Archive for November, 2010

November 10, 2010

Wednesday, November 10th, 2010

People sometimes pretend that mutual fund MERs are too high. But that’s what people want:

Value of Canadian mutual fund assets: $720-billion

Value of Canadian-listed exchange-traded funds: $36.2-billion

Value of segregated fund assets in Canada: $83.3-billion

Value of hedge fund assets in Canada: $45.7-billion

Value of closed-end funds: $24.1-billion

The Financial Post reports that a real newspaper reports that RBC is too big to fail on a global basis:

Royal Bank of Canada has appeared on a list of banks that have been deemed by global authorities as being too big to fail, according to the Financial Times.

The G20 will put off a decision on whether to impose an international capital surcharge for the world’s most vital banks, which would force them to maintain additional capital buffers to help them withstand market shocks, the Financial Times report said.

While it may not be explicitly settled at this week’s G20 meeting, it is understood that the banks that are deemed too big to fail will need to raise even more capital than their peers as extra insurance against their sizable reach and influence over the world’s economy.

There are signs the US fiscal deficit is intractable:

The co-chairmen of President Barack Obama’s debt-reduction commission will propose cuts to Social Security and Medicare, as well as reductions in income tax rates in exchange for curbing tax breaks, according to a Republican aide who attended the meeting.

The chairmen’s plan is already causing some Democrats and Republicans on the 18-member commission to balk. The plan will be announced at 1 p.m. Washington time today, said commission spokesman Fred Baldassaro.

Fearless forecast: the problem will remain intractable until the President gets a call from the Treasury saying they’re having big problems selling a bond issue and can he please start working the ‘phones. Then whichever party’s in power will start showing some sense.

The 30-year Treasury auction was disappointing:

Treasury 30-year bonds declined for a sixth day as the U.S. sold $16 billion of the securities amid concern yields will continue to climb as the Federal Reserve focuses its purchases on shorter-maturity debt.

The bonds drew a yield of 4.32 percent, compared with the average forecast of 4.288 percent in a Bloomberg News survey of eight of the Fed’s 18 primary dealers. The bid-to-cover ratio, which gauges demand by comparing total bids with the amount of securities offered, was 2.31, the lowest since November 2009.

In a primer titled A Survival Guide to Bonds, by Rob Carrick of the Globe and Mail, there is a most interesting quote:

“For most of the time in the past 13 years or so, bonds have been negatively correlated to stocks,” explains Michael Herring, managing director and investment strategist at BMO Nesbitt Burns. “When stocks are down, bonds are up. So they provide a nice diversification effect, a counterbalance that dampens the volatility of the overall portfolio.”

That’s not what the Kansas City Fed thinks! In the construction of their Financial Stress Index, they indicate that the “Negative value of correlation between stock and Treasury returns” is an indicator of “Flight to Quality” and therefore a stress indicator. They cite other studies showing that this holds true for other government bond returns; specifically, the measure used is computed over rolling three month periods using the S&P500 and a 2-year Treasury bond index.

MSCI-BARRA published an interesting piece on stock-bond correlation in 2009.

The Canadian preferred share market showed little direction today – for a change! – although volume continued to be high. PerpetualDiscounts lost 3bp, while FixedResets gained 6bp, taking the median weighted average Yield to Worst on the latter index down to 2.84% – yet another new low.

PerpetualDiscounts now yield 5.28%, equivalent to 7.39% interest at the standard equivalency factor of 1.4x. Long Corporates now yiel about 5.3%, so the pre-tax interest-equivalent spread is now about 210bp, a sharp tightening from the 230bp reported on November 3.

HIMIPref™ Preferred Indices
These values reflect the December 2008 revision of the HIMIPref™ Indices

