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	<title>Themis Trading Blog</title>
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	<description>Independent No Conflict Agency Trading for Institutional Investors</description>
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		<title>Schumer asks SEC to Study Rapid Trading/Quote Stuffing in Flash Crash</title>
		<link>http://blog.themistrading.com/?p=1361</link>
		<comments>http://blog.themistrading.com/?p=1361#comments</comments>
		<pubDate>Tue, 07 Sep 2010 11:58:11 +0000</pubDate>
		<dc:creator>sarnuk</dc:creator>
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		<guid isPermaLink="false">http://blog.themistrading.com/?p=1361</guid>
		<description><![CDATA[
I wonder what the sound of 8,000 SEC eyes rolling is like?  Maybe the Senator can also demand a looking into Steroids in MLB next?
First Published Monday, 6 September 2010 10:53 pm - © 2010 Dow Jones

By Jacob Bunge
Of DOW JONES NEWSWIRES
U.S. Sen. Charles Schumer urged federal securities regulators to explore ways to slow some high-speed [...]]]></description>
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<h4>I wonder what the sound of 8,000 SEC eyes rolling is like?  Maybe the Senator can also demand a looking into Steroids in MLB next?</h4>
<h4>First Published Monday, 6 September 2010 10:53 pm <em>- © 2010 <a title="World-class publisher of business and financial newswires, indexes, newspapers and magazines - Dow Jones" href="http://www.dowjones.com/role-algo-trading.asp" target="_blank">Dow Jones</a></em></h4>
</div>
<p>By Jacob Bunge</p>
<p>Of DOW JONES NEWSWIRES</p>
<p>U.S. Sen. Charles Schumer urged federal securities regulators to explore ways to slow some high-speed trading at times of market stress and to investigate strategies that have raised concerns of stock manipulation, including one known as &#8220;quote stuffing.&#8221;</p>
<p>Schumer, a New York Democrat, urged the Securities and Exchange Commission to launch a formal inquiry into whether computer-powered trading firms&#8217; rapid entering and canceling of stock orders, called quote stuffing, played a role in the so-called flash crash of May 6, and to more broadly reconsider these participants&#8217; role in the U.S. marketplace.</p>
<p>&#8220;While I acknowledge that technological advances, including [high frequency trading], have brought significant efficiency gains to our markets, I have come to believe that HFT provides less of the benefits to our markets than its adherents claim, and does so at greater cost to long-term investors,&#8221; Schumer wrote in a letter to SEC Chairman Mary Schapiro, a draft of which was reviewed by Dow Jones.</p>
<p>SEC representatives were not immediately reached for comment.</p>
<p>The Wall Street Journal reported last week that the SEC has begun looking into whether quote stuffing is putting some investors at a disadvantage by distorting stock prices.</p>
<p>Also under agency scrutiny is a practice known as &#8220;sub-penny pricing,&#8221; where many orders are priced in increments as small as one-tenth of a cent and far away from the most recent price of a stock, raising fears of manipulation.</p>
<p>The SEC should identify firms that frequently pursue such strategies, Schumer said, and require exchanges and other trading venues to throttle back these firms&#8217; trading activity&#8211;or that of all participants&#8211;when market volatility is on the rise.</p>
<p>Requiring stock quotes to stand for a set period of time would also help ensure that trading programs can&#8217;t send thousands of orders if traders have no intention of executing them, he said.</p>
<p>Such a minimum quote lifetime has been suggested by brokerage executives in recent months, but implementing the idea is seen as difficult. Some traders have said it could create the possibility of arbitrage in related securities or derivatives markets.</p>
<p>The recommendations from Schumer, a senior member of the Senate Banking Committee, follow his call in August for the SEC to create additional requirements for high-speed electronic traders to keep trading in volatile markets. Several such firms which typically provide market liquidity ceased trading amid the May 6 flash cash, potentially exacerbating price swings.</p>
<p>Schumer&#8217;s comments come as U.S. regulators prepare to deliver a report as soon as this month on the flash crash, which exposed flaws in the infrastructure of U.S. securities markets and thrust computer-driven trading into the spotlight. European regulators and exchange officials are also expected to discuss the topic this week at a conference in Interlaken, Switzerland.</p>
<p>&#8211;By Jacob Bunge, Dow Jones Newswires; 312-750-4117; <a href="mailto:jacob.bunge@dowjones.com">jacob.bunge@dowjones.com</a></p>
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		<title>More Stuffing?</title>
		<link>http://blog.themistrading.com/?p=1357</link>
		<comments>http://blog.themistrading.com/?p=1357#comments</comments>
		<pubDate>Thu, 02 Sep 2010 09:24:02 +0000</pubDate>
		<dc:creator>sarnuk</dc:creator>
				<category><![CDATA[Market Commentary]]></category>

		<guid isPermaLink="false">http://blog.themistrading.com/?p=1357</guid>
		<description><![CDATA[

I know, I know… it is not November. And to be honest I never liked turkey, especially with all the stuffing. The Wall Street Journal reports that the SEC is in fact looking into the role quote stuffing played in the Flash Crash of May 6th: SEC Probes Canceled Trades (ht ZH). The article highlights [...]]]></description>
			<content:encoded><![CDATA[<p><a href="http://blog.themistrading.com/wp-content/uploads/2010/09/stuffing-cage.png"><br />
<img class="aligncenter size-full wp-image-1358" title="stuffing-cage" src="http://blog.themistrading.com/wp-content/uploads/2010/09/stuffing-cage.png" alt="" width="496" height="402" /></a></p>
