Catching Complex Cross-Product Abuse Calls for a Trading Floor Mindset

By Mike Coats, CTO, TradingHub

In the analog days of trading, regulators were concerned with finding instances of the good old-fashioned pump and dump, insider trading, or market timing schemes. But digital transformation has reimagined the entire financial system, and while some bad actors have simply digitized legacy forms of market manipulation, most have used technology to originate new, more intricate forms of abuse. For banks, this means that the trade surveillance problem is now more complicated than ever before.

Regulators turn a keen eye to the cross-product problem

As markets have become more complex and interconnected, the potential for illicit activity has expanded. This is especially true when it comes to the opportunity for market manipulation presented by ‘cross-product’ trading patterns – correlated activity that spans multiple asset classes and trading venues, often across both lit and OTC markets. But no matter how complex this trade surveillance problem is, regulators expect market participants to have a handle on it. We can see this message clearly in the large number of enforcements in this space in recent years.

Despite the capital markets industry investing heavily in compliance and surveillance capabilities in the hopes of avoiding regulatory hot water, recent high-profile fines against Bank of AmericaJPMorgan ChaseNatWestHSBC, and others, indicate that these efforts are falling short.

So why is cross-product abuse slipping through the gaps of some banks’ preventative systems? And what can be done to safeguard against the huge financial and reputational risks of regulator action?

Operating cross-product and cross-venue

The truth is that the market abuse problem is a web that’s spread across the entire capital markets. Today, virtually every sell-side trading desk makes money by employing cross-product strategies, often laying off risk arising from illiquid client-transactions with benchmark or listed products. Trading floors approach their activity by thinking in terms of ‘market risk’, and as such they trade across a variety of securities, products, and venues to manage that market risk, while calculating the relationships between various assets.

This means that taking a single-venue or single-instrument approach to trade surveillance – which is the default at a lot of banks – is no longer sufficient. These systems aren’t equipped to identify the instances of abuse which present the highest regulatory risk, because they’re not looking at the cross-product picture. Because today’s riskiest forms of market manipulation are happening across various interconnected places that traditional approaches are not capable of spotting, banks are left with costly blind spots.

Surveillance models now need to understand the relationships between instruments so that they can assess pricing impacts to indicate the intent behind any trading pattern. Buying one instrument and selling a related one – albeit elsewhere on the markets – is a position in the spread between the two, not two independent positions, so looking at any transaction independently misses the full picture.

An interconnected web

For example, in fixed income a nefarious trader might use a series of trades in a liquid instrument like government bonds to move the price of a much less liquid instrument like certain over-the-counter (OTC) derivatives. Many fixed income products are interconnected, therefore effective surveillance must consider trading activity in correlated products — such as cash vs. futures, or products with different durations.

Every single bond from government to corporate, and every single product from bond futures to swaptions are expressions of interest rate risk. This means they will manifest significant correlation in their price evolution. These ever-present relationships between different instruments are the very reason that traditional trade surveillance methods have proven inadequate to police such complexity.

What’s more, because trade surveillance approaches are so out of date based on today’s markets, any bank monitoring trades in isolation is now going to be dealing with an onslaught of expensive false alerts. This monopolizes a compliance team’s time, yet the bank will remain incapable of capturing the severe cases of wrongdoing because the cross-product picture is not being accounted for or it’s lost in the pile of false positives.

Rules-based efforts are futile

Traditional trade surveillance systems are using rules based approached to detect instances when a trader is trying to artificially move the price of an instrument to his or her advantage by executing trades or placing and then cancelling orders.

This approach reflects more straightforward equities abuse detection tactics and has resulted in institutions deploying technology platforms that flag every potential instance of manipulation based on lengthy, rules-based taxonomies that can include 60-70 or more categories of market abuse types. The result is an unmanageable deluge of alerts that flag any potential instance of market price movement – which costs millions of dollars just to investigate.

Yet despite most trading desks operating using cross-product strategies today, only one of those 60-70 categories is likely to be a row labeled cross-product abuse. This implies that cross-product abuse is still a rare and niche risk, instead of one of the most common market manipulation strategies that it has become today.

A different surveillance POV: using a trading floor way of thinking

There is no question about it – trade surveillance must adapt. And this adaptation cannot take the shape of simply bolting on additions to chronically unperforming legacy technology. To truly protect against the costly fines and reputational damages of regulatory action, the entire system must be reoriented to reflect how traders actually think, behave, and trade today.

