s all client-driven. ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195. 9
  • 10. ALGO-PipelineArticle 9/9/10 2:37 PM Page 1 SPONSORED ARTICLE FROM ACTIONABLE TCA TO CUSTOM STRATEGY DESIGN Carla Gomes, Ph.D., research analyst, Pipeline Financial Group, Inc. and Henri Waelbroeck, Ph.D., director of research, Pipeline Financial Group, Inc. Most trading desks have tried to introduce Transaction Cost prove to be very difficult when the circumstances of the trade are not Analysis (TCA) into their process, but for over a decade they have known. Pipeline’s most recent developments intend to fill this gap found it frustrating and ineffective. In general, trades are broken and convert TCA into a new tool that up into multiple placements and sent to a variety of brokers can be applied not only to post-trade back-testing, but also to live trading under different market conditions and with different limit prices. and custom strategy design. Inevitably, the end shortfall performance results are biased and A new actionable TCA framework can any inference made from them is compromised. distinguish algo performance from the use of limits or trading schedules The pervasiveness of high frequency evaluate brokers, algorithms and Trading schedules and limit prices, if trading and increased awareness of execution venues in order to select the used appropriately, can enhance alpha, the costs of trading large institutional most efficient. It usually consists of but if used incorrectly, can exacerbate orders have raised the stakes for implementation shortfall comparisons trading costs. In standard TCA, traders, who now face an ever more between competitors, sometimes implementation shortfall costs are fast-paced environment with a wider accounting for trading difficulty measured as totals. Hence, the set of trading tools and venues to measured as a function of order size, separate impact on overall choose from. Traders need to know liquidity and volatility. It is widely performance of the algorithm, the whether they are being taken acknowledged that trading alpha, trading schedules and the selected advantage of and which algorithms are market conditions, speed selection and limit prices cannot be identified. the most effective. Without reliable limit prices also have a considerable Pipeline’s enhanced TCA determines TCA, how are they to know? impact on the outcome of a trade. Yet, the significance of every component these are seldom considered in of shortfall costs. It provides an standard TCA. This limitation is far assessment of the trade-offs TCA is meaningful only in relation to from trivial when a trading desk needs associated with each decision element the context of a trade to determine the providers that deliver and it determines the most The relevance of TCA to strategic the best execution, yet each one appropriate selections. For speed trading decisions has grown with the receives a systematically different selection, market impact is weighed pressure on trading desks to reduce order flow. Inferences on the quality of against alpha capture to decide costs. In general, TCA is employed to execution, even from a single broker, whether an execution with urgency is
  • 11. ALGO-PipelineArticle 9/9/10 2:37 PM Page 2 SPONSORED ARTICLE worthwhile. For limit price selection, Pipeline’s Alpha Pro suite, a new impact and post-trade reversion, but to check whether there are generation of customized trade also in terms of adverse selection vs. opportunities for tactical price strategies, leverages this TCA opportunistic savings. The latter is selection, execution price savings are framework to associate an optimal identified by the analysis of weighted against opportunity costs strategy to each trade arrival participation rates under different from incompletion due to the price Equipped with the detailed knowledge market conditions and tracking limit. Also, algorithm performance can performance against the Participation of the alpha loss profiles at the time be evaluated in parallel in terms of Weighted Price (PWP). Additionally, of the trade, Pipeline can facilitate adverse selection and opportunistic the performance results provide efficient trading by recommending or savings. With this knowledge, traders guidance to the best approaches in deploying best-fitting execution can devise forward-looking solutions terms of speed and limit price strategies that enhance alpha capture. and be more effective making the management in accordance with the Orders with weak alpha loss are right decision at the time of the trade. specific objectives of each manager. executed with tactical limits, which These enhancements to standard TCA are more effective if deployed transform it from a post-trade Portfolio managers have distinct automatically rather than manually. reporting product into an actionable order creation strategies leading to Orders with considerable alpha loss trading tool that provides direction to different short-term alpha patterns are executed with front-loaded custom strategy design. strategies with reduced timing costs. Just as an institution can implement several strategies from a wide range With customization of trading of well-known styles of fund strategies, the opportunities for Summary management, including growth, value, delivering the best execution do not • An evidence-based selection of best market neutral, indexed, etc., a single end here. A close collaboration execution algorithms requires