<p>I know, I know… it is not November. And to be honest I never liked turkey, especially with all the stuffing. The Wall Street Journal reports that the SEC is in fact looking into the role quote stuffing played in the Flash Crash of May 6<sup>th</sup>: <a href="http://online.wsj.com/article/SB10001424052748703882304575465990082237642.html">SEC Probes Canceled Trades</a> (ht ZH). The article highlights already reported-on and blogged-on findings by Nanex, who also demonstrates how P&amp;G stock was manipulated on April 28<sup>th</sup>, where a flood of orders slowed down NYSE to be behind the “real market”, creating an arbitrage between the “real market” and the slower NYSE market. Latency Arbitrage on demand! We recall how some astute observers noted that May 6<sup>th</sup> was not a symptom of poor market structure; it was a feature.</p>
<p>Will the activity prove to be benign, and a function of “legitimate market making”? I’ll be open minded and say, “maybe”, although our experience has taught us that where there is smoke there is fire, especially where market structure issues are concerned. Go get ‘em Mary. We know that it is politically difficult for the SEC to find fault in a system created by the SEC, albeit unintended. And we know that it is hard to do the right thing, when you have pressure from a lobby, complete with their “powerful” representatives in Washington. But know that a great many have faith specifically in you.</p>
<p>Please allow us to make one last point this morning regarding market structure, the stock market, and implied correlations. With the implied correlations of so many distinct asset classes, as well as within stocks, reaching bizarre levels of late, we would like to reiterate what we stated in our paper in mid 2009, entitled What Ails Us About High Frequency Trading:</p>
<p><strong><em>&#8220;HFT Trading Possibly Affecting Asset Valuations</em></strong></p>
<p><em>The third issue we have with HFT is that we are concerned that it is causing a disconnect between market prices and real asset values. As everybody knows, the value of security assets are based on the pricing established every day by market trading. But shouldn&#8217;t we be wary of the pricing of a good if 70% of the transactions taking place are done by a few very large players? Would you prefer to buy a diamond in a marketplace controlled by one family, or in a marketplace of controlled by many players? Given the wild volatility in the oil market in the past few years, and now in currency, commodity, food and securities, are we avoiding examining another systemic risk?&#8221;</em></p>
<p><em> </em></p>
<p>Good morning everyone, and remember that US Open Tennis is on the tube if CNBC gets to be too much!</p>
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		<title>Bachus Hensarling Letter to Schapiro, and Our Comments.</title>
		<link>http://blog.themistrading.com/?p=1354</link>
		<comments>http://blog.themistrading.com/?p=1354#comments</comments>
		<pubDate>Tue, 31 Aug 2010 14:35:59 +0000</pubDate>
		<dc:creator>sarnuk</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://blog.themistrading.com/?p=1354</guid>
		<description><![CDATA[This morning we awaken to find the Bachus/Hensarling August 24th 2010 letter to Mary Schapiro in our inbox, which we include as an attachment for you to read. Ever since the HFT industry formed their own lobbying group in Washington DC a few months back, we have expected a letter like this to surface. We [...]]]></description>
			<content:encoded><![CDATA[<p>This morning we awaken to find the Bachus/Hensarling August 24<sup>th</sup> 2010 letter to Mary Schapiro in our inbox, which we include as an attachment for you to read. Ever since the HFT industry formed their own lobbying group in Washington DC a few months back, we have expected a letter like this to surface. We certainly have expected it to surface given the recent anti-HFT media attention post May 6<sup>th</sup>. Please allow us summarize their letter for you.</p>
<p>“In 2008 markets functioned exceptionally well. High Frequency Trading is beneficial to all. We all benefit from their liquidity. If it goes away we will all suffer.  Spreads have never been narrower. Costs of trading have never been lower. There is no evidence that flash order types are bad. Don’t make any changes unless you have more data. Turning back the clock on innovation will do harm. With our bias in mind, please answer in writing to us by September 10<sup>th</sup>, 2010 the following 15 rhetorical questions.”</p>
<p>Had we told you this letter was written by the HFT lobby, you would have shrugged while commenting that such drivel is what you would expect that lobby to say. Perhaps we all should shrug less, and be more alarmed, that it comes from two congressman up for re-election, and written on the Committee on Financial Services letterhead. Incidentally, you can see who contributed to Representative Bachus so far in 2010 here : <a href="http://www.opensecrets.org/politicians/summary.php?cid=N00008091&amp;cycle=2010">Open Secrets Bachus</a>, and you can see who contributed to Representative Hensarling so far in 2010 here: <a href="http://www.opensecrets.org/politicians/summary.php?cid=N00024922&amp;cycle=2010">Open Secrets Hensarling</a>.</p>
<p>We understand how politics work in the United States. We know there will always be certain groups that have the ear of certain Congressman. However, let us compare this letter, with its open-ended and one-sided blatant bias with the well thought out letter from Senator Kaufman dated August 5<sup>th</sup>, where he analyzed our market structure deficiencies and offered up 9 separate potential solutions <a href="http://www.sec.gov/comments/s7-27-09/s72709-96.pdf">Kaufman Letter to Schapiro</a>.</p>