Values are provisional and are finalized monthly
Index Mean
Current
Yield
(at bid)
Median
YTW
Median
Average
Trading
Value
Median
Mod Dur
(YTW)
Issues Day’s Perf. Index Value
Ratchet 0.00 % 0.00 % 0 0.00 0 -0.1270 % 2,229.2
FixedFloater 4.94 % 3.55 % 27,261 19.12 1 -0.2268 % 3,402.8
Floater 2.67 % 2.34 % 65,952 21.40 4 -0.1270 % 2,407.0
OpRet 4.78 % 2.89 % 80,621 1.86 9 0.0127 % 2,396.7
SplitShare 5.84 % -16.73 % 67,067 0.09 2 0.1007 % 2,412.7
Interest-Bearing 0.00 % 0.00 % 0 0.00 0 0.0127 % 2,191.6
Perpetual-Premium 5.62 % 5.07 % 162,883 2.75 24 0.0779 % 2,029.6
Perpetual-Discount 5.28 % 5.28 % 256,830 14.86 53 -0.0274 % 2,067.9
FixedReset 5.19 % 2.84 % 351,316 3.21 50 0.0557 % 2,297.8
Performance Highlights
Issue Index Change Notes
GWO.PR.I Perpetual-Discount -1.82 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-10
Maturity Price : 21.60
Evaluated at bid price : 21.60
Bid-YTW : 5.28 %
FTS.PR.G FixedReset -1.28 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2013-10-01
Maturity Price : 25.00
Evaluated at bid price : 26.26
Bid-YTW : 3.22 %
MFC.PR.C Perpetual-Discount -1.06 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-10
Maturity Price : 21.42
Evaluated at bid price : 21.42
Bid-YTW : 5.34 %
ENB.PR.A Perpetual-Premium 1.22 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2010-12-10
Maturity Price : 25.00
Evaluated at bid price : 25.72
Bid-YTW : -30.35 %
BAM.PR.M Perpetual-Discount 1.66 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-10
Maturity Price : 21.47
Evaluated at bid price : 21.47
Bid-YTW : 5.61 %
Volume Highlights
Issue Index Shares
Traded
Notes
BNS.PR.Q FixedReset 122,290 RBC crossed blocks of 70,000 and 25,000, both at 26.61.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2013-11-24
Maturity Price : 25.00
Evaluated at bid price : 26.61
Bid-YTW : 2.75 %
TD.PR.M OpRet 110,555 Scotia crossed 97,900 at 25.90.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2010-12-10
Maturity Price : 25.75
Evaluated at bid price : 25.86
Bid-YTW : 0.88 %
HSB.PR.D Perpetual-Discount 93,734 RBC crossed blocks of 32,000 and 27,400, both at 23.48, then another 24,500 at 23.50.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-10
Maturity Price : 23.27
Evaluated at bid price : 23.50
Bid-YTW : 5.38 %
TD.PR.Y FixedReset 76,481 RBC sold blocks of 10,000 and 21,400 to anonymous, both at 26.75, then crossed 10,700 at 26.72.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2013-11-30
Maturity Price : 25.00
Evaluated at bid price : 26.75
Bid-YTW : 2.64 %
MFC.PR.A OpRet 73,532 Nesbitt crossed 30,000 at 25.60.
YTW SCENARIO
Maturity Type : Soft Maturity
Maturity Date : 2015-12-18
Maturity Price : 25.00
Evaluated at bid price : 25.61
Bid-YTW : 3.72 %
TD.PR.E FixedReset 44,033 TD crossed 35,000 at 27.85.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-05-30
Maturity Price : 25.00
Evaluated at bid price : 27.92
Bid-YTW : 2.85 %
There were 49 other index-included issues trading in excess of 10,000 shares.

November 9, 2010

Tuesday, November 9th, 2010

Here’s another exhibit regarding the reluctance of asset management firms to promote star managers:

Roger Guy and Guillaume Rambourg, Gartmore Group Ltd.’s two star managers, won European fund of the year at a black-tie gala at London’s Grosvenor House Hotel on Jan. 21. Ten months later, both have quit and the company is considering putting itself up for sale.

Rambourg and Guy together managed about a third of the company’s assets after its IPO. Three other managers have departed, prompting the company to hire Goldman Sachs Group Inc. to help find a buyer after investors including Skandia Investment Management Ltd. pulled or planned to pull 3.3 billion pounds ($5.3 billion), or about 14 percent of its assets under management, since Rambourg was suspended in March. The performance of their funds has lagged behind competitors this year, according to data compiled by Bloomberg.

… and here’s one about the usual effect of politicized regulation:

U.S. airlines canceled 4,754 flights in September, a 62 percent jump from the same month a year ago, as the government requires carriers to let passengers off stuck flights within three hours.

Carriers are seeking to avoid fines as high as $27,500 per customer stuck on a plane during a lengthy delay under the rule by Transportation Secretary Ray LaHood. Airlines said the requirement would lead to cancellations, and as of September an additional 5,000 flights were scrapped, an 18 percent rise, since the rule took effect.