portfolio manager may also use a between portfolio manager, trader and dependable TCA that accounts for multitude of strategies with his own broker can further leverage this the trading environment. Pipeline distinctive investment style and skill. comprehensive body of knowledge by attends to this need with an Typically, orders originating from long- determining the specific benchmarks, enhanced TCA that identifies term strategies may create the goals to be met and then refining separately all sources of trading cost opportunities for tactical trading, the design of execution strategies and lays the groundwork for optimal whereas orders more focused on accordingly. trading strategy design. short-term returns usually require • Assessing potential alpha loss is at more aggressive trading, early on or at the core of the daily trading decision later stages of the trade. As a result, Pipeline’s post-trade analysis enables process, but quite challenging when the order flow sent to the trader is dynamic strategy performance the sources of order flow are very very diverse in terms of short-term evaluation and fine-tuning diverse and not fully understood. alpha loss profiles and that may Pipeline’s comprehensive TCA is not Post-trade quantitative analysis can require very different execution limited to the validation of trading provide validation to the selection of strategies. Although some orders are strategies; it also provides all the limit prices and trading schedules sent with very specific instructions necessary information to identify with immediate insight into the alpha and goals, there are still many cases opportunities for fine-tuning each characteristics of the order flow. where the trader has considerable strategy. Gradually, some drivers may • Pipeline’s Alpha Pro uses this discretion. A quantitative post-trade lose importance whereas others may knowledge to direct each analysis such as Pipeline’s can help become more relevant and, as a distinguishable trade profile into its the trader do a better job by providing result, trade profiles may also change. best-fitting scheduled trading detailed information on the short-term Short-term alpha loss is one of the strategy. Alpha Pro strategy design alpha loss profiles that characterize components of implementation is dynamic as it capitalizes on each portfolio manager’s investment shortfall that is estimated to validate recurring, forward-looking TCA. style. Each alpha profile is associated trade classification and determine with specific trade arrival settings of whether characteristics of the order order creation time, order size, market flow have changed or remained the capitalization etc., which comprise the same. Execution performance is set of relevant predictors. evaluated not only in terms of market
  • 12. Elec&Algo Report_2010.qxp 9/10/10 10:00 AM Page 12 SEPTEMBER 2010 WALL STREET LETTER ELECTRONIC & ALGO TRADING REPORT Multi-Asset Algos Eye Bigger Stage By Corrie Driebusch The marriage between options and equities has flourished in the multi-asset class algorithm arena, and now the industry is looking forward to offerings that are next in line. Both buy-side trading firms and sell-side algorithm providers expect some growth in multi-class algorithms, specifically in foreign exchange and futures in the next year or two. Currently the most popular multi-asset class algorithms remain Harrell Smith, head of product strategy at Portware, said the options- and equity-tied algorithms. “Options and equities are a slow pick-up in multi-asset algos beyond options has been an issue natural marriage,” one hedge fund manager said. Goldman of lagging demand. Nevertheless, funds Sachs, Barclays, Jefferies, ITG and Knight Capital Group all offer that trade globally are driving demand for pairs trading strategies that tie options and equities. For instance, algorithms that can handle foreign Knight’s two offerings are a delta-neutral, or delta-adjusted, exchange. Smith noted that in addition to strategy and a volatility offering. The former allows a client, options, FX algos are also viewed largely typically a convertible arbitrage hedge fund, to execute an option as “useable” for algorithmic trading. at a particular delta while simultaneously executing a delta hedge Portware already has a suite. Hitesh Harrell Smith in the underlying equity. Volatility algorithms allow traders to Mittal, head of liquidity management at purchase an option at a particular volatility regardless of price Investment Technology Group, said ITG has focused a lot of its while purchasing the underlying security at the same time. energies on its algorithm that incorporates equities and foreign Joe Wald, managing director at Knight, noted that these exchange for stocks listed on both the Toronto Stock Exchange time-saving tools have proven incredibly important in an and either Nasdaq Stock Market, NYSE Amex or the New York especially fragmented market. “You’re Stock Exchange. ITG is looking at whether to launch similar trying to maximize alpha that is heavily algorithms between other marketplaces, such as Europe. dependent on executing both legs of the Mittal also sees futures, a natural hedge for equities, as strategy—if you’re wasting time or another potential asset class to be embraced by algorithms. “It inefficient on getting the hedge on, makes perfect sense to me to do [a futures and equities trade] in you’re really giving up alpha there,” he tandem versus one guy yelling over to another guy across the explained. One New York-based hedge room,” Mittal explained. “It’s an obvious one the market should Joe Wald fund manager who trades both equities move very quickly to.” In May ITG rolled out equity index futures and options agreed, saying the only multiple-asset class trading capabilities in its portfolio algorithm Dynamic algorithm he uses is a delta-hedge strategy. “It’s not very sexy, Implementation Shortfall. Mittal said it wasn’t based on client but it’s widely used,” he noted, adding that he is not looking for demand, rather a belief that this is the next step for the industry. other algorithms at this time. “We see this growing in the future,” he said. 12 ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