Trade surveillance systems must think in the same way that those on the trading floor do: in terms of risk sensitivities, not rules. A bond and a bond future are basically the same expression of risk, although they might trade in a different way, over a different venue. In both cases, by buying or selling this product a trader is forming an opinion on what’s going to happen to interest rates.

Trades in different instruments are, in most cases, likely to form part of the same abusive strategy, so rather than treat them individually, a surveillance system must intelligently group them together.

Asset classes which require risk-based methodologies like OTC derivatives or fixed income products, are impossible to monitor using traditional surveillance methodology. But thinking in terms of holistic market risk can map how a trader’s positions across a combination of instruments and across a series of maturities are all linked, thereby determining the intent of a behavior and whether manipulation is likely to have occurred.

Market-risk models are able to put the trader’s mindset at the forefront to enable surveillance teams to capture hidden signals that traditional trade surveillance systems are blind to.

This approach not only reduces false positives dramatically, but it enables compliance teams to focus their resources where they really matter to protect against the growing reputational, financial, and legal risks of the most prevalent market manipulation types today.

It’s time to expand the trade surveillance lens

Our industry has built trade surveillance by thinking rules upwards instead of market risk downwards, resulting in the worst kind of complexity.

It’s like trying to spot a shooting star by looking through a keyhole – you’re not likely to see it, because you’re not looking at the whole sky. Now is the time to reimagine the trade surveillance approach so that banks can significantly expand the lens they’re looking through and capture the alerts which genuinely demand their attention.

Shining Light on Liquidity Lamp

Last week, Exegy added intraday signals to its AI-powered iceberg order detection offering, Liquidity Lamp. The enhancement provides quantitative traders with visibility on the volume of iceberg orders throughout the day using summary files delivered every ten minutes.  

Andy Lee, Exegy

Traders Magazine spoke with Andy Lee, Director of Quantitative Research at Exegy, to learn more.

What is the background of Liquidity Lamp?

Liquidity Lamp first came to market in 2020, as a real-time product for customers who consume data via the Exegy Ticker Plant.

Liquidity Lamp is originally a product that detects when a reserve order is found on US equity markets. Once we find it, we can track it in the order book and also the price book. But a lot of customers came to us and said, “Is there a way that a mid-frequency, or even a low-frequency product can be derived from that HFT signal?” That’s when we came out with our initial end-of-day product. 

The end-of-day product basically provides a summary by tracking the reserve orders. It allows us to note that a particular order was traded against at this exchange for this symbol at that time of the day, and we can roll that up and tell customers really easily what symbols, how much volume, and how much notional value was traded on any given day.

That product really galvanized Liquidity Lamp, because it was the buy-side firms that were looking for alpha and looking for unique, differentiated data sets that were uncorrelated to anything they were already working with. So that’s the storyline of how Liquidity Lamp became a success. 

What is the essence of the new offering?

This new product bridges the gap between the real-time product and the end-of-day product. We had been thinking, “Is there a way we can deliver the customer the same end-of-day summary file that’s easily consumable, but every 10 minutes instead of end-of-day so they can action something when it’s most tactically opportunistic rather than having to wait until the next day?” This is the answer.

Who are the core users of Liquidity Lamp? 

It’s quantitative, systematic funds that are looking for statistically significant data points and using Liquidity Lamp in AI and in their models. Other users would be stat arbs, mid- to low-frequency intra-day traders, and multi-day traders. The product is not geared toward fundamental investors.

Do you expect some customers who use the end-of-day product to switch to this new product?

People have different objectives. Some customers have strategies that involve accumulating information across multiple days, weeks, and months, rather than intra-day; they will still be happy with the end-of-day product. But other customers want to deploy this more on an intra-day basis. They may see a large iceberg order trade in a given name, and they want to take advantage of that information intraday, because that information may not be helpful tomorrow. So it just opens up the opportunity for new and more strategies to use this, versus the end-of-day.

Comparing Liquidity Lamp real-time with every 10 minutes and end of day, what is the difference in ‘lift’ from the user’s perspective?

Real-time is infrastructure-intensive – you need to purchase a ticker plant and consume full-depth market data feeds. End of day is the opposite – we just give you an AWS [Amazon Web Services] free bucket to grab the data files from, which you can do with commercial internet access on your laptop from the basement of your home.

The new intraday product has some infrastructure necessary because it is consuming real time market data, but it’s mostly distributing out to AWS. It’s a hybrid approach, but we take up a lot of the infrastructure cost and try to make consumption very easy for customers.

What’s the most important takeaway from the associated whitepaper?

One point is that we had some early adopters of Liquidity Lamp come back to us and say this is beneficial as a creative product to our existing P&L. Meaning, instead of creating brand new alpha, what it does is enhance our existing strategies. That was the draw.