“Cancellations are a much worse result for passengers” than long delays, said David Stempler, president of the Air Travelers Association, an advocacy group in Chevy Chase, Maryland. “The time it takes them to get to their destinations may last up to days” after a flight is scrubbed, he said.

One of China’s major credit rating agencies has downgraded the US to A+:

China’s Dagong Global Credit Rating Co. reduced its credit rating for the U.S. to A+ from AA, citing a deteriorating intent and ability to repay debt obligations after the Federal Reserve announced more monetary easing.

The credit outlook for the U.S. is “negative,” as the Fed’s plan to buy government debt will erode the value of the dollar and “entirely encroaches” on the interests of creditors, analysts at Dagong, one of China’s five official ratings companies, said in a statement.

Dagong, seeking to become an alternative to S&P, Moody’s and Fitch Ratings, ranks China’s debt higher than that of the U.S. and Japan, citing widening deficits in the developed world. Global ratings methodology is “irrational,” Dagong Chairman Guan Jianzhong said in July, and “cannot truly reflect repayment ability.”

In September, the Securities and Exchange Commission denied the application of Dagong to become a Nationally Recognized Statistical Rating Organization in the U.S.

Life will become even more fun if the EU sets up its own captive credit rater!

I ran across an interesting essay … The Impact of High Frequency Trading on the Canadian Market by members of the BMO-CM Quantitative Execution Services, dated July 2009 … it’s filled with the familiar booHooHoos about Portfolio Managers having their lunch eaten. I mean, look at this:

Liquidity has become less obvious – As predatory high frequency trading creates extra volume without creating additional real liquidity, it become increasing difficult for fund managers to discern the real achievable liquidity in a given stock. To date we have witnessed many instances where portfolio managers looking at total trading volume attempt to buy (sell) too much of a given stock resulting in additional market impact. This cost is again shouldered by the individual end clients

They hired an incompetent manager and it cost them. I’m not wringing my hands.

We have had several discussions with Canadian buy side accounts who have noted the decreasing effectiveness of their pre-trade analytic tools. Typically these tools rely on volume and a number of other market metrics (e.g. spread, volatility) to predict the impact a given order will have on the market for that issue. As ‘real’ volume becomes less discernable these tools have greater difficulty determining this number. Portfolio managers, who have become increasingly reliant on these tools over the last several years, are becoming increasingly frustrated with their performance.

Not frustrated enough, apparently, to do a damn bit of work to fix the problem.

The Bank of Canada has released a working paper by Céline Gauthier, Zhongfang He and Moez Souissi titled Understanding Systemic Risk: The Trade-Offs between Capital, Short-Term Funding and Liquid Asset Holdings:

We offer a multi-period systemic risk assessment framework with which to assess recent liquidity and capital regulatory requirement proposals in a holistic way. Following Morris and Shin (2009), we introduce funding liquidity risk as an endogenous outcome of the interaction between market liquidity risk, solvency risk, and the funding structure of banks. To assess the overall impact of different mix of capital and liquidity, we simulate the framework under a severe but plausible macro scenario for different balance-sheet structures. Of particular interest, we find that (1) capital has a decreasing marginal effect on systemic risk, (2) increasing capital alone is much less effective in reducing liquidity risk than solvency risk, (3) high liquid asset holdings reduce the marginal effect of increasing short term liability on systemic risk, and (4) changing liquid asset holdings has little effect on systemic risk when short term liability is sufficiently low.

I don’t like it much becaue it does not address the role of the Central Bank in reducing liquidity risk.

Regulators continue to run amok in the UK, once best known as the home of Magna Charta:

Traders’ mobile-telephone calls may be taped in an effort to stamp out insider trading under new rules scheduled to be published by the U.K. financial regulator as soon as this week.

The Financial Services Authority has said cell phones used for business shouldn’t be exempt from rules requiring banks and brokerages to record employees’ calls so that they can be listened to later. In March, the agency said in draft proposals that around 22,000 phones would be covered.

The regulator in September warned companies to prevent leaks to the media as part of its effort to crack down on market abuse. The FSA started to cold-call traders to interview them under caution two years ago about possible insider trading, a strategy that fell prey to hoax calls.

“We continue to work to keep undesirable people out of our financial services industry,” FSA enforcement chief Margaret Cole said in a speech yesterday. “We use information and intelligence from a range of sources to consider whether those who own or run financial firms, as well as people in sensitive roles within those businesses, are ‘fit and proper.’”