  • 13. Wall Street Letter is the only paid news service that brings you up-to-the-minute coverage of what’s happening in institutional trading, advances in electronic trading—including algo’s and dark pools— high-frequency trading, exchanges and alternative platforms. Whether you trade, or provide trade-related services at an investment manager, hedge fund, proprietary Wall Street Letter provides the critical market intelligence on what the latest developments in trading and operations mean to you—and why. Other publications may report on new technology and processes; only Wall Street Letter consistently delivers the perspective from the are responding to daily changes in how, where, and why they route, track, and clear their trades. Fully searchable PDF archive of past issues going trading strategy, regulatory issues and market back to 2001 structure issues you don’t miss key headlines 24/7 live news updates via the website – News is posted as it happens www.wallstreetletter.com 1-800-715-9195 for immediate access. WSL booster color.indd 1 9/9/10 6:17 PM
  • 14. Elec&Algo Report_2010.qxp 9/10/10 10:00 AM Page 14 SEPTEMBER 2010 WALL STREET LETTER ELECTRONIC & ALGO TRADING REPORT The Future Of Anti-Gaming: Where Are We Going? By Jeanene Timberlake The concept of anti-gaming technology and the logic that is used Systems. “In the early days, people talked of penny jumping and to build it is getting more attention these days in light of an front-running.” In the first instance, a specialist, knowing of a large increasingly microscopic focus on trading and market structure. institutional limit order to buy, would buy the same stock for a “Anti-gaming” is the keyword in nearly any conversation that price one penny above the institution’s bid, hoping to move the discusses dark liquidity, high-frequency trading or buy-side algos. price up and create an opportunity to make money back on the Several firms have been quietly perfecting the technology, which sale. In the latter, illegal instance, a broker receives a buy order essentially intends to protect a buy-side order from being picked and before filling the order, places a buy order for the same stock off at a higher price than market realized prices in order to make in a proprietary account; the broker then money on a sale at the NBBO. places the customer order, hoping to push The technology ranges in approach and application, but all the price up to later sell the stock that was works toward the goal of limiting buyside interaction with purchased. predatory sell-side flow. Firms are using post-trade methodologies, Gaming today is more sophisticated in reviewing data on a delayed schedule, but also have added in real- light of the increased use of algorithms and time techniques. Some variations being developed will feature the prevalence of dark pool trading. Mario Giannone monitoring activity at the point of sale and the ability to monitor According to Mario Giannone, head of market surveillance and a for gaming across the market as opposed to looking at activity software developer at Liquidnet, “peeking” is a problem common taking place in a single shop. in pools where trades are negotiated between counterparties. In Already, there are concerns that regulators may try to restrict that situation a buy-side and sell-side member match up, and after gaming activity, though it’s unclear how rules would work. One the buy-side member indicates he is ready to trade, the sell-side factor that would make regulation difficult is that gaming isn’t counterparty is no longer there. “They can see a match and they illegal or unethical, it’s a natural part of trading that traders have know there is someone of size on the other side,” he said, adding to master to a certain extent. “True gaming happens when firms that while once may be accidental, multiple “peeks” often are not. are identifying supply and demand Gamers may also try to test a price by buying little bits of a imbalances in the marketplace and then particular stock at a time to test an institutions limit price and take market action to effect price based on determine the size. Eran Fishler, director of research at Pragma, their assessment, but identifying said one clue is when an institution gets a fill in a dark pool at a supply/demand imbalances and using that price which is higher than the prices realized in the market prior to one’s advantage is the job of every to the fill and after the sale, the price immediately reverts back to Doug trader,” according to Doug Rivelli, ceo of more favorable levels. The danger in both cases is that the sell-side Rivelli Pragma Securities. member may go out to the public market and move the price before going back to the pool to complete the trade, if the buy- NOT YOUR GRANDMA’S GAME side interest is still there. Anti-gaming technology started gaining traction and credibility as more trading moved electronic. Larger institutional orders are the PLAYING DEFENSE typical targets, and the games are not new, according to Henri Since no one expects gamers to go away, the consensus for now seems Waelbroeck, v.p. and director of research at Pipeline Trading to be that the only option is to block the gamers once detected. Firms 14 ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
