For the past five years we have been complaining about the two-tiered, and broken, market resulting from the near-ubiquitous presence of HFT trading strategies, where fundamentals have been tossed into the trash, and where quote churning, packet stuffing and not to mention, momentum ignition, put on candid display just before market open today when the Emini was ramped in a vertical line straight up taking the S&P to new all time highs, have become the only trading strategies that matter. Why? Because algos were in a panic buying mode as other algos were in a panic buying mode, and so reflexively on. The SEC long ignored our complaints, even after the HFT-precipitated flash crash, which we had warned apriori would happen, in a market as broken and manipulated as the one the Fed and the algos have unleashed. This changed recently when NY AG Schneiderman finally decided to "look into things" following the release of Virtu's ridiculous prop trading profits when the firm, in its IPO prospectus, announced it had made money on 1327 of 1328 trading days. However, when even Goldman Sachs begins complaining about HFT, it may be time to fire all those 20-some year old math PhDs who program your "trading algorithms."
In an Op-Ed overnight, Goldman COO Gary Cohn reminds those who may have forgotten, that:
In the past year alone, multiple technology failures have occurred in the equities markets, with a severe impact on the markets' ability to operate. Even though industry groups have met after the market disruptions to discuss responses, there has not been enough progress. Execution venues are decentralized and unable to agree on common rules. While an industry-based solution is preferable, some issues cannot be addressed by market forces alone and require a regulatory response. Innovation is critical to a healthy and competitive market structure, but not at the cost of introducing substantial risk.
Odd - we have been saying this since April 2009.
Anyway, what does Cohn suggest? Here, via the WSJ, are his four proposal for eliminating the fragmented, broken markets that have resulted from the relentless incursion of vacuum tubes, which have also driven the vast majority of carbon-based traders out.
Regulators and industry participants, including asset managers, broker-dealers, exchanges and trading firms, have all put forth ideas and reforms. We agree with a number of their concerns and propose the following four principles:
First, the equity market needs a stronger safety net of controls to reduce the magnitude and frequency of disruptions. A fragmented trading landscape, increasingly sophisticated routing algorithms, constant software updates and an explosion in electronic-order instructions have made markets more susceptible to technology failures and their consequences.
We propose that all exchanges adopt a stringent set of uniform, SEC-mandated execution controls to reduce errors. In addition to limit-up, limit-down rules that prevent trades from occurring outside a specified price band, pre-trade price and volume limits should be implemented to block problematic orders from entering the market. Mechanisms should also be introduced to halt a firm's, market maker's or other entity's trading when an established threshold is breached, thus minimizing the uncontrolled accumulation of trades.
Second: Create incentives to reduce excessive market instability. The economic model of the exchanges, as shaped by regulation, is oriented around market volume. Volume generates price discovery and liquidity, which are clearly beneficial. But the industry must recognize how certain activities related to volume can place stress on a market infrastructure ill-equipped to deal with it.
Electronic-order instructions connect the objectives of buyers and sellers to actions on exchanges. These transaction messages direct the placement, cancellation and correction of orders, and in recent years they have skyrocketed. In the 2010 "flash crash," a spike in the volume of these messages exacerbated volatility, overwhelming the market's infrastructure.
According to industry analysis, since 2005 the flow of these order instructions sent through U.S. stock exchanges has increased more than 1000%, yet trade volume has increased by only 50%. One consequence of the enormous growth in order-message traffic is that increasingly the quote that an investor sees isn't the price he or she can transact, as orders often get canceled at lightning-quick speeds.
Currently there is no cost to market participants who generate excessive order-message traffic. One idea would be to consider if regulatory fees applied on the basis of extreme message traffic—rather than executions alone—are appropriate and would enhance the underlying strength and resiliency of the system. Regulators in Canada and Australia have adopted this approach.
Third: Public market data should be disseminated to all market participants simultaneously. Exchanges currently disseminate prices and transaction data to the SEC-sanctioned distributor for all investors, but exchanges may also send this information directly to private subscribers. While the data leave the exchange simultaneously, the public data are delayed because they go through the intermediary's processing infrastructure. The public aggregator should release information to all market participants at the same time.
Removing the possibility of differentiated channels for market data also reduces incentives that favor investment in the speed of one channel over the stability and resiliency of another. Instability creates and compounds market disruptions. Stable and accurate market data is one of the most important elements of market safety; it is the backbone of the market that must weather the most extreme periods.
Fourth: Give clearing members more tools to limit risk. A central clearing house with strong operational and financial integrity can reduce credit risk, increase liquidity and enhance transparency through enforced margin requirements and verified and recorded trades. But because clearing members extend credit, the associated risks must be recognized. Tools like pre-trade credit checks and being able to monitor positions and credit on an intraday basis are essential. Clearing firms use various tools like margin and capital adequacy to manage their risk, but exchanges should also provide uniform mechanisms for clearers to set credit limits and to revoke a client's ability to trade immediately upon request, when necessary.
Once again, all suggestions we have banged the table on for the past five years to the point where we simply don't care.
Why? Because we realize that the HFT-parasite system is so embedded in the market structure and "New Normal" levitation topology that serves the failed status quo system, that there is no hope of ever extricating the algos from the market without crashing the market outright. And the regulators know this all too well.
Which is the definite paradox, because the only thing that will revert the market back to some semblance of normalcy, is precisely a crash that wipes out the false sentiment that things are stable, which as everyone who traded securities in the old normal, knows they are anything but.
In other words, the best thing one can do is to cheer on the increasing incursion of idiocy in stock trading, which inevitably will self-cannibalize itself. As, incidentally, will the Fed's final attempt to centrally plan the "wealth effect" to all time highs.
So do your worst, Mr. Chairmanwoman and Virtu, we, for one, are rooting for you!