There’s more about the cold-calling here. For now, it’s all to the good – I know some fine immigrants from the UK who came here out of disgust with the ubiquitous camera monitors, ASBOs and so on. But this trend will eventually hurt us all.

Another strong day on the Canadian preferred share market, but this time with a big difference in inter-sector performance. PerpetualDiscounts gained 41bp, while FixedResets lost 3bp; today’s performance takes the Bozo Spread (the difference between PerpetualDiscount and FixedReset Current Yields) down to a mere 9bp. I am all agog to see if this spread goes negative … it is my theory that this spread shows the retail perception of the interest rate risk inherent in a Straight Perpetual … but who knows? Maybe it doesn’t. Volume was very heavy.

HIMIPref™ Preferred Indices
These values reflect the December 2008 revision of the HIMIPref™ Indices

Values are provisional and are finalized monthly
Index Mean
Current
Yield
(at bid)
Median
YTW
Median
Average
Trading
Value
Median
Mod Dur
(YTW)
Issues Day’s Perf. Index Value
Ratchet 0.00 % 0.00 % 0 0.00 0 0.1272 % 2,232.1
FixedFloater 4.93 % 3.53 % 27,559 19.14 1 -0.6757 % 3,410.6
Floater 2.67 % 2.34 % 64,550 21.40 4 0.1272 % 2,410.0
OpRet 4.78 % 2.87 % 80,881 1.87 9 -0.1875 % 2,396.4
SplitShare 5.84 % -14.84 % 66,296 0.09 2 -0.0403 % 2,410.3
Interest-Bearing 0.00 % 0.00 % 0 0.00 0 -0.1875 % 2,191.3
Perpetual-Premium 5.62 % 5.01 % 160,386 3.08 24 -0.0805 % 2,028.0
Perpetual-Discount 5.28 % 5.27 % 257,751 14.96 53 0.4123 % 2,068.4
FixedReset 5.19 % 2.86 % 352,075 3.21 50 -0.0298 % 2,296.6
Performance Highlights
Issue Index Change Notes
BAM.PR.H OpRet -1.53 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2010-12-09
Maturity Price : 25.25
Evaluated at bid price : 25.70
Bid-YTW : -8.13 %
FTS.PR.H FixedReset 1.02 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2015-07-01
Maturity Price : 25.00
Evaluated at bid price : 26.00
Bid-YTW : 3.23 %
RY.PR.D Perpetual-Discount 1.07 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 22.57
Evaluated at bid price : 22.73
Bid-YTW : 4.96 %
RY.PR.E Perpetual-Discount 1.12 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 22.49
Evaluated at bid price : 22.65
Bid-YTW : 4.97 %
SLF.PR.C Perpetual-Discount 1.13 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 21.53
Evaluated at bid price : 21.53
Bid-YTW : 5.24 %
SLF.PR.E Perpetual-Discount 1.21 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 21.46
Evaluated at bid price : 21.77
Bid-YTW : 5.22 %
FTS.PR.F Perpetual-Discount 1.22 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 23.21
Evaluated at bid price : 23.42
Bid-YTW : 5.23 %
TD.PR.O Perpetual-Discount 1.24 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 24.30
Evaluated at bid price : 24.57
Bid-YTW : 4.96 %
RY.PR.F Perpetual-Discount 1.30 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 22.41
Evaluated at bid price : 22.56
Bid-YTW : 4.94 %
RY.PR.A Perpetual-Discount 1.33 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 22.62
Evaluated at bid price : 22.80
Bid-YTW : 4.88 %
NA.PR.L Perpetual-Discount 1.45 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 23.59
Evaluated at bid price : 23.85
Bid-YTW : 5.09 %
MFC.PR.B Perpetual-Discount 1.61 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 21.79
Evaluated at bid price : 22.10
Bid-YTW : 5.33 %
GWO.PR.I Perpetual-Discount 1.62 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 21.65
Evaluated at bid price : 22.00
Bid-YTW : 5.16 %
Volume Highlights
Issue Index Shares
Traded
Notes
MFC.PR.A OpRet 151,540 RBC bought 35,700 from Nesbitt at 25.59. RBC then crossed 24,300 at 25.59, while Nesbitt crossed 57,000 at 25.60.
YTW SCENARIO
Maturity Type : Soft Maturity
Maturity Date : 2015-12-18
Maturity Price : 25.00
Evaluated at bid price : 25.60
Bid-YTW : 3.72 %
BNS.PR.N Perpetual-Discount 120,002 Desjardins crossed 10,000 at 25.09; RBC crossed 70,500 at 25.14. Anonymous crossed (?) 13,000 at 25.14.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2017-02-26
Maturity Price : 25.00
Evaluated at bid price : 25.06
Bid-YTW : 5.27 %
PWF.PR.P FixedReset 117,485 TD crossed 10,700 at 26.25, then sold 10,000 to Desjardins at 26.27. Finally, TD crossed 39,500 at 26.00.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 23.44
Evaluated at bid price : 26.00
Bid-YTW : 3.44 %
BNS.PR.J Perpetual-Discount 89,000 RBC crossed 76,500 at 25.15.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 23.41
Evaluated at bid price : 25.11
Bid-YTW : 5.17 %
RY.PR.F Perpetual-Discount 88,487 RBC crossed 50,000 at 22.56.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 22.41
Evaluated at bid price : 22.56
Bid-YTW : 4.94 %
RY.PR.A Perpetual-Discount 87,814 RBC crossed 47,900 at 22.78.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-09
Maturity Price : 22.62
Evaluated at bid price : 22.80
Bid-YTW : 4.88 %
There were 64 other index-included issues trading in excess of 10,000 shares.

