The TRADE 58 | Page 74

[ I N - D E P T H | S Y S T E M AT I C I N T E R N A L I S E R S ] looking for in an ELP SI, and this means offering liquidity across a large and diverse securities universe. This is an easy one to quantify because the informa- tion is available on the quote streams. With quantity of liquidity, it is via quote sizes. To Matt’s point, we are not going to be two-way in every single stock all the time in all sizes, but what we will do is offer a quantity of liquidity that matters to the buy-side. It all boils down to those three and making sure that brokers and the buy-side are aware of the different ELP SI models. Citadel Securities obviously only represents one type of ELP SI, but there are other types of SIs out there as well. Regarding quality of liquidity, measuring the price impact following an SI trade remains the key focal point for many discussions. Ideally, the focus would be as an A-B test per market maker, but realistically this would not be practicable. Focusing on fill level analysis would help the buy-side and sell-side deter- mine which market makers unwind positions quickly and which ones risk warehouse positions. One point worth noting is that we are talking here from a Jefferies and Liontrust perspective, but brokers are evaluating these factors very differently depending on their interactions with market makers. It remains difficult for the buy-side to become aware of what a good evaluation and a bad evaluation actually looks like, so again, the more we can talk about it the more we can move into a standardised framework for eval- uating these factors. HM: What are your thoughts around SI price improve- ments sub-tick above SMS and the European Commis- sion’s recent take on the tick-size regime for SIs? BS: We do not factor marginal improvements in, it doesn’t mean anything for us. We believe it could po- tentially create the wrong incentive, and I think risks in efficient market structure. In Europe a few years ago when we saw the dawn of fragmentation in lit markets, we saw tick-size competition taking place between primary exchanges and alternative venues, but I think the industry did a very good job of self-policing that and coming to a harmonised tick-size regime. Mi- FID II of course has a harmonised tick-size requirement for trading venues, so the industry is un- der regulatory pressure 74 // TheTrade // Winter 2018 to conform with the regime more widely. I think potentially antag- onising the regulator by offering fractional tick price improvements is not very productive. MM: From the buy-side’s per- spective, a tenth or twentieth of a tick price improvement is not something we are looking for. The regulators have been looking at extending the tick size regime to cover SI flow, so price improve- ment could soon be a thing of the past. There is a danger that this gets extended to LIS venues and periodic auctions, which would prevent a large amount of mid-point trading. This is defi- nitely not in the best interests of investors. I’m pretty comfortable with the tick size regime being expanded to include SIs, however, because it’s not a driver as to why I’m trading with them in the first place. BS: Yes, it’s very important as an industry that we protect being able to trade at mid-point. It’s a very valuable option for a range of different venues that use if it for a wide range of market participants, and is well established as a go-to option for many of the largest asset managers across the Continent. HM: How do you see relationships between brokers, the buy-side and market makers evolving in future? JF: I would say the SI regime has achieved one of the key goals of MiFID II, that being increased transparency albeit on a bilat- eral basis. For the first time, the buy-side and sell-side can isolate, identify and ultimately evaluate each individual market maker on