Because of that draw, in the whitepaper, we took the early adopters’ approach. We said, “Let’s design a basic, plain vanilla stat arb strategy and then inject that baseline model with Liquidity Lamp information to see if it creates a better portfolio, a better strategy.” 

And that’s exactly what we found. It reduces draw downs, it increases returns, it increases your Sharpe ratio and beats the S&P 500 on a relative basis, but it also defeats the baseline stat arb model on an absolute basis, which we were really pleased about.

Final thoughts?

We’re not traders at Exegy. From a customer perspective, that is an important consideration.  Rather, we’re trying to take tools that are closely guarded at most HFT shops and democratize those signals so that more people can access this information to create their own alphas and improve their strategies. 

DTCC Advances Pilot to Further Automate Corporate Actions Announcement Process

The pilot is expected to run through the end of 2024 and will introduce greater levels of automation in sourcing Corporate Actions announcement data.

New York/London/Hong Kong/Singapore/Sydney, March 6, 2024 ‒ DTCC, the premier post-trade market infrastructure for the global financial services industry, today announced a pilot to further automate the corporate actions (CA) process, delivering new efficiencies and capabilities that address decades-long asset services challenges around the sourcing of corporate actions announcements.

The pilot, which includes two phases, aims to streamline interactions across the Agent and Issuer community by standardizing and automating the sourcing of corporate actions announcements, eliminating manual processes, providing cost savings, reducing processing lead time and mitigating risks.

Phase 1 of the pilot, which was completed in December 2023, tested new inbound automated messaging for Issuers and Agents. As part of this successful test, DTCC provided messaging capabilities modeled on the ISO 20022 standard that enabled an Agent to submit an automated announcement to DTCC. DTCC was then able to automate the processing of that announcement through its system and generate an ISO 20022 corporate actions announcement to its client in a test environment. The messaging solution removes current manual processes and caters to Agents with large event volumes or those looking to send events with large numbers of assets or event notifications.

DTCC plans to launch Phase 2 of the pilot with a scheduled test release in Q3 2024. In this phase, firms will test a modernized Corporate Actions GUI portal. The new portal will provide an easy-to-use interface for Redemption event types, such as Partial/Full Calls and Maturities, which Agents and Issuers can use to transmit accurate and complete announcement event information. The aim is to provide Agents and Issuers with the ability to transmit standardized event information via a modernized interface, increasing accuracy, removing manual validation processes, and eliminating delays to the industry.

“As the global financial industry becomes increasingly more complex, we see tremendous opportunity for increased automation and modernization within the corporate actions space. We are pleased to deliver this pilot, in direct response to client and industry feedback, to bring long-needed automation and standardization to the critical event notification process – increasing efficiency and accuracy,” said Ann Marie Bria, DTCC’s Managing Director, General Manager, Asset Services.

The pilot follows DTCC’s recent paper, “Automating the Sourcing of Corporate Actions Announcements from Agents and Issuers,” which highlighted that almost half (46%) of corporate action global event data is still published and received manually, according to data from SIFMA’s Operations & Technology Committee and Ernst & Young LLP. Because the validation of the information between Issuers, Agents and DTCC is currently manual in nature, it can delay the dissemination of important data to clients and, ultimately, the beneficial owner. In its work to further automate the Corporate Actions process, DTCC worked with S&P Global Market Intelligence and other large firms in the financial services industry.

“After the successful completion of phase 1 with DTCC, we welcome their continued collaboration with the industry to proactively initiate phase 2 of the pilot. Leveraging our proven experience from diverse markets, we are thrilled to contribute to advancing efficiency and innovation in the dynamic US markets by automating issuer and agent interaction for CA announcements,” said Bidhu Rusia, Director of Corporate Actions, S&P Global Market Intelligence.

“Ultimately, our goal is to revamp the end-to-end corporate actions event structure to more efficiently capture source data and provide a more reliable, sustainable, and secure foundation for the future processing landscape,” Bria said. “We look forward to working closely with our key stakeholders to drive improvements to this important area, and we welcome additional firms to join our pilot.”