<p>The Bachus/Hensarling letter states as fact that the US markets functioned exceptionally well during the financial meltdown of 2008. But did they? Where is the Congressmen’s data to support that claim, aside from comments made by HFT proponents? In addition, their letter wants us all to ignore everything that has happened in 2009 and subsequently regarding HFT. They want us to ignore the arrest of Sergey Aleynikov, who stole code from Goldman Sachs that could be used to manipulate markets. They want us to ignore the studies by brokerage firms and TCA firms that demonstrate the negative and predatory effects of HFT. They want you to pretend you never heard of quote stuffing.</p>
<p>The Bachus/ Hensarling letter also states as fact that our markets remain efficient, transparent, and accessible to all investors. They obviously do not understand that our markets have become tiered, based on the degree of co-location paid to the exchanges. They also don’t understand that 20% of trading volumes are executed in the dark, which is less than transparent, shall we say. They also don’t understand that our markets have altered their focus from investing and towards ultra-short term hyper trading, collateral damage and capital formation be damned.</p>
<p>The Bachus/Hensarling letter states that, as we all do not know what caused the events of May 6<sup>th</sup>, we should refrain from using terms like “Flash Crash”, as it presumes flash order types were the culprit. To this point, we say the following: not only is the “re-naming and spin management” game a silly one for the civil servants, whose salaries we pay, to play, but their argument demonstrates the lack of knowledge by these two Congressmen. The May 6<sup>th</sup> Flash Crash is aptly named, because the events of that day took place in flash-like speed. The May 6<sup>th</sup> Flash Crash was never named because of any reference to flash order types. The Congressmen know precious little of the issue they are attempting to address! Given the other portions of this letter that specifically address the SEC’s focus on flash order types, we easily see the real purpose of this letter, which is to advocate the position of those who wish to utilize these order types in equities and options.</p>
<p>We suggest that the Congressmen listen to what the real owners of our market have been saying.  They may want to read the letters recently written from Iridian Asset, Southeastern Asset, and Baron Asset.  Or listen to the words of Invesco and Principal Global.   These large institutional players have become frustrated with our fragmented market structure and they are now demanding change. Most of them have warned that unless significant changes are made then we should expect more flash crashes to happen. They may also want to listen to the legions of retail investors who have totally lost confidence in our equity market and are withdrawing their funds every month.   So, who are we to believe?   Two up-for-reelection Congressmen who appear highly conflicted, or the true owners of this market, as well as the outgoing Senator Kaufman who has clearly demonstrated that he understands what the issues are facing our market structure?</p>
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		<title>Equity market structure caters to interests of the few</title>
		<link>http://blog.themistrading.com/?p=1347</link>
		<comments>http://blog.themistrading.com/?p=1347#comments</comments>
		<pubDate>Mon, 30 Aug 2010 19:57:36 +0000</pubDate>
		<dc:creator>jsaluzzi</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

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		<description><![CDATA[David Weild knows a little something about our capital markets.  He was previously Vice Chairman of Nasdaq and now runs his own firm, Capital Markets Advisory.  He is also a senior advisor To Grant Thornton.  David and his partner, Ed Kim, have written extensively about how there has been an IPO crisis going on in [...]]]></description>
			<content:encoded><![CDATA[<p>David Weild knows a little something about our capital markets.  He was previously Vice Chairman of Nasdaq and now runs his own firm, Capital Markets Advisory.  He is also a senior advisor To Grant Thornton.  David and his partner, Ed Kim, have written extensively about how there has been an IPO crisis going on in this country for the past few years (check out their latest paper here <a href="http://www.gt.com/staticfiles//GTCom/Public%20companies%20and%20capital%20markets/Files/IPO%20crisis%20-%20June%202010%20-%20FINAL.pdf">http://www.gt.com/staticfiles//GTCom/Public%20companies%20and%20capital%20markets/Files/IPO%20crisis%20-%20June%202010%20-%20FINAL.pdf</a>).  Below is a letter to the editor that David wrote to the FT today.  We couldn&#8217;t agree more with him.</p>
<p><strong>Equity market structure caters to interests of the few</strong></p>
<p>Published: August 30 2010 03:10 | Last updated: August 30 2010 03:10</p>
<p><em>From Mr David Weild IV.</em></p>
<p>Sir, Larry Tabb (<a title="FT - Fixing equity markets is not such an easy task" href="http://www.ft.com/cms/s/0/835ba5ae-b05e-11df-8c04-00144feabdc0.html">“Fixing the equity markets not such an easy task”, Insight August 26</a>) diverts attention from equity market structure issues, high frequency trading, derivatives and the May 6 flash crash with a smokescreen of wider economic reasons for investors withdrawing in droves. But just like the credit crisis was induced by market structure (for example, no money down mortgages, unsustainable teaser rates, lowered underwriting standards and so on) and caused grievous harm to the US economy, it would be naive to assume that equity market structure cannot harm the US economy. It can. It has. It will.</p>
<p>Once upon a time, US market structure provided economic incentives to employ people in the business of providing high quality research, committing capital to create liquidity, and putting salesmen on the phone with investors to discuss individual stocks. Fundamental investors dominated the market and valued stocks. By contrast, today’s low commission, penny spread, fragmented and hidden markets destroyed economic incentives to support stock selection. Wall Street research budgets were slashed, analysts fled to hedge funds, stockbrokers became asset allocators, and capital was pulled from trading desks draining liquidity from small cap stocks.</p>