Dickson speaks against IFRS Exposure Draft

Tuesday, November 9th, 2010

Julie Dickson spoke against the IFRS Exposure Draft on Insurance Contracts in a speech at the 2010 Life Insurance Invitational Forum:

On the “positive side”, the new approach might better capture financial risks of companies, particularly equity and interest rate risks, and thus provide more early warnings of risks. On the “negative” side, the discount rate change could potentially lead to extreme earnings volatility especially given the large blocks of long-duration guaranteed product liabilities on the books of Canadian insurance companies. As such, we think the proposals may go too far in terms of capturing short-term interest rate movements on long-term exposures. Consequently, we are working on options to help deal with this issue.

In fact we are encouraged by recent developments in this regard. One such development is that the IASB’s Insurance Working Group is meeting later this week to discuss possible ways to minimize the effects of any inappropriate volatility. This group’s objective is to analyze accounting issues relating to insurance contracts. The group brings together a wide range of interests and includes senior financial executives who are involved in financial reporting. Other developments closer to home are discussions by the Canadian Accounting Standards Board’s Insurance Accounting Task Force and the Canadian Institute of Actuaries group to develop their comment letters to the IASB. Both these groups are discussing the volatility issue.

OSFI is committed to continuing to work with industry and other international stakeholders as we complete our response to the IASB, which is due November 30th. We encourage the industry to contribute to this work; the more that we work together, the better the result will be.

See also the Canada Life and Health Insurance Association comment letter, discussed briefly in the post SLF Coy on Capital Rule Changes.

FDIC Addresses Systemic Risk

Tuesday, November 9th, 2010

Bloomberg reported today:

The FDIC board today approved two proposals for overhauling assessments for its deposit insurance fund, including one that would base the fees on banks’ liabilities rather than their domestic deposits. The fee proposal, a response to the Dodd- Frank financial-regulation law, would increase assessments on banks with more than $10 billion in assets.

The measure would increase the largest banks’ share of overall assessments to 80 percent from the present 70 percent, the FDIC said. The assessment increase would be in place by the second quarter of next year, according to the proposal.

“It’s a sea change in that it breaks the link between deposit insurance and deposits for the first time,” Acting Comptroller of the Currency John Walsh said today. “It is significant.”

The proposal would increase assessment rates on banks that hold unsecured debt of other lenders. That step was proposed to address risk that is retained in the system even as it is removed from one bank’s holdings.

It is this last bit that makes me happy. The Basel rules allow banks to risk-weight other banks’ paper as if was issued by the sovereign – which is simply craziness. The FDIC memorandum – which we can only hope will survive the comment period and spread to Canada, if not world-wide – is going to charge them extra deposit insurance premiums on the long-term portion of these assets:

Depositary Institution Debt Adjustment

Staff recommends adding an adjustment for those institutions that hold long-term unsecured liabilities issued by other insured depositary institutions. Institutions that hold this type of unsecured liability would be charged 50 basis points for each dollar of such long-term unsecured debt held. The issuance of unsecured debt by an IDI lesens the potential loss to the [Deposit Insurance Fund] in the event of an IDI’s failure; however, when such debt is hel by other IDIs, the overall risk in the system is not reduced. The intent of the increased assessment, therefore, is to discourage IDIs from purchasing the long-term unsecured debt of other IDIs.