About DTCC

With 50 years of experience, DTCC is the premier post-trade market infrastructure for the global financial services industry. From 20 locations around the world, DTCC, through its subsidiaries, automates, centralizes, and standardizes the processing of financial transactions, mitigating risk, increasing transparency, enhancing performance and driving efficiency for thousands of broker/dealers, custodian banks and asset managers. Industry owned and governed, the firm innovates purposefully, simplifying the complexities of clearing, settlement, asset servicing, transaction processing, trade reporting and data services across asset classes and bringing increased security, enhanced resilience and soundness to financial markets. In 2022, DTCC’s subsidiaries processed securities transactions valued at U.S. $2.5 quadrillion and its depository subsidiary provided custody and asset servicing for securities issues from over 150 countries and territories valued at U.S. $72 trillion. DTCC’s Global Trade Repository service, through locally registered, licensed, or approved trade repositories, processes more than 17.5 billion messages annually. To learn more, please visit us at www.dtcc.com or connect with us on LinkedInXYouTubeFacebook, and Instagram.

24 Exchange Aims to Launch National U.S. Equities Exchange

24 Exchange, a multi-asset class trading platform, has recently submitted an updated Form 1 application to the U.S. Securities and Exchange Commission (SEC) for a license to create a new national securities exchange.

If approved, this new U.S. equities exchange, 24X National Exchange, will be the first fully electronic exchange in the U.S. that allows around the clock trading of securities.

Dmitri Galinov

According to 24 Exchange CEO and Founder Dmitri Galinov, 24X National Exchange would facilitate around-the-clock trades in U.S. equities for retail and institutional traders anywhere in the world via broker-dealers, who are registered members of the Exchange. 

Speaking on the rationale behind the launch, Galinov said that traders are most at-risk when the market is closed in their geographic location, adding that 24 Exchange will eliminate this problem by offering around-the-clock retail trading.

“We believe 24X National Exchange will attract U.S. and foreign companies and investors to list and participate in the U.S. market,” he told Traders Magazine.

According to Galinov, the timing for the SEC’s review and approval decision will be determined solely by the agency. 

“We would plan to launch our new exchange as soon thereafter as possible,” he said.  

“If approved, 24X National Exchange will enable any institutional or retail trader to benefit from the proven stability and cost efficiencies that only 24 Exchange can deliver,” he added.

Galinov further said that if granted a license by the SEC, 24X National Exchange would represent the highest levels of regulatory scrutiny and oversight – as well as of investor protections, resilience and quality – that a global equities trading platform could achieve.

“24X National Exchange will reduce risk by making a regulated exchange available to trade around the clock with appropriate controls that were developed in close coordination with the SEC,” he said.

24X National Exchange, if approved for a license, will work like a regular exchange, while also enabling participants to trade U.S. securities, including those with unlisted trading privileges (UTP), via broker-dealers who are registered members of the exchange, Galinov said.

“In addition, the new exchange would be a good venue to facilitate cryptocurrency ETF trading among other instruments,” he said.

Regulated by the Bermuda Monetary Authority, 24 Exchange currently offers FX NDFs, FX Swaps, and FX Spot trading.

“We believe adding a U.S. equities exchange to our company’s range of FX offerings would create major new opportunities for exchange participants, and their institutional and retail customers around the world,” Galinov said.

He added, that if approved, 24X National Exchange “would run on a proven, state-of-the-art technology platform provided by MEMX”.

“To accommodate routine industry IT needs such as software upgrades and functionality testing, we plan to implement brief trading pauses on the new exchange: one hour trading pauses on business days, Sundays and holidays, and a three-hour trading pause on Saturdays,” he said.

SGX FX Roundtable Assesses Macro Trends, Market Issues, Election

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The big picture was in focus at a recent Singapore Exchange (SGX Group) dinner discussion in New York.

The Feb. 22 event included a keynote address and a panel discussion, covering global macro trends, critical market issues, and outlook for the US presidential election in November.

KC Lam, SGX
 KC Lam, SGX

SGX’s Global Head of FX and Rates, KC Lam, was one of the hosts of the roundtable, kicking off the session with a discussion of the exchange’s Asia product suite across equities, currencies and commodities. Amid turbulent interest rates, inflation and geopolitical risks, there has been increased hedging across SGX’s major Asian currency pairs as yield differentials widened. Activity was particularly pronounced for SGX USD/CNH Futures, which has leapfrogged to become the third most-traded listed FX contract globally.

David Woo, CEO of David Woo Unbound, an independent global macro strategy boutique that focuses on the intersection of economics, politics, and geopolitics, presented keynote remarks virtually.

Formerly a Wall Street strategist and International Monetary Fund economist, Woo observed the macro landscape has mostly been two or three good years to one bad year over the course of his 25+ year career, but lately that has been closer to one bad year for every good year. “Macro challenges are becoming more complex,” he said.

Woo relayed an anecdote where a Wharton School professor recently pitted MBA students against ChatGPT in a competition to develop commercially viable products that could be marketed to students for $50 or less. ChatGPT had 35 of the 40 top products as picked by product evaluators.