<p>Today, market structure has induced an era dominated by derivative interests and computerised trading – where stock index funds, exchange-traded funds and stock index futures replace the need to value individual stocks, while computers arbitrage these “derivative” securities against their underlying stocks; where computers don’t care whether the stock is Intel or Exxon or General Electric; where computers put orders a penny in front of your order to leverage your intent to their advantage.</p>
<p>More people are realising, to paraphrase the famous expression, that “It’s the market, stupid.” Recently, Mark Grier, vice chairman of Prudential Financial, in testimony at the Securities and Exchange Commission panel discussions on equity market structure, stated that he believes that Prudential Financial’s stock price is increasingly detached from its fundamental value.</p>
<p>The US stock market is in secular decline: we have 40 per cent fewer public companies today than at the peak in 1997. When SEC Commissioner Kathleen L. Casey asked a panel of trading experts during the SEC panel discussions on equity market structure: “Have small cap stocks experienced liquidity benefits from electronic trading?” almost to a person these experts said: “No, they have not.” This is troubling because 70 per cent of public companies are smaller than $250m in market value – smaller than “small cap”.</p>
<p>Increasingly, it is clear, the stock market caters to the interests of a few – large trading concerns and large investment banks – while undermining the interests of small public companies, small broker dealers, fundamental investors, the US economy and jobs. Sound familiar?</p>
<p>David Weild IV,</p>
<p>Chairman and Chief Executive,</p>
<p>Capital Markets Advisory Partners</p>
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		<title>Barrons&#8217; Abelson chimes in on HFT</title>
		<link>http://blog.themistrading.com/?p=1344</link>
		<comments>http://blog.themistrading.com/?p=1344#comments</comments>
		<pubDate>Mon, 30 Aug 2010 17:12:49 +0000</pubDate>
		<dc:creator>jsaluzzi</dc:creator>
				<category><![CDATA[Uncategorized]]></category>

		<guid isPermaLink="false">http://blog.themistrading.com/?p=1344</guid>
		<description><![CDATA[We have recently pointed out that many more voices have been weighing in on our fragmented equity market structure.  Firms like Southeastern, Invesco, Principal, Iridian and Baron Asset are all well respected, established institutional players that have joined the chorus of voices and are starting to demand action from our regulators.  The chorus got even [...]]]></description>
			<content:encoded><![CDATA[<p>We have recently pointed out that many more voices have been weighing in on our fragmented equity market structure.  Firms like Southeastern, Invesco, Principal, Iridian and Baron Asset are all well respected, established institutional players that have joined the chorus of voices and are starting to demand action from our regulators.  The chorus got even louder this weekend as Alan Abelson form Barrons weighed in.  He quotes from a newsletter for individual investors called Crosscurrents: &#8220;The public has gotten the shaft from Wall Street, from the SEC, from short-oriented hedge funds and now from high-frequency trading.&#8221;  Ouch, that one stings. </p>
<p> But Abelson goes on to highlight another paper titled &#8220;The Marginalizing of the Individual Investor&#8221;.  The piece was written by some folks associated with a firm called Bluemont Capital.  We don&#8217;t know these guys or their firm but we do know that they just wrote an excellent piece: <a href="http://www.international-economy.com/TIE_Su10_MalmgrenStys.pdf">http://www.international-economy.com/TIE_Su10_MalmgrenStys.pdf</a> .  In the paper, the authors question if HFT has distorted true market valuations.  Here are a few quotes:</p>
<p> <em>&#8220;Unfortunately, high-frequency trader interaction with computerized algorithms of large-cap financial institutions is providing opportunities for high-speed, virtually undetectable market manipulation.&#8221; </em></p>
<p> <em> &#8221;At a minimum, computerized high-frequency and algorithmic trading are undermining traditional value investing strategies. Short-term liquidity and data movements are distorting information on real business performance.&#8221;  </em></p>
<p> <em>&#8220;Essentially, high-frequency trading platforms function as positive feedback loops. Engineers treat positive feedback loops as inherently unstable, as each positive response generates stepped-up repetition of the same actions. Positive feedback loops result in an ever- expanding balloon, but like all balloons, the risk of bursting increases with the balloon’s size. &#8220;</em></p>
<p> The chorus is singing and they are sounding better every day.</p>
<p><strong> </strong></p>
<p><strong> </strong></p>
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		<title>Fixing Equity Markets Ain&#8217;t Easy?</title>
		<link>http://blog.themistrading.com/?p=1330</link>
		<comments>http://blog.themistrading.com/?p=1330#comments</comments>
		<pubDate>Thu, 26 Aug 2010 13:13:21 +0000</pubDate>
		<dc:creator>sarnuk</dc:creator>
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		<description><![CDATA[ http://www.ft.com/cms/s/0/835ba5ae-b05e-11df-8c04-00144feabdc0.html
Yesterday, Larry Tabb of Tabb Group penned an editorial in the online edition of the FT. I linked to it above, and pasted it for you below, but don’t bother even reading it (ok, you can if you want); I will recap it for you right here:
“Y’all are all bummed out because the economy stinks, [...]]]></description>