  • 15. Elec&Algo Report_2010.qxp 9/10/10 10:00 AM Page 15 ELECTRONIC & ALGO TRADING REPORT WALL STREET LETTER SEPTEMBER 2010 are doing this now by combining technology for intraday detection better [than the institution placing the trade]... What I would like to with old-fashioned data mining with the goal of finding trading think is that presumption is fundamentally wrong. No trader patterns, whether within specific dark pools or for specific clients. should resign himself or herself to the idea that others are better Fishler said Pragma studies post-execution data for executions its informed than they are,” he added. That line of thinking is what clients make in the 40 or more venues it provides access to on a daily, started Pipeline on the development path of its Algorithmic weekly and monthly basis. “We want to study [the executions] and see Switching Engine, launched in 2007. It applies the analytical power which destinations play host to gamers. So, we look at the return pre- high frequency traders use to help determine what will happen in and post-fill at the destination,” he said, which is where the firm will a stock to predict a particular algorithm’s performance and notice whether the price reverts consistently. combines that with the institutional trader’s own knowledge of the Pragma monitors a variety of other factors as well to root out strategy being deployed. On top of that, Pipeline recently anomalies. Dark pools with anomalies are blacklisted until Pragma introduced Alpha Pro, which combines a firm’s trading history with can determine whether the anomalies are due to valid market real-time conditions to create a custom strategy for traders. activity or gaming. The answer to that question determines Pragma’s approach will also look to use gamers’ strategy of Pragma’s next step, which can be as severe as deciding not to trying to identify orders. The firm is developing an algorithm that connect to a certain venue any more, although Fishler said in will attempt to detect gaming that is happening relative to the some cases they can target gaming down to the counterparty level. trader using the algo as well as gaming that may be happening Giannone said his firm also monitors historical data that is elsewhere in the market and plan trade executions around that. gathered from 35 different programs that survey his firm’s “Whether I’m trading or not, the next generation will understand systems. “We gather information and look for patterns among our what I am doing and what the market is doing,” said Fishler. members,” he said, noting it takes place on a T+1 basis to monitor Figuring out where gaming is happening outside your own world is for outliers that may occur among members. “If any members are always difficult because you never really know what is happening, doing something much more frequently than the rest of the Rivelli added. This algorithm should go a long way to solving that community [compared to a community benchmark]... we will issue, though he cautioned that these types of strategies should still proactively investigate that,” he added. be used in concert with other detection techniques. In both cases, these historical views are backed up by real-time Liquidnet’s Giannone said his firm is in the process of rolling systems. Giannone noted members of his pool are encouraged to out an enhancement to real-time capabilities that will move complain if they see any type of suspicious activity but the pool also detection to the front-end. He noted that right now, real-time does its own monitoring. “We’re hoping to catch it before a member monitoring will alert the pool operator that suspicious activity has complains, of course,” he said. “If we think it’s a bad trading occurred, tipping off staff to monitor particular activity and protocol, we may even, intraday, block a member from matching flagging the trades for further investigation and possible again. One reason would be to alleviate frustration, but another is disciplinary action. The new capabilities, being developed in- to give time to investigate what happened,” he added, noting that house, will monitor for gaming scenarios that, if engaged, will be enough evidence will earn a permanent suspension for the gamer. acted on automatically. “If someone is breaking protocol, the Pragma’s real-time monitoring and anti-gaming help determine system automatically takes action without investigation,” he said. what activity is happening as part of gaming and what might be a Members engaging in the negative activity would receive alerts real strategy. If it is determined that the activity can be attributed to and the third alert would result in an instant block from trading. a gamer, the firm will stop trading or put limit prices on the trade, a “We would still investigate, but in terms of being proactive, this is move Fishler characterized