“Generative AI is huge,” Woo said. “It’s the biggest dollar growth story since US energy independence. It’s very bullish for the US,” he said, noting that 95% of the top AI providers are US-based, as are most early adopters of AI.

 David Woo

With regard to monetary policy and interest rates, Woo said he has been short bonds, but he’s now considering a long position. He cited three reasons for this: recently high levels of government spending are not sustainable; recently low energy prices are reversing course; and the geopolitical risk premium remains elevated.

The US presidential election in November also looms. “The closer the race, the more risk implied for the market and for the economy,” Woo said, adding that he expects a significant slowdown in the third quarter as concerns about political stability come to the fore.

The SGX event drew a good mix of some 40 senior participants from the sell-side, macro-hedge funds, systematic funds, commodity trading advisors as well as trading firms.

Impact of US economy and election risks on the dollar

Michael Zolandz, Dentons
 Michael Zolandz, Dentons

The keynote was followed by a panel discussion with Thierry Wizman, Managing Director, Global Interest Rates and Currency Strategist at Macquarie Group, and Michael Zolandz, Managing Partner at Dentons Washington DC. Bill Gulya, Head of Americas at SGX Group, framed the discussion weaving together a narrative on global macro and US politics, both of which will have an impact on Asian economies in the years to come.

Zolandz offered an overview on the upcoming US presidential election, which is expected to be a rematch between Democrat Joe Biden and Republican Donald Trump.

He said the Democrats are playing not to lose, which is “fundamentally a bad strategy, but it might be enough” in a race between two candidates with historically low approval ratings.

One demographic that could prove critical in the election are suburban women in key swing states. This core group of likely voters have proven decisive in recent elections, and are a critical demographic that both candidates will seek to influence heading into November.

Zolandz highlighted the four top election issues as the economy and inflation, which is a “tossup variable”; immigration and the border, a still-unsolved problem that favors Republicans; foreign interventions, for which Republicans hold a slight advantage; and the notion that democracy itself is on the ballot, which favors Democrats.

The election “will be closer than people think,” and it may come down to which side has the better ground game, traditionally a Democratic strength but an area that Republicans have recently made ground.

Thierry Wizman, Macquarie Group
 Thierry Wizman, Macquarie

Macquarie’s Wizman cited the important and surprising economic theme of the US economy continuing to outperform Europe and China. “We expected a weaker dollar this year, but that hasn’t happened,” he said. “No data suggests that the US has slowed down versus the rest of the world.”

One prominent factor for the US economy over the past couple quarters has been AI-fueled productivity gains. This productivity is likely to be inflationary in the present as higher output leads people to anticipate price increases, possibly influencing Federal Reserve decision making.

“The Fed may think it doesn’t need to cut that much, so as to not let that belief promulgate in the economy,” Wizman said.

Recordkeeping Takeaways from FINRA Regulatory Oversight Report

By Harriet Christie, COO, MirrorWeb

The Financial Industry Regulatory Authority (FINRA) recently released its annual regulatory oversight report for 2024. This has been shared to provide firms with key insights and observations from the regulator’s recent operations, with the aim of improving transparency and strengthening compliance programs for businesses in the finance sector. 

Alongside topical focuses around the use of artificial intelligence and the shifting state of cybersecurity, recordkeeping requirements also continue to evolve alongside modern technology. Below, we’ll look at the key recordkeeping takeaways.

Off-channel communications

The report indicates that FINRA uses a risk-based approach to review how firms manage business-related communications. It acknowledges that with off-channel platforms and devices, there is clearly far greater risk that records won’t be maintained. Reference is made to the SEC fines administered across the industry from 2021 to 2023, where they indeed were not.

While off-channel communications can occur on any tool that hasn’t been approved for business use (email and instant messaging platforms for example), mobile correspondence undoubtedly accounts for a significant proportion, largely due to its convenience of use, immediacy, and availability outside working hours.

 In the report, firms are asked if their electronic communication policy includes …

  • Procedures to maintain, preserve and monitor all business-related correspondence by staff, including those via off-channel methods.
  • Processes to monitor for new channels available to customers.

Rather than simply expecting employees to follow protocol, the surveillance element is now more pronounced, and compliance teams are expected to do the detective work to understand the landscape and make sure employee conduct is above board. FINRA directly recommends that firms surveil…

  • Whether approved channels are underutilized, signifying that alternatives are being used.
  • Their approved channels, for ‘indicia of communications occurring off-channel’, ie references to other conversations on unsanctioned domains

The last point could come in the form of email chains that copy an email address from an off-channel domain, or suggestions that recipients should interact elsewhere, away from scrutiny.