			<content:encoded><![CDATA[<p> <a href="http://www.ft.com/cms/s/0/835ba5ae-b05e-11df-8c04-00144feabdc0.html">http://www.ft.com/cms/s/0/835ba5ae-b05e-11df-8c04-00144feabdc0.html</a></p>
<p>Yesterday, Larry Tabb of Tabb Group penned an editorial in the online edition of the FT. I linked to it above, and pasted it for you below, but don’t bother even reading it (ok, you can if you want); I will recap it for you right here:</p>
<p><strong>“Y’all are all bummed out because the economy stinks, your money in the stock market has gotten crushed, and so have your investments in housing. And therefore you blame HFT and market structure. Widening spreads? Come on. When was the last time a person replaced a computer? It isn’t as easy to fix the markets as you think, so just leave it be. Please????”</strong></p>
<p><strong> </strong></p>
<p>I again share with you the image I created depicting our market structure, first shared with you in yesterday’s morning note. Look at it please:<strong> </strong></p>
<p><strong> </strong></p>
<p><a href="http://www.zerohedge.com/sites/default/files/images/user5/imageroot/hildebrand/Market%20Structure.jpg"></a><strong> </strong></p>
<p style="text-align: center;"><strong><a href="http://blog.themistrading.com/wp-content/uploads/2010/08/marketweb2.jpg"><img class="aligncenter size-full wp-image-1331" title="marketweb" src="http://blog.themistrading.com/wp-content/uploads/2010/08/marketweb2.jpg" alt="" width="419" height="531" /></a> </strong></p>
<p><strong> </strong></p>
<p>Fixing equity markets is not an easy task; this much Mr. Tabb and I can agree on. However, we at Themis, and many more of us at an increasingly large number of  firms who are owners of the market (<a href="http://blog.themistrading.com/?p=1323">http://blog.themistrading.com/?p=1323</a>), know that it all starts with the admission that there is a problem. We hope Mr. Tabb looks at the diagram above. Maybe even twice.</p>
<p><strong> </strong></p>
<p><strong> </strong></p>
<p><strong> </strong><strong></strong></p>
<p><strong> </strong></p>
<p><strong> </strong></p>
<p><strong>Fixing equity markets is not such an easy task</strong></p>
<p>By Larry Tabb</p>
<p>Published: August 25 2010 17:16 | Last updated: August 25 2010 17:16</p>
<p>In a letter on August 5 to Securities and Exchange Commission chairman Mary Schapiro, US senator Ted Kaufman called for stricter governance of high-frequency trading and asked Ms Schapiro to re-think the idea that a faster, tighter market is better than a slower, deeper market. Senator Kaufman suggested that <a title="FT - Time for debate on equity market structure" href="http://www.ft.com/cms/s/0/4950201a-abc7-11df-9f02-00144feabdc0.html">a slower market with wider spreads</a> may be the best solution to both drive capital formation and create a market that benefits longer-term investors. <strong></strong></p>
<p>He proposed a nine-point plan that included greater oversight of HFT, reducing market fragmentation and harmonising stock exchange rule books. The senator might be on to something, but the challenges we face today are less structural and more economic and will not vanish with a new set of more robust equity execution rules. Investors have been running away from the US stock market in droves. Equity volumes are about half or less than the historic highs reached at the March 2009 market bottom, with average daily volumes for August in the low 6bn share range (numbers we have not seen since early 2008). What’s more, equity mutual fund flows have been negative since the beginning of the credit crisis. According to the Investment Company Institute, $157bn has been pulled out of US equity mutual funds since September 2008. And that does not include market value loss, just net redemptions.</p>
<p>Can we lay this state of affairs at the feet of market structure? I don’t think so. That would be like blaming the reservation system at a restaurant for its fading popularity. Sure, a better process would help, but there are plenty of other reasons why we choose to dine elsewhere. So what then is at the heart of our fading equity markets? The first chink in the armour is purely demographic. Baby boomers are getting closer to retirement and increasingly less inclined to own stocks. The United Nations pegs the number of US residents over 65 at roughly 13 per cent of the total population and estimates that will reach nearly 20 per cent in 20 years. Given this seismic shift, a move away from risk assets (equities) towards safer ones (cash and bonds) would not be surprising. Beyond demographics, the market’s performance during the past decade has not exactly engendered much confidence.</p>
<p>The market crashes of 2000-2001 and 2008-2009 wiped out virtually all equity gains, while the latter also demolished housing values and greatly curtailed credit. More recently, <a title="FT- Vital lessons of the ‘flash crash’" href="http://www.ft.com/cms/s/0/2e1a96ee-5f7e-11df-a670-00144feab49a.html">the May 6 “flash crash” </a>and incessant talk of a double-dip recession have weighed heavily on investor sentiment. Government policy has not helped. Investors are not only worried about the markets but about the country’s political future. The corporate uncertainty generated by the passing of healthcare reform, financial reform and possibly a new energy policy – not to mention concern over how economic stimulus and tax policy will affect the deficit – has not created an investor-friendly climate. The vitriol directed at banks has not helped either, as the government has done its best to shift blame for the credit crisis on to financial intermediaries. Not that we should cry over banks; they deserve significant blame, but not all. It doesn’t take long to convince investors not to trust their nest eggs with firms that pushed a bunch of “s***ty deals,” as our legislators were fond of recounting.</p>