as the “main tool” for prevention. the Holy Grail.” There is some concern that regulation could be under FROM DEFENSE TO PREVENTION consideration to limit gaming in the U.S. similar to that which Providers don’t have the same concepts in mind when looking at exists in the U.K. requiring pools to provide prevention technology. the future, but there is agreement that one of Operators of global pools would likely be more prepared in that the best tools for the future is to use gamers’ case. Still, the prospect is considered unlikely in the U.S. in light of own techniques to combat them. “Anti- the fact that gaming is still within the rules. “There’s an important gaming technology has developed as differentiation between gaming based on an assessment of defensive mechanisms,” said Pipeline’s supply/demand versus actually knowing [information] and front- Waelbroeck. “The defensive approach makes running it. As long as a trader is taking market risk, it’s difficult to Henri Waelbroeck the assumption that someone else knows regulate a trading strategy,” Rivelli said. ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195. 15
  • 16. Elec&Algo Report_2010.qxp 9/10/10 10:00 AM Page 16 SEPTEMBER 2010 WALL STREET LETTER ELECTRONIC & ALGO TRADING REPORT Buyside Worries Focused On Regulation Reform Regulatory issues have been a growing concern for industry participants of late, including those on the buyside, thanks to the sheer volume of new regulatory activity expected in the next few years. Chief among those concerns are the far-reaching implications of the recently passed Dodd-Frank Act, which touches nearly every aspect of the financial markets and permeates nearly every asset class. The following participants spoke about those concerns and how they’re dealing with it now, as well as their technology issues, how they’re handling volatility and what they want now in response to questions from reporters Meredith Lepore and Corrie Driebusch. FROM THE BUYSIDE is now playing catch-up to this new, quickly changing environment. Right now, I don’t think there is one major concern, but many BASIL WILLIAMS, ceo of Concordia Advisors. Williams oversees smaller issues that the industry is focused on. [For example], the the daily investment and business operations of the firm. Prior to [National Market System] issue. The Securities and Exchange being named ceo, he was president and head of fixed-income Commission is proposing a new Rule 613 that would require trading. Williams began his career at Merrill Lynch. national securities exchanges and national securities associations (self-regulatory organizations) to act jointly in developing a NMS JONATHAN KANTERMAN, managing director at Stillwater plan to develop, implement, and maintain a consolidated order Capital Partners. Kanterman has more than 16 years of investment tracking system, or consolidated audit trail, with respect to the management experience and has worked at firms such as trading of NMS securities. Valenzuela Capital Partners and Woodford Gayed Management. [There is also] the “large trader rule,” which would require high- frequency and other large-volume traders to code their trade tickets JUDITH MOSES, portfolio manager at Evercore Wealth with a unique identifier. Management. Moses has more than 19 years of experience in the For the circuit-breaker issues, we need to help stop flash crashes investment management industry. Prior to joining Evercore, she was and [find] ways to speed recovery if they do occur, bust erroneous v.p. at U.S. Trust, Bank of America Wealth Management and trades when crashes happen, etc. before that she was with the Charter Financial Group. Algorithm flow catching up to phone orders is another issue. The fact that the volume of shares that buy-side traders send to sales desks KEVIN CRONIN, director of global equity trading at Invesco. and to the equities markets using algorithms will soon be the same. Cronin has spent more than a decade at the helm of global trading for Probably the biggest issues are the unknown results of The Dodd- investment firms. He has testified on multiple occasions in front of Frank (Wall Street Reform and Consumer Protection) Act, which the Securities and Exchange Commission on a variety of subjects. grants the SEC an entire array of new powers. The unknown usually results in the most apprehension. STEVE SACHS, director of trading at Diamond Hill Investments. He previously held the same position at SGI/Rydex. CRONIN: It’s not easily contained to one issue—it’s really the whole picture. After the flash crash, you have a number of people trying to rush to judgment on what went wrong and who’s responsible. As I WSL: What is the biggest regulatory concern facing look at the world I can’t help but think the biggest risk for all of us is the industry? to overregulate an environment that’s not today very well-known. KANTERMAN: I think this is one of the most historic times for the For example, look at high-frequency trading. A lot of us have industry, with new levels of technology driving growth, efficiency concerns about high-frequency trading. But there are a number of and productivity, coupled with the resulting need for proper different participants in the marketplace that would be considered regulation. As is traditionally the case, regulatory oversight lags and high-frequency traders and their place in the market is very good. It 16 ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195.