Firms are also asked to consider what corrective/disciplinary measures are in place for advisers that do go rogue and breach policy. Traditionally, companies have paid the price for employee misconduct, and so FINRA is encouraging deterrents to be established for individuals.

Public-facing Communications

Like the SEC’s Marketing Rule, FINRA Rule 2210 (Communications with the Public) encompasses electronic communications, and so websites and social media channels are held to the same standard as written brochures, TV advertisements and indeed emails.

FINRA reminds firms of their obligation to present information that is accurate, balanced, and not misleading; by sharing the associated risks of a product/service alongside its benefits, for example. This ties in significantly with developments around the use of AI for content creation purposes.

Artificial Intelligence

FINRA explicitly classifies AI as an ‘emerging risk’, recommending that firms consider its pervasive impact and the regulatory consequences of its deployment.

When you break down the ways in which marketers can leverage ChatGPT, for example, it becomes clear how effective the tool has become. Not only can it draft social media posts and website copy, it can also optimize them based on SEO, trending keywords, or other relevant metrics. This saves marketers an incredible amount of work, and will tempt stretched workforces in need of a lifeline.

Unfortunately, those teams might not be equipped to check the generated output thoroughly, which is especially problematic in the context of chatbot ‘hallucinations’. Without the correct checks and amendments, a brand’s tone of voice and clarity of messaging can be compromised. More worryingly, so can its factual legitimacy.

The SEC has already clarified that advisers themselves are responsible when issues arise after AI tools are used for investment recommendations. FINRA shares many of the same uncertainties. On a podcast dissecting the 2024 report, Ornella Bergeron, FINRA senior vice president of member supervision, said that despite the operational efficiencies afforded by developments in AI, there are worries.

“While these tools can present really promising opportunities, their development has raised concerns about things like accuracy, privacy, bias and intellectual property.

“So far, firms are being very cautious and thoughtful when considering the use of AI tools, and before deploying new technologies,” Bergeron said. “So while for this year’s report there was not a lot in the AI section by way of specific roles or observations, this is likely a topic we’ll be seeing a lot more about in the future.”

In Summary: A Shift to Surveillance

Off-channel and public-facing communications have been on the regulatory agenda for some time now, and FINRA’s 2024 report reiterates these concerns. 

By providing probing questions for firms to ask themselves, it will help highlight the inadequacies and blind spots that led to industry-wide recordkeeping shortcomings in the first place. And by prescribing procedures to uncover and root out the use of unauthorized channels, the regulator has shown a genuine desire to put a stop to it, or for firms to find new ways to handle the situation compliantly.

Communications archiving providers can now capture and record data across the traditional ‘off-channel’ platforms (WhatsApp, WeChat, Telegram). They are also increasingly developed to tackle the surveillance piece of the puzzle; by applying lexicon policies to flag specific wording, for example. This would negate the need for unrealistic platform bans, and ensure that illicit activity is quickly uncovered.

While a lot of the report’s content feels familiar, FINRA has also shown that they’re alive to new developments, and particularly the latent carnage that artificial intelligence could bring to proceedings. In a world where algorithms can follow a prompt but might state a few fictions in the process, digital accountability is of paramount importance. FINRA, like most regulators, is treading carefully.

TECH TUESDAY: Financial Market Infrastructures Eye Regulation in Move to Cloud 

TECH TUESDAY is a weekly content series covering all aspects of capital markets technology. TECH TUESDAY is produced in collaboration with Nasdaq.

Financial market infrastructures (FMIs) have been adopting cloud technology for a number of years, to tap into advantages such as agility, scale and cost savings. As the migration continues and more critical workloads are entrusted to cloud service providers (CSPs), regulatory engagement will be vital.

FMIs that utilize CSPs are subject to stringent regulatory requirements. They must know the exact delineation of responsibilities on a service-by-service basis; methodically evaluate which CSPs and services to use; and structure and manage their relationships with CSPs to ensure that their service utilization is compliant with applicable regulations. That’s according to a recently published Nasdaq whitepaper, Planning for Cloud: Regulatory Considerations for FMIs When Choosing a Cloud Service Provider

As cloud usage has expanded among exchanges, central counterparty clearing houses (CCPs) and central securities depositories (CSDs), so has regulators’ interest in the technology, and its implications for market stability and serving the interests of end-user investors. 