<p>In addition, the Sarbanes-Oxley Act of 2002 increased the risk and compliance cost of being public, and the Eliot Spitzer-driven Global Analyst Research Settlement of 2003 destroyed the business model for broker research, making it very difficult to get any information on many small and mid-cap equities. Without even biased market intelligence, investors simply stay away.</p>
<p>Monetary policy has not benefited the stock market either. Short-term rates at near zero and mortgage and high-yield bond rates at record lows should be good for equities. But the fear of deflation – a horrible development for equity markets as reduced wages and the incentive to delay buying will put a crimp on corporate revenues – is keeping would-be investors on the sidelines. I could go on.</p>
<p>But the point is clear: The challenge of fixing our equity markets is not as simple as “fixing” the market structure by widening spreads. Widening spreads across the board will only remove trading opportunities and increase trading costs. I would love to say widen spreads and tax the HFTs and everything will be fine, but in the end, I think increased spreads will only force institutional and retail investors to pay more for execution and make it harder to get in or out of an investment . . . and profits will just be re-allocated from the fast and fleet to slower players with larger pockets.</p>
<p>If we think by taxing high-frequency firms we will go back to a time when markets were slow and humans made trading decisions – forget it. When was the last time we replaced computers with humans?</p>
<p><em>Larry Tabb is founder and chief executive of Tabb Group</em></p>
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		<title>Post Reg NMS Market Structure Diagram</title>
		<link>http://blog.themistrading.com/?p=1326</link>
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		<pubDate>Wed, 25 Aug 2010 13:23:32 +0000</pubDate>
		<dc:creator>sarnuk</dc:creator>
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		<title>Major Money Managers Representing Retail Investors Speaking Out Against HFT</title>
		<link>http://blog.themistrading.com/?p=1323</link>
		<comments>http://blog.themistrading.com/?p=1323#comments</comments>
		<pubDate>Tue, 24 Aug 2010 17:35:25 +0000</pubDate>
		<dc:creator>sarnuk</dc:creator>
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		<description><![CDATA[Major Money Managers Representing  Retail Investors Speaking Out Against HFT
As we had anticipated, leading  institutional investors of primarily retail money are beginning to speak out  against the market structure that has helped foster HFT.  Here are three major  examples:
Kevin Cronin, Director of Global  Equity Trading at Invesco
Invesco (NYSE:  IVZ) is [...]]]></description>
			<content:encoded><![CDATA[<p><strong>Major Money Managers Representing  Retail Investors Speaking Out Against HFT</strong></p>
<p>As we had anticipated, leading  institutional investors of primarily retail money are beginning to speak out  against the market structure that has helped foster HFT.  Here are three major  examples:</p>
<p><strong>Kevin Cronin, Director of Global  Equity Trading at Invesco</strong></p>
<p>Invesco (NYSE:  IVZ) is a leading independent global  investment manager, providing a wide range of investment strategies and vehicles  to retail, institutional and high net worth clients around the world.  According to an August 10, 2010 news release,  Atlanta-based Invesco (<a title="http://www.invesco.com/" href="http://www.invesco.com/">www.invesco.com</a>) reported preliminary  month-end assets under management of $580.3 billion.</p>
<p>The following are comments Mr.  Cronin made in public testimony before the SEC’s June 2<sup>nd</sup> and the  CFTC’s August 11<sup>th</sup> roundtables on market  structure.</p>
<ul>
<li>“The  large and sudden price dislocations on May 6 were, in large measure, the result  of flaws and inefficiencies in the current U.S.  market structure.”</li>
<li>“In its  examination of the market events on May 6, the Advisory Committee should not  lose sight of the broader market structure issues raised by the SEC’s concept  release examining the structure of U.S. equity markets, including the  adequacy of information provided to investors about their orders, the impact of  high frequency trading, and undisplayed liquidity.”</li>
<li>“While  INVESCO believes there are many beneficial high frequency trading strategies and  participants which provide valuable liquidity and efficiencies to the markets,  we also believe there are some strategies that could be considered as improper  or manipulative activity.”</li>
<li>“There is  an immediate need for more information about high frequency traders and the  practices of high frequency trading firms. Additionally, regulators should act  to address the increasing number of order cancellations in the securities  markets. It has been theorized that as many as 95% of all orders entered by high  frequency traders are subsequently cancelled. Incentives that currently exist  for market participants to route orders to particular venues, such as liquidity  rebates, and any related conflicts of interest that may arise due to these  incentives also need to be examined.”</li>
<li>“Fragmented trading markets and the  differing rules and practices governing those markets were a significant factor  in the price declines experienced on May 6. Specifically, there is a need for an  examination of the use by exchanges of mechanisms to pause trading in a security  and the impact such action may have on other exchanges which may not have  similar mechanisms in place.”</li>
<li>“New  challenges also have been created by recent market structure developments, for  example there is still virtually no incentive for institutions to publically  post limit orders. This point was clearly on display on May  6.”</li>