  • 17. ELECTRONIC & ALGO TRADING REPORT WALL STREET LETTER SEPTEMBER 2010 needs to be well-understood and not a rush to judgment to focus is almost post-mortem of how orders are managed. appease some faction of the market that says something has to be done. Many of the things that led us to May 6 are not as easily fixed SACHS: First and foremost are the tools we need to better serve our by putting circuit breakers or disallowing market orders. shareholders. A big driver of [technology changes] is also responding to market structure—how we’re forced to trade these days versus MOSES: While the recently passed Frank-Dodd Bill will certainly have days in the past. The fact is there are 40-plus execution venues out a far reaching and, at this point, indeterminable impact on the there where a stock may or may not trade. financial services industry, of immediate concern to those of us in Given that, and given the short-term noise in wealth management is the uncertain tax regime. It is a challenge to the market, and given the illusion of liquidity make investment decisions when one doesn’t out there, most of what we’ve done is getting know what the capital gains or dividend tax better tools to find the liquidity we need to rates will be next year. Will Congress allow make transactions. We can trade 4-5 billion President George W. Bush’s tax cuts to expire, shares of volumes in the markets in a given Steve Sachs in which case our clients will be looking at a day but I don’t think [the markets] are any possible dividend tax rate of 39.6%? I have more liquid than they were years ago. If anything they’re less liquid; heard numerous possibilities being discussed, the depth of book has disappeared. What we need is a tool set to Judith Moses including dividend and capital gains rates of connect anywhere and everywhere and to be able to monitor how 20%, 25% or 28%, an extension of the Bush tax cuts for one year, our tools are doing in those marketplaces, what sort of gaming is taking place. keeping the tax cuts for those earning less than $250K, etc. There is the same uncertainty with regard to estate taxes. MOSES: Technology is an integral part of our business and advances in technology have made it possible for us to easily invest in all WILLIAMS: For certain operators in the hedge fund arena, SEC asset classes, equities, fixed income, currencies, options, futures, registration is a burden. A less certain question is bank capital etc. Technology has lowered transaction costs and improved price requirements and the lending activity of alternative asset managers. discovery and liquidity to name a few benefits. But we have also What will requirements mean to banks and bank clients? seen some of the negatives of technology as evidenced by the flash crash in May. SACHS: I think we’re at a point where the pendulum has swung way Now that the majority of equity [trading] is done electronically, too far and we need a complete overhaul of our financial system. off the exchanges, there are not designated market makers whose For the last five years since [Regulation] NMS we have moved to a responsibility is to provide an orderly market in stocks. One can see market structure that no longer serves the fundamental investor. how a disorderly situation could occur if participants in electronic The market is full of tactical trading strategies. My biggest concern is exchanges who typically provide liquidity, but are not required to, a lot of one-off solutions, from the uptick rule to circuit breakers. step back from trading and liquidity disappears. Our responsibility We need to take a step back and take a look at the whole market. to our clients is to use technology to help us construct and manage The SEC is beginning to do that with the concept release, but now well-diversified portfolios while minimizing transaction costs. In what happens? Will there be follow through? addition, we must protect and manage the risk that advances in technology pose to our clients’ portfolios. WSL: What type of technology issues are you focused on right now? KANTERMAN: I think the biggest issues right now stem from the CRONIN: We don’t fashion ourselves as high-frequency. Our time uncertainty. Companies don’t want to spend on new technology horizon is not six seconds. We’re not trying to solve for pico- or and services until they have more clarity on the regulatory and nanosecond. But on the other hand, because the market has compliance issues in the pipeline. Most of the industry is in a become comprised of so many of these picosecond and holding pattern until they know exactly what will be needed. Then nanosecond participants, we have to understand well how this arms there will be a wave of spending on new technology and upgrades race is going to play out. We have to understand how our orders are to match the new landscape. These types of dramatic changes and being handled. [For instance, what happens] if we send an order to advancements happen every 10-15 years. one place [that] subsequently sends it to another place that subsequently sends it to another? Who can see those orders and WSL: What’s your take on recent market volatility and what potential information leakage can be from that? [We need to how it is affecting your business? know] how technology works with respect to transaction cost in WILLIAMS: It has been good for our business. We are looking to particular, and also in terms of what dark pools we can go to. The trade relative value, so when there are high levels of volatility, there ©Institutional Investor News 2010. Reproduction requires publisher’s prior permission. To receive email alerts or online access to Wall Street Letter, call (800) 715-9195. 17