There are many other adjustments and changes; I cannot comment on the specifics of the proposal because the data that would assist with the evaluation of the calibration of the adjustments is not available. The comments on this proposed rule will be most interesting!

Update, 2010-11-10: The FDIC has published the official notice.

November 8, 2010

Monday, November 8th, 2010

The Canadian Securities Administrators have brought in proposals to maximize the risk of single-point failure in Canada, titled Consultation Paper 91‐401 on Over‐the‐Counter Derivatives Regulation in Canada. One of the risks outlined is the potential for doing business in a productive manner:

Regulatory inaction is not an option given the commitments Canada has made as part of the G20. Notwithstanding Canada’s G20 commitments, there are compelling reasons to introduce regulation. Because OTC derivatives trading takes place across borders, if other countries adopt stringent regulations, and Canada does not act, it may gain a reputation as a haven, resulting in regulatory arbitrage and a flight of risky trading to Canada.

Mind you, the scare factor of “risky trading” is inflammatory bullshit. The proposals are all about central clearing, not “risky trading”.

The Canadian Securities Law blog advises:

CNSX Markets Inc., the operator of the Canadian National Stock Exchange and Pure Trading has proposed amendments to its Policy 2 that would extend listing eligibility to certain prospectus-exempt debt securities. The amendments to Policy 2 would mirror language contained in its Restated Order. Comments are being accepted on the amendments for 30 days from today.

OSC Notice 2010-006 specifies:

The prospectus-exempt debt securities that CNSX Markets seeks to list are currently distributed to the public in Canada under the exemptions set out in the Restated Order, following which the securities are freely traded over-the-counter with settlement through FundServ.

This might mean simply GICs: FundSERV is making a push in this market:

FundSERV announces the launch of GICSERV, an industry wide network for automating brokered GIC transactions. The first release of industry standards are now available for comment.

“We saw the brokered GIC market as a perfect chance for FundSERV to utilize its business and technical capabilities to further support our existing distribution customers and other participants in this financial services segment,” said Brian Gore, president and chief executive officer at FundSERV. “Our goal is to allow our existing network to facilitate standards and automation in the brokered GIC market.”

It will be most interesting to see how the CNSX proposal unfolds. Will it be strictly a new issue market – for instance, if you bid 2.55% for a five year GIC and somebody hits you, will you get a brand new GIC with a 2.55% coupon? Probably not, since that would restrict the sellers to issuers only. Perhaps there will be conversion formulas and such, so that when you get hit on your 2.55% bid, you get whatever the seller wants to deliver … a higher (lower) coupon with a lower (higher) price. In such a case, I will be fascinated to see whether the brokerages start showing account statments with the price of the GIC marked to market.

However, PPNs might be the securities in question:

Treatment of Deposit Products

SSI commented that clarification is required to address the treatment of deposit products held in dealer client accounts, such as Guaranteed Investment Certificates (“GICs”) or Principal Protected Notes (“PPNs”) and asked how accrued interest is to be addressed in determining market values.

MFDA Response

The market value of GICs should be reported as the principle amount plus accrued interest earned as at the end of the account statement period.

With respect to reporting the value of PPNs, certain PPNs have market values that are available on FundSERV. However, for PPNs that do not have a reliable market value, the book value should be reported.

Political manoeuvering over the Volcker Rule was mentioned briefly on November 4. Jim Hamilton’s World of Securities Regulation has more details and supporting documentation, and a post detailing support for the Rule. There is also some reason to hope that US Covered Bonds will be forthcoming.

Pam Martens writes an entertaining, if paranoid, account of the Flash Crash titled The “Flash Crash” Cover-Up:

The official report does not break out the wealth destruction to the small investor on May 6, but Ms. Schapiro shared that information on September 7 with the Economic Club of New York: “A staggering total of more than $2 billion in individual investor stop loss orders is estimated to have been triggered during the half hour between 2:30 and 3 p.m. on May 6. As a hypothetical illustration, if each of those orders were executed at a very conservative estimate of 10 per cent less than the closing price, then those individual investors suffered losses of more than $200 million compared to the closing price on that day.”