<li>“We also  question whether high-frequency traders should be anointed yet as the modern-day  market makers, given that it is unclear whether they are truly providing  liquidity to the great majority of stocks in the markets.”</li>
</ul>
<p><strong>James P. McCaughan,  President &#8211; Global Asset Management, and CEO, Principal Global  Investors</strong></p>
<p>Mr. McCaughan oversees  all global asset management activities, including developing global strategies  and identifying and analyzing market opportunities.  The Principal Financial Group (NYSE: PFG) is  a leading global financial company offering businesses, individuals and  institutional clients a wide range of financial products and services.  According to an August 19, 2010 news release,  Des Moines-based Principal (<a title="http://www.principal.com/" href="http://www.principal.com/">http://www.principal.com</a>) has $284.7  billion in assets under management and serves some 18.9 million customers  worldwide.</p>
<p>The following are comments McCaughan  made in a July 9, 2010 interview with the FT and an August 23, 2010 interview  with CNBC.</p>
<ul>
<li>“Order to  one trading venue get shared with others. The problem is there is very strong  circumstantial evidence that it&#8217;s front run in many places. And that is why both  the SEC and FINRA have been looking at who is doing the trading in order to get  more forensic about trading patterns.”</li>
<li>“I am  talking when orders get pinged out to multiple trading venues, there is at least  circumstantial evidence that there&#8217;s quite widespread use of that information to  front-run trades&#8230;That&#8217;s fraud.”</li>
<li>“There  are traders who send out orders with no intention of filling them, simply to try  and see what activity it provokes.”</li>
<li>“It is  getting to the point that the investors are put off by the volatility that these  phenomena are causing, and that is actually quite dangerous. We want to be able  to look our investors in the eye and tell them the market is fair, and  unfortunately in the market it&#8217;s quite difficult to do  that.”</li>
<li>“The  trigger of May 6th is not all that important; the key issue is the vulnerability  of the market to a rapid move. The instability that led to the flash crash  arises from a number of places. I think one source of instability is high  frequency trading.”</li>
<li>“Many of  the HFT efforts amount to destructive front running  schemes.”</li>
<li>“Oh yes,  I think the SEC was correct into moving towards uniform circuit breakers. But  what the flash crash is a good example of, is the unfairness, and the inequity  that is built in to the market by giving, in particular, high frequency traders  access to information that other investors don’t have.”</li>
</ul>
<p><strong>Jeff Engelberg, Principal  and Senior Trader at Southeastern Asset  Management</strong></p>
<p>According to Mr.  Engelberg’s June 22, 2010 statement to  SEC‐CFTC  Panel Regarding the Events of May 6, 2010, Memphis-based Southeastern manages approximately $35 billion, serving  investors via The Longleaf Partners Funds (<a title="http://www.longleafpartners.com/" href="http://www.longleafpartners.com/">www.longleafpartners.com</a>) and  through 210 separate accounts, most of which are non‐taxable pensions,  endowments, and foundations.</p>
<p>The following are comments Mr. Engelberg made in  his April 28<sup>th</sup> comment letter to the SEC, and public testimony before  the SEC’s June 22<sup>nd</sup> and the CFTC’s August 11<sup>th</sup> roundtables  on market structure.</p>
<ul>
<li>“Our  psychology has fallen victim to a notion that, without qualification, technology  and speed should be embraced. Contrary to the claim that speed reduces risk, the  introduction of excessive speed and unrestrained technology destabilized the  markets and made them wholly indecipherable on May 6. We ask the Committee to  weigh the benefits of microsecond by microsecond access against the costs of  market instability and loss of investor confidence and ask why humans with  direct access to the markets need to be licensed but technology does not. There  are few events in life requiring decision making which can be altered in less  than the blink of an eye. We do not feel that securities trading falls into that  category.”</li>
<li>“Further,  it strikes us as discontinuous that the markets sanction microsecond speed in  calm waters but slow down in times of turbulence through circuit breakers and  Liquidity Replenishment Points (LRPs). Why are remedial responses a preferred  course over preventative actions? Has speed reached an inflection point and  become a liability to the markets?”</li>
<li>“Some  participants have access to proprietary market data feeds while others do not.  Short-term traders with premium data feeds receive an instantaneous view into  the future, i.e., the order flows through the feeds. This is similar to a casino  with odds favoring the house.&#8221;</li>
<li>“This  Committee and the regulatory community at large should not try and will never be  able to buffer the markets from unexpected and challenging news.  However, the mechanisms by which the market  digests information, discovers price, and continues to function through any and  all events should be of significant focus and concern. I believe May 6 should be  seen as a symptom of underlying weaknesses in market structure, and our response  should seek to correct the underlying structural problems in the market which  are currently being exploited, and, in the case of May 6, most likely  mishandled.”</li>
<li>“The  US equity markets are meant  to facilitate investors&#8217; allocation of capital to businesses, thus expanding  production and improving the quality of life in America. The markets have strayed  from this social purpose, and presently resemble casinos more than orderly  markets. As a result, the economy is hindered, fewer jobs are created, and  reasonable returns for true investors (not traders) are  compromised.”</li>
