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It is my view that one of
the most significant causes of the global financial crisis was a lack of
transparency in financial markets. Put simply, that means no one, not
regulators or market participants, knew what the size of certain derivatives markets
(like credit default swaps) was, who held what positions, or what the
consequences of holding positions could be. If financial reform brings
nothing else, it should at least hold banks accountable for the business they
conduct, and that means full disclosure and constant monitoring by responsible
This action would help provide the basis for
preventing future crises. No matter how inventive financial products may
become, if regulators have complete and detailed information about financial
markets and banks’ activities there, better assessments of risk can be made.
This means that if necessary, banks’ activities can be reigned in through
higher capital requirements or similar measures. Simply limiting banks’
ability to conduct certain business is a blunt instrument that does not resolve
the lack of transparency and likely will hamper economic growth.
Market transparency exhibits itself in many forms. Particularly relevant is that related to electronic trading. Therefore, I predict that regulators will require
banks to implement relevant stronger pre-trade risk mechanisms. Regulators, such as the
FSA & SEC, will ultimately bring in new rules to mitigate against, for example, the risk
of algorithms ‘going mad’. This is exemplified by Credit Suisse, which was
fined $150,000 by the NYSE earlier this year for “failing to adequately
supervise development, deployment and operation of proprietary algorithms.”
Furthermore, volumes traded via high frequency
trading will increase, although at a much slower pace than last year, and at
the same time the emotive debates about high frequency trading creating a
two-tier system and an unfair market will die down.
In addition, with regards to mid market MiFID
monitoring, greater responsibility for compliance will be extended from
exchanges to the banks themselves. Banks and brokers will soon be mandated to
implement more trade monitoring and surveillance technology. There will also be
no leeway on Dark Pools; they just simply have to change and be mandated to
show they have adequate surveillance processes and technology in place. They
will also have to expose more pricing information to the market and regulators.
This year will see a definite shift to an
increasingly transparent – and therefore improved – working environment within
capital markets. The ongoing development of market surveillance technologies
and changes in attitudes to compliance will drive this forward, creating a more
open and fairer marketplace for all.
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