Capgemini cited “magnified supervision from financial regulators across the globe” in a 2023 thought leadership piece published on Forbes. The IT services and consulting firm highlighted specific initiatives such as the Digital Operational Resilience Act (DORA) in the EU, recommendations from the Bank of England, guidance from various US regulators including FINRA, and principles set forth by the Monetary Authority of Singapore.  

More broadly, Capgemini stated: “Key stakeholders in the modern cloud ecosystem … are likely to be challenged by the evolving regulatory supervision and expose their internal barriers to change. In the long run, though, these initiatives will not only be seen as a compliance exercise but as an accelerator to strengthen operational resilience and develop differentiated capabilities in cloud technology and services.”   

As cloud regulation takes shape globally, FMIs, from their nexus position, can lead on collaboration and alignment between regulators, internal stakeholders, and CSPs. Embracing this challenge as best practices can optimize the benefits of cloud today, while modernizing for a future-proofed tomorrow. 

The Nasdaq whitepaper highlighted components of the regulatory process, starting with stakeholder alignment, initial regulatory assessment, and vendor assessment. From there, key solution considerations include security (physical, data, and infrastructure); resilience and business continuity planning; governance and control; exit strategies; fairness; data sovereignty and integrity; and incident management.  

“The accelerating technical evolution and innovation in cloud (e.g., AI/ML) will continue to make service utilization a significant area of consideration for FMIs,” the whitepaper stated. “Finding the right CSP vendor will help FMIs accelerate their transformation while still maintaining the necessary guardrails, putting them in a position to lead the industry and seize new opportunities, knowing they have a detailed framework bought into by CSPs and regulators.”

“Over time, we expect continuous CSP investment in infrastructure, infosec and adjustments to FMI and regulators’ requirements,” which paired with the development of industry best practices “ideally will create a pathway to long-term decrease in costs and risks associated with compliance when utilizing service providers.”  

Creating tomorrow’s markets today. Find out more about Nasdaq’s offerings to drive your business forward here.

Stifel Launches New Intra-Day Momentum Signal

Stifel Electronic Trading Team has developed an intra-day momentum signal to predict short-term price movement with a high degree of accuracy.

John Spensieri

The signal is designed to allow all Stifel algorithms to reduce execution costs and improve spread-capture, independent of the parent strategy, according to John Spensieri, Stifel Head of U.S. Equity Trading.

“Once an algorithm decides it should trade, the signal is given discretion to dictate the optimal order placement strategy in light of real-time stock specific behavior,” he told Traders Magazine.

He said that navigating today’s increasingly fragmented market requires a vigilant approach to deploying execution strategies that preserve alpha and minimize implicit costs. 

While many factors influence the success of an execution strategy, order placement and pricing are two of the most critical, he said. 

“To optimize order placement and pricing, the ideal strategy would be equipped with knowledge of imminent price changes and their direction, allowing fill-by-fill reductions in execution costs,” he said.

The signal demonstrates consistently high accuracy in back-tests and production, said Spensieri, adding that the duration of the signal is ticker-specific and dependent on quote stability.

“Since the signal responds to market action instead of market expectation during event-driven volatility, it is more robust to external noise than more sentiment-based models,” he said.

“The real-time analysis of trade data is more responsive than the internal GARCH model, which suffers from a characteristic lag,” he added.

According to Spensieri, Stifel’s clientele runs the gamut of asset managers, from mutual funds to quantitative hedge-funds. 

“Our clients benefit from the momentum signal by achieving reduced execution costs,” he said.

Spensieri added that Stifel’s U.S. Equity Trading Desk offers a proprietary suite of algorithms, in addition to Portfolio, ETF, Cash, Options, and Convertible Bond Trading. 

He said that Stifel’s shift to a proprietary algorithmic product began in 2019 with the implementation of a cloud-based data infrastructure, which provided our foundation for quantitative execution research, and subsequently their algorithm development process. 

“We also launched our Stifel X ATS program to facilitate interaction between Stifel retail and institutional equity flows,” he said.

According to Spensieri, Stifel’s algorithmic development process and products focus on optimizing trader experience in providing performance, flexibility, and transparency that reduces unexpected outcomes. 

“In turn, the efficiency of our design and development process further strengthens our ability to offer unique solutions to client needs in relatively short time-frames,” he said.

Since Beta deployment of the signal to Stifel’s Liquidity Seeking and Implementation Shortfall algorithms, near-side fills on market orders increased 8 percentage points with a corresponding reduction in far-side fill percentages, Spensieri said.

In addition, spread-adjusted performance on market orders improved 6% with an overall increase in participation rates, he said. 

On the back of these positive results, Stifel will deploy the signal to VWAP, TWAP, POV, and SPY Dark Aggregator over the coming months. 