</ul>
<p>We applaud the leadership of these  individuals, and the firms they represent. It is encouraging to see the &#8221;Owners  of The Market&#8221; step forward and probe our current equity market structure.  Not  only is the tide turning against HFT, but clearly industry leaders are seriously  concerned. We anticipate more institutional money managers speaking out, and  welcome their voices in this long marathon of a debate.</p>
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		<title>Media wakes up to HFT concerns</title>
		<link>http://blog.themistrading.com/?p=1319</link>
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		<pubDate>Tue, 24 Aug 2010 12:20:57 +0000</pubDate>
		<dc:creator>jsaluzzi</dc:creator>
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		<description><![CDATA[Ok, who woke up the media and told them about what has been going on in the stock market over the past two years?  After being one of the few critical voices trying to be heard over a chorus of HFT cheerleaders, we at Themis Trading have been pleasantly surprised with all the critical attention [...]]]></description>
			<content:encoded><![CDATA[<p>Ok, who woke up the media and told them about what has been going on in the stock market over the past two years?  After being one of the few critical voices trying to be heard over a chorus of HFT cheerleaders, we at Themis Trading have been pleasantly surprised with all the critical attention HFT has been getting lately in the press.  Just in the past few days we have been greeted by these stories:</p>
<p> August 22, 2010 NY Times: <em>&#8220;Stock Swing Still Baffles, With an Ominous Tone</em>&#8220;  &#8211; “There is a credible allegation that there is seriously abusive practices going on,” said James J. Angel, a financial market analyst specialist at Georgetown University, “to the extent that somebody is firing in a very high frequency of orders for no good economic reason, basically because they are trying to slow everybody else down.” <a href="http://www.nytimes.com/2010/08/23/business/23flash.html?_r=1&amp;dbk">http://www.nytimes.com/2010/08/23/business/23flash.html?_r=1&amp;dbk</a></p>
<p>August 22, 2010 Financial Times: <em>&#8220;Brokers face fines over role in flash crash</em>&#8221; -  “The sub-custodian chain can bury the identity of high-frequency traders in Eastern Europe and elsewhere who raise serious regulatory concerns,” Richard Ketchum, chairman and chief executive of Finra, told the Financial Times. <a href="http://www.ft.com/cms/s/0/0ab57556-ae17-11df-bb55-00144feabdc0.html">http://www.ft.com/cms/s/0/0ab57556-ae17-11df-bb55-00144feabdc0.html</a></p>
<p>August 24, 2010 WSJ: &#8220;<em>Saving the Stock Market Only to Destroy It&#8221; </em>by Dennis Berman &#8211; &#8220;They thought they were saving the stock market. They ended up maiming it&#8230;Yet somehow we have wound up right where we began: with a market that many perceive as tainted and prone to gaming by a cadre of insiders. Only this time, instead of wielding the biggest, baddest berth on the New York Stock Exchange floor, they are wielding the biggest, baddest computers&#8230;.Saving money has taken its own toll. The market has become deeply fragmented, traded across at least 50 trading venues both large and small. Those high-frequency traders now making the markets have only the option and not the responsibility to step in at a time of distress like the flash crash. In other words, we have traded cheaper up-front costs for unknown back-end ones. That is exactly what is spooking the same investors the SEC vowed to protect in 2005.&#8221;  <a href="http://online.wsj.com/article/SB10001424052748704340504575447862115744190.html?mod=googlenews_wsj">http://online.wsj.com/article/SB10001424052748704340504575447862115744190.html?mod=googlenews_wsj</a></p>
<p> The noose is starting to tighten now on HFT as the masses begin to demand change.   But, if the heat gets too much for some of the HFT&#8217;s, they may want to consult Mike &#8220;The Situation&#8221; Sorrentino from MTV&#8217;s Jersey Shore for their next venture.  After having to put up with Snookie and getting ambushed by some &#8220;grenades&#8221; in the hot tub, The Situation is about to cash in.  The Hollywood Reporter is reporting that he will earn $5 million in 2010 <a href="http://www.hollywoodreporter.com/hr/content_display/news/e3i0aa95b30b2cefc020fe37ded26061f7c">http://www.hollywoodreporter.com/hr/content_display/news/e3i0aa95b30b2cefc020fe37ded26061f7c</a>   Now, that is a lot of scarole for a guy whose day consists of &#8220;GTL&#8221;  (that would be gym, tanning and laundry for those of you who have never seen the show).</p>
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		<title>Jim McCaughan on CNBC Squawk this morning</title>
		<link>http://blog.themistrading.com/?p=1316</link>
		<comments>http://blog.themistrading.com/?p=1316#comments</comments>
		<pubDate>Mon, 23 Aug 2010 14:39:32 +0000</pubDate>
		<dc:creator>sarnuk</dc:creator>
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		<description><![CDATA[http://www.cnbc.com/id/15840232?video=1572716553&#38;play=1


Listen 06:30  on!


The tide is turning  folks. Kudos Mister McCaughan. He nails HFT and more importantly our market stucture for what it is, and explains the link to investor confidence, with eloquence and quiet logic and confidence.

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<div><span style="font-family: Arial; font-size: x-small;">Listen 06:30  on!</span></div>
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<div><span style="font-family: Arial; font-size: x-small;">The tide is turning  folks. Kudos Mister McCaughan. He nails HFT and more importantly our market stucture for what it is, and explains the link to investor confidence, with eloquence and quiet logic and confidence.<br />
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