A stop-loss order is the dull Boy Scout knife with which the small investor attempts to protect himself from the star wars gang. It is an order placed with an unlimited time frame that sits in the system and says if my stock trades down to this level, sell me out. Unfortunately, most of these orders are placed as market orders rather than indicating a specific “limit” price that the investor will accept. (That alternative order is called a stop-loss limit order.) Stop-loss market orders go off on the next tick after the designated price is reached. In a liquid and orderly market, that should be only a fraction away from the last trade. On the day of the Flash Crash during that pivotal half hour, the next tick was frequently 10 to 60 per cent away from the last trade.

The SEC has banned stub-quotes:

The new rules address the problem of stub quotes by requiring market makers in exchange-listed equities to maintain continuous two-sided quotations during regular market hours that are within a certain percentage band of the national best bid and offer (NBBO). The band would vary based on different criteria:

  • For securities subject to the circuit breaker pilot program approved this past summer, market makers must enter quotes that are not more than 8% away from the NBBO.
  • For the periods near the opening and closing where the circuit breakers are not applicable, that is before 9:45 a.m. and after 3:35 p.m., market makers in these securities must enter quotes no further than 20% away from the NBBO.
  • For exchange-listed equities that are not included in the circuit breaker pilot program, market makers must enter quotes that are no more than 30% away from the NBBO.
  • In each of these cases, a market maker’s quote will be allowed to “drift” an additional 1.5% away from the NBBO before a new quote within the applicable band must be entered.

The new market maker quoting requirements will become effective on Dec. 6, 2010.

For the life of me, I don’t understand why the exchanges and the SEC ever permitted stub quotes in the first place. Market Makers get special privileges – from the SEC’s perspective, exemptions from the various short-sale rules – so why were they allowed to pay for them with debased coin?

Here’s one reason QE2 might not work:

Rather than providing money to businesses and consumers, U.S. commercial banks are increasingly using the cash available at interest rates set by the Federal Reserve that are next to zero and lending it back to the government. Since June, the biggest banks bought about $127 billion of Treasuries, compared with $47 billion in the first half, according to the central bank. Commercial and industrial loans outstanding have fallen by about $68.5 billion this year, central bank data show.

The Basel III regulations set by the Bank for International Settlements in Basel, Switzerland, may trim economic growth by 0.1 percent and 0.9 percent, and result in $400 billion of additional Treasury purchases by U.S. commercial banks by 2015, a committee of bond dealers and investors that advises Treasury Secretary Timothy Geithner said in a Nov. 2 report.

Lenders are on pace this year to buy the most Treasury and agency debt since the Fed began tracking the data in 1950, adding $186.2 billion of the securities through Oct. 20 and bringing the total to $1.62 trillion. At the same time, commercial and industrial loans fell by 5.3 percent to $1.23 trillion, Fed data show.

Of interest in the November 2 TBAC Report:

Against this economic backdrop, the Committee’s first charge was to examine what adjustments to debt issuance, if any, Treasury should make in consideration of its financing needs. In the near term, given the uncertain economic and fiscal situation, the Committee felt stabilizing nominal coupon issuance at current levels was appropriate. To the extent the Committee has greater clarity, it will likely recommend further reductions to nominal coupon issuance at the February refunding. Consistent with the August meeting, the Committee felt maintaining flexibility was necessary.

There was continued debate regarding the average maturity of outstanding Treasury debt. Although the Committee felt meaningful progress had been made, there was broad agreement that continuing down this path was appropriate. One concerning consequence of raising the average maturity of debt is the decline in T-bills as a percentage of marketable debt. A majority felt that a further lengthening of the average maturity should take precedence.

With regard to TIPS, the Committee suggested an auction every month. To accomplish this, the Committee recommended two 30-year TIPS re-openings, in June and October, and a discontinuation of the 30-year TIPS re-opening in August. Likewise, in five year TIPS, the Committee recommended two re-openings, in August and December, and a discontinuation of the October re-opening. This auction schedule should allow for growth in gross TIPS issuance to approximately $120 billion in calendar year 2011 from approximately $86 billion in calendar year 2010.

Despite the aforementioned recommendation on TIPS issuance, there was continued debate at the Committee regarding the success of the TIPS program. A number of members cited that relative to nominal issuance, TIPS issuance was more expensive, less liquid, and lacked the flight to quality aspect experienced in 2008. One Committee member recommended further detailed analysis into the costs and benefits of the TIPS program.