Concurrently, Stifel’s Electronic Trading Team will continue to collect feedback from existing algorithms to develop practical solutions that add measurable value to our clients’ execution process.

“Our team is currently testing a new implementation shortfall strategy that utilizes client definable factors to fine-tune the sensitivity of signals within the algorithm,” commented Spensieri. 

“This provides clients with more transparency and control with respect to the behavior of the algorithm,” he concluded.

Morgan Stanley Forms Private Markets Transaction Desk

  • Companies are staying private longer, warranting the need for liquidity solutions
  • New offering supports secondary trading for shareholders of private companies through an company-centric focus with concierge service
  • Investors gain access to a distinct array of private market opportunities stemming from Morgan Stanley’s unique ecosystem encompassing Companies, Wealth Management Clients, and Institutional Investors

Morgan Stanley Wealth Management announced the launch of its Private Markets Transaction Desk, a concierge service that empowers eligible shareholders and investors to buy and sell eligible private company shares in the secondary market. The offering is part of Morgan Stanley’s broader Private Markets ecosystem that provides a unique suite of solutions for companies, employees and investors to serve a diversity of client needs.

Growth-stage venture-backed global companies worth over $1 billion in value have grown from 150 in 2015 to 1,000+ today, with a current cumulative valuation of $4.3 trillion.1 The Private Markets Transaction Desk has been launched to assist clients seeking liquidity in a highly fragmented and opaque secondary market.

“Alternative investments like private market shares are only growing in importance as investors seek deeper portfolio diversification,” said Jed Finn, Head of Morgan Stanley Wealth Management. “We are fortunate to possess the largest alternatives business there is, and when coupled with our world-class capital markets and private company solutions, are in a unique position to help meet the needs of both buyers and sellers within the private market.”

The Private Markets Transaction Desk helps solve these needs through an company-centric approach. Clients who use the desk can benefit from direct support for one-off sales of private company shares. Conversely, clients intent on investing in private companies can gain access to investments not widely accessible. This offering complements the existing private investment platforms for clients offered through Morgan Stanley Wealth Management.

“As a larger percentage of capital formation and economic growth is occurring in the private markets, we aim to continue to work hand in hand with all of our clients to source and facilitate these opportunities to create lasting value,” said Michael Gaviser, Head of Private Markets, Morgan Stanley Wealth Management.

The Private Market Transaction Desk is currently live and facilitating trades on behalf of clients. In addition to existing client relationships, it has established relationships with leading secondary marketplaces which can help clients gain exposure to a broader market with a focus on transaction execution quality. Morgan Stanley tapped industry veteran Jeff Urban to lead the desk, who previously led a number of leading private and public markets distribution and syndication businesses.

“As the private markets continue to evolve and mature, there is an increased appetite among shareholders and potential investors for a trusted institution to provide access to robust liquidity solutions in the secondary markets,” said Kevin Swan, Head of Private Markets Solutions. “With more investors and capital entering the space, the Private Markets Transaction Desk puts clients in the driver’s seat to streamline complex transactions and address the needs on both sides of the market while working closely with the company.”

Morgan Stanley continues to invest in private company solutions to serve this growing market. Through the Shareworks equity management platform, Morgan Stanley has achieved $20 billion+ in company-led private share liquidity programs since 2020. With the launch of the Private Markets Transaction Desk, the types of liquidity programs Shareworks can support has expanded to give companies a suite of automated solutions to manage secondary transactions while maintaining control of their cap table.

Source: Morgan Stanley

OCC February 2024 Monthly Volume Data

March 04, 2024

Contract Volume

 February 2024 ContractsFebruary 2023 Contracts% Change2024 YTD ADV2023 YTD ADV% Change
Equity Options521,543,021470,542,71910.8%24,952,11624,639,1861.3%
ETF Options367,236,348345,614,2066.3%18,480,58918,116,1022.0%
Index Options82,813,40067,077,83023.5%4,155,868 3,463,53320.0%
Total Options971,592,769883,234,75510.0%47,588,57346,218,8213.0%
Futures4,264,3304,316,963-1.2%221,466210,2985.3%
Total Volume975,857,099887,551,7189.9%47,810,03946,429,1193.0%

Securities Lending

 February 2024 Avg. Daily Loan ValueFebruary 2023 Avg. Daily Loan Value% ChangeFebruary 2024 Total TransactionsFebruary 2023 Total Transactions% Change
Market Loan + Hedge Total154,774,637,195117,615,756,21531.6% 200,117 173,88815.08%

Additional Data