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Moody's Chimes In On The Consequences Of The Flash Trading Ban

Tyler Durden's picture




In their weekly commentary piece, among many other things, Moody's discussed the downstream impacts of the ban of Flash, IOIs and other existing practices. They provide a different perspective in terms of a pros/cons analysis of the upcoming changes to both brokers-dealers and exchanges. Nothing earth shattering, but useful information to keep a sense of perspective in light of upcoming market structure developments, and who stands to lose the most.

More relevant to us seems the question of whether a ban on “flash” orders would be a precursor of more changes in the market structure. The modern U.S. cash equities market is a highly complex network of electronic trading platforms with a myriad of order types, order flow aggregation mechanisms, and pricing schemes. As a whole, the market is also very liquid and extremely competitive. The pricing pressure exerted on exchanges by brokers and traders trying to keep their execution costs down is intense.

A major component of the market’s competitiveness stems from the fact that over 30% of total U.S. cash equities trading takes place away from exchanges, and about 50% away from NASDAQ OMX and NYSE Euronext – the two major exchanges. Much of this order flow is either “internalized” by major brokers or is directed to “dark pools,” which are a type of ATS. As with “flash” orders, the traders and platforms executing trades via these means benefit from the price discovery that occurs on “bright” venues (e.g., exchanges), which post visible firm quotes to the NBBO. But none of these trading venues contribute to price discovery.

Furthermore, there are other reasonably common market practices, such as the so-called indication-of-interest (IOI) orders, which are used to link dozens of dark pools among themselves and with other venues, that function in ways that are similar (though, not identical) to “flash” orders and could therefore be subjected to similar criticisms. [TD: this statement agrees with the thoughts presented yesterday by Credit Suisse, and represented earlier by Zero Hedge]

Were market practices such as internalization and “dark pools” also to be prohibited or made significantly less attractive – perhaps, on the grounds similar to those that may apply to “flash” orders – this could change the industry’s competitive landscape in a major way. It would shift an important degree of pricing power to exchanges and away from brokers and traders. All other things being equal, this would generally be positive for the credit profiles of exchanges and could be negative for institutional brokers.




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Thu, 08/13/2009 - 18:57 | Link to Comment Missing_Link
Missing_Link's picture

Moody's  ...  Correct me if I'm wrong, but aren't those are the guys that rated subprime-mortgage-backed securities as AAA securities, allowing the mortgage crisis to escalate into a full-blown banking crisis which nearly destroyed our entire economy?

Thu, 08/13/2009 - 19:03 | Link to Comment djchill2
djchill2's picture

Hell Ya!  These guys are badass!  These guys are so badass, I know, they are on the verge of downgrading that AAA US credit rating!  These guys don' t give a shit!...Moody's...Hell Ya!

Thu, 08/13/2009 - 20:31 | Link to Comment Hansel
Hansel's picture

they are on the verge of downgrading that AAA US credit rating

 

HA!  They won't downgrade the credit rating until the U.S. actually defaults.

Thu, 08/13/2009 - 19:03 | Link to Comment Anonymous
Thu, 08/13/2009 - 21:11 | Link to Comment eraser (not verified)
Thu, 08/13/2009 - 19:04 | Link to Comment Anonymous
Thu, 08/13/2009 - 19:08 | Link to Comment Anonymous
Thu, 08/13/2009 - 19:12 | Link to Comment SloSquez
SloSquez's picture

"All other things being equal, this would generally be positive for the credit profiles of exchanges and could be negative for institutional brokers."  So.

Thu, 08/13/2009 - 19:15 | Link to Comment SloSquez
SloSquez's picture

Compartmentalization is for secrecy and nothing else.

Thu, 08/13/2009 - 19:17 | Link to Comment Anonymous
Thu, 08/13/2009 - 19:28 | Link to Comment SloSquez
SloSquez's picture

In my mind and maybe I'm a fool.  All shares through one keyhole and one keyhole only.  Only then is there true price discovery.  All of it!

Thu, 08/13/2009 - 20:02 | Link to Comment sellside_pov
sellside_pov's picture

You aren't a fool.  You're just wrong.  What most people don't understand is that dark pools, ioi's, flash orders, etc... give large traders a means to hide their orders from prop trading hedge funds.  The more information people are forced to expose, all that information is rapidly aggregated and used against them.  What's good for the public, retail trader is amazing for HFT's, prop traders, etc...

Thu, 08/13/2009 - 20:10 | Link to Comment SloSquez
SloSquez's picture

I'm not worried about the retail trader.  If a large block must be dumped, then they should have to go to market to dump them.  Oh shit, a price spike.  Allow a market to function as a market.

Thu, 08/13/2009 - 20:12 | Link to Comment SloSquez
SloSquez's picture

Push / Pull.  If a hedge fund can't dump them economically, then they are phucked.  They should not have bought them.

Thu, 08/13/2009 - 20:14 | Link to Comment sellside_pov
sellside_pov's picture

Then who are you worried about? Who do you think the winners and losers would be if say, dark pools were banned?

Thu, 08/13/2009 - 20:25 | Link to Comment SloSquez
SloSquez's picture

The market would be amongst the truly predictive ones.  Why buy oil if the market is going electric.  It seems to me the market would function as a true market.  Someone will be left with the bag.  The transaction speed and compartmentalization is about capital investment gaining an advantage - nothing else.  Large sums of money going towards nothing substantial.  That's not a market.

