Listen Carefully

Listen carefully.

Listen carefully and you can hear the industry spinning the Knight algo situation not as a market structure problem but as a risk management issue.  Since the August 1st “Knightmare”, we have seen numerous industry insiders speaking out that risk needs to be better managed.  They have been advocating adding new Risk Officers and even adding more software to detect problems.  An August 22nd interview with the Direct Edge stock exchange CEO, Bill O’Brien, is a perfect example of what the industry has been spinning:

“Now that automation is such an essential part and change of pace is so dynamic, we really need to make sure the risk management and control systems are in place…Technology has permeated the stock market. We need to control that risk more effectively with any firm but we also have to be more constructive working together cooperatively…I think you are going to see a lot more focus and cooperation among exchange to control the incremental risks that technology has brought to the system and I feel pretty good about that.”

Well, we are glad to hear the exchange executives finally think it is time to work on risk management.  Considering that the stock market produces millions of messages per minute and trades in microseconds, this is probably a good idea.  But we say, what took you so long?  And is risk management really the issue or is that just something to deflect the regulators and the public from the real issue which is our fragmented market structure and the embedded conflicts of interests that exist in it?

We saw something very similar to this happen right after the Flash Crash.  Almost every industry insider was immediately advocating the same remedy: circuit breakers.  If we only had single stock circuit breakers, then the Flash Crash would have never happened, they said.  The SEC was convinced and spent the next two years applying small band aid fixes but neglecting to look at the bigger picture problems.  The industry insiders were successful and deflected the SEC two years ago from the real issues and they are trying the same stunt right now.

And it appears to be working again. The SEC has latched onto the bait and will be holding a market technology roundtable on September 14.  Here is what their press release signals about the roundtable:

“While the SEC recognizes the central role that technology plays in different aspects of our market structure, the agenda set forth below is intended to focus on how appropriate controls or processes for the implementation of technology can support a robust and reliable market.”

The participants have yet to be announced but we expect the same folks that we always see at these events to show up.  They will claim that they have better risk management controls and that they are going to work together to make sure that another Knight algo situation never happens again.

If the SEC was really serious about reform, they would be looking at bigger picture items like the elimination of the maker taker model.  They would dust off their 3 year old dark pool regulation proposal.  They would look at the exchange data feeds and eliminate the excessive information in them that is hurting institutional investors.  They would stop approving conflicting order types.

We hope the September 14 roundtable produces some concrete action steps but unfortunately we have seen this movie before and pretty much know how it ends.

-Sal Arnuk & Joe Saluzzi,  August, 2012

~~~

Joseph Saluzzi (jsaluzzi-at-ThemisTrading.com) and Sal L. Arnuk (sarnuk-at-ThemisTrading.com) are co-heads of the equity trading desk at Themis Trading LLC (www.themistrading.com), an independent, no conflict agency brokerage firm specializing in trading listed and OTC equities for institutions. Prior to founding Themis, Sal and Joe worked for more than 10 years at Instinet Corporation, pioneers in the field of electronic trading, and at Morgan Stanley.