Thu, 08/13/2009 - 20:46 | Link to Comment sellside_pov
sellside_pov's picture

Didn't get an answer to my question.  Transaction speed is the result of people slicing their orders very thin to expose as little information as possible.  Compartmentalization is people trying to avoid the public markets altogether, again to avoid exposing themselves.  Who do you think they are trying to avoid?

Thu, 08/13/2009 - 21:11 | Link to Comment SloSquez
SloSquez's picture

Slicing orders assumes a buyer and lots of them.  To prevent exposing and an iceberg as it were.  Compartmentalization creates a market on the side.  They are not trying to avoid, they are avoiding the market.  If the buyer and seller were forced to gather in one place and expose their position to the rest of the market.  The market price would react.  The result of dark pools is to transfer large blocks quietly without ever exposing position or supply/demand to the broad market.  This is not a market.  Your question - the market as a whole.  Nothing but side deals paid handsomely.

Thu, 08/13/2009 - 21:36 | Link to Comment sellside_pov
sellside_pov's picture

Every time the rules change, certain players benefit, and others are disadvantaged.  The market as a whole might benefit.  But it's worth considering who WITHIN the market wins and loses.  It seems like you are avoiding considering who the beneficiaries of dark pools are.  Note I'm not trying to pick on you specifically.  I'm refering to the more general problem here.  There are lots of people with opinions on the market structure, but few seem to have thought deeply about the actual mechanics of the trading process.

Side note.  Dark pools don't allow anyone to avoid exposing supply and demand, as all of their volumes are publicly reported just like trading on the major exchanges.  The difference is that you can put a large open order into a dark pool and no one will know about it unless you get filled.

Thu, 08/13/2009 - 21:53 | Link to Comment SloSquez
SloSquez's picture

"The difference is that you can put a large open order into a dark pool and no one will know about it unless you get filled."  by a large order.  i.e. outside of the market or inside another market.  You choose.

Thu, 08/13/2009 - 23:18 | Link to Comment Howard_Beale
Howard_Beale's picture

And when Paulson dumps his BAC and COF noone will know. Works for him!

Thu, 08/13/2009 - 23:24 | Link to Comment sellside_pov
sellside_pov's picture

They will know because the volumes are reported just like any exchange.  Seems like no one understands that.  It's basic.

And secondly most investors trying to trade large blocks would rather find one or a few other large traders to take the other side rather than risk getting chopped to bits by order anticipators (HFT's) in the public market.

Fri, 08/14/2009 - 08:32 | Link to Comment dnarby
dnarby's picture

Two words.

PRICE.  DISCOVERY.

Thu, 08/13/2009 - 20:45 | Link to Comment KidDynamite
KidDynamite's picture

bingo. this is the key - if dark pools were banned, it would help the HFT guys most of all.  that's why i don't understand why TD is on a rampage against dark pools...

Fri, 08/14/2009 - 05:27 | Link to Comment peterpeter
peterpeter's picture

Neither do I (understand it).

The angst against all of HFT, Flash and Dark Pools seems like a mis-guided backlash against things that have poorly chosen names, or are just mis-understood.

While I am supportive of all 3 of the above, I can understand someone talking their book and liking Flash but not Dark Pools (some HF funds for instance), or Dark Pools but not Flash (mututal funds).

The only people who seem to dislike both Flash and Dark Pools seem to either have a philisophical bend that all trading should be done in the open on a single exchange (no internalization, no dark pools, no non-displayed orders, and probably no ADRs if they gave it thought...) - or else they are simply against things because they think Goldman Sachs makes money utilizing them, which is pathetic.

Thu, 08/13/2009 - 20:03 | Link to Comment eraser (not verified)
Thu, 08/13/2009 - 19:36 | Link to Comment phaesed
phaesed's picture

Heh, I have a nice quote from W.D. Gann for ya...

"STOCKS NOT MANIPULATED: Before the Stock Exchange started regulating brokers and the control of markets, there was manipulation and pools often were organized that could advance low priced stocks that had very little merit to extreme high levels."

 

Phil Roth also commonly speaks of dark pool trading being more common just like back in the 30's.

Thu, 08/13/2009 - 19:45 | Link to Comment SloSquez
SloSquez's picture

 "just like back in the 30's".  Exactly, reminiscent of the bucket shops of lore.  How's it any different?

Thu, 08/13/2009 - 23:29 | Link to Comment Howard_Beale
Howard_Beale's picture

It's not. We had funds of funds as we do now creating a massive Ponzi scheme. The list is so long I'm not even going to start. As I have said before, history loves to repeat itself.

Thu, 08/13/2009 - 19:41 | Link to Comment Anonymous
Thu, 08/13/2009 - 19:49 | Link to Comment Anonymous
Thu, 08/13/2009 - 19:52 | Link to Comment Anonymous
Thu, 08/13/2009 - 20:47 | Link to Comment Ando
Ando's picture

Do institutional brokers still exist?  They get FREE MONEY for getting in between institional orders and the market.  Keeping the market fragmented only helps the FUCKS that get that order flow.

Thu, 08/13/2009 - 22:32 | Link to Comment Anonymous
Fri, 08/14/2009 - 09:22 | Link to Comment Anonymous
Fri, 08/14/2009 - 18:08 | Link to Comment sellside_pov
sellside_pov's picture

Not sure I see the difference between an "iceberg order" (read: order the public cannot see) and an order in a dark pool.  I think one just sounds more scary than the other.

Sat, 08/15/2009 - 07:24 | Link to Comment Anonymous
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