… and with respect to Basel 3 …

The third charge examined the potential impacts of Basel III (presentation attached). The member documented the tighter definitions of Tier-1 capital, prescribed leverage and liquidity ratios, counter-cyclical capital buffers, additional capital requirements for systemically important firms, and new limits on counterparty credit risk. The member remarked that while institutions had years to comply, markets were pushing institutions to convey and implement adoption plans today. As a result, extension of liquidity, credit, and capital are being curtailed at a time of slow economic growth. The member included estimates of Basel III’s negative impact on growth. Furthermore, members expressed concern that specific U.S. regulatory reforms in conjunction with Basel III adoption may put U.S. financial firms at a competitive disadvantage versus international peers. Lastly, the member pointed out that compliance with liquidity coverage ratios will lead to increased demand by designated institutions for U.S. Treasuries.

How ’bout that Goldman Sachs, eh? They’ve done a Maple Issue:

Goldman Sachs Group Inc. (GS) raised C$500 million from an issue of five-year, so-called Maple bonds, according to people familiar with the matter.

Maple bonds are debt securities denominated in Canadian dollars that are issued by foreign companies.

The Goldman issue, which matures in November 2015, was priced at 208 basis points over the relevant government of Canada benchmark curve, or at the low end of the guidance, to yield 4.102%.

The bonds carry a coupon of 4.10%.

Goldman’s offering provides the latest evidence of a recovery in the Maple-bond market this year following a slow period in 2009, reflecting a combination of improved credit conditions and larger syndicates underwriting the deals. A larger number of dealers in a syndicate often lends itself to better trading conditions for the securities in the secondary market.

… and an ultralong issue:

The Goldman issue is a poster child for the continuing frenzy in the capital market for long-dated instruments. The Wall Street bank originally hoped investors might have the appetite for $250-million (U.S.) worth of the securities, according to market chatter at the time of the issue last month.

But Goldman sold more than five times as much – $1.3-billion. Ordinary ma and pa investors were the target buyers, signified by Goldman chopping the bonds into minuscule $25 amounts. This is an unusual size. Bonds typically trade in minimum multiples of $1,000.

It’s not clear how many of the small investors who bought Goldman’s bonds realize the fine points of the deal. According to the prospectus, Goldman has reserved for itself the right to redeem the bonds at their face value of $25 on five days’ written notice any time after Nov. 1, 2015.

If interest rates stay low, Goldman, which didn’t respond to a request for comment, will likely call the bonds and pay off investors. Those seemingly high yields will then vanish.

Meanwhile, if market interest rates return to more normal levels because the economy recovers or inflation resumes, it’s likely that the cost of borrowing for extremely long terms could rise well above the 6.125 per cent that Goldman is paying. In that case, Goldman won’t redeem them, and buyers will be stuck with losses because bond prices move inversely to interest rates.

It’s telling that, while Goldman has the right to redeem, buyers weren’t given the same right to force Goldman to buy back the securities if interest rates surge.

By way of comparison, the Long Term Corporate Bond ETF (VCLT) has a “SEC Yield” of 5.42% … but mind you, the SEC Yield is basically Current Yield, so it doesn’t mean much.

Efforts to destroy banking in the UK continue:

Business Secretary Vince Cable dismissed warnings from U.K. banks of a potential brain drain to Asia if the government follows through on its pledge to crack down on bonuses.

Warnings that banks may quit London are “a familiar negotiating technique and clearly one has to listen to them — one has to take these things seriously,” Cable said in an interview with Bloomberg Television in Beijing yesterday. “But it is clear that you have got to balance that against our national interest. Banks have to be safe and that means that the regulations have to take into account the potential problems created by cash bonuses.”

Royal Bank of Scotland Group Plc Chairman Philip Hampton and Standard Chartered Plc Chief Executive Officer Peter Sands said during a trade mission to Beijing with Cable and Chancellor of the Exchequer George Osborne that tighter bonus rules would drive bankers and traders away from London.

In April, the U.K. introduced a new 50 percent tax band for those earning more than 150,000 pounds a year. Osborne said last month he will block the payment of large bonuses unless banks show they are extending credit to households and companies.

HSBC Bank of Canada is redeeming its HaTS-series 2010. This Innovative Tier 1 Capital Issue is described as:

Each Series 2010 unit was issued at $1,000 per unit to provide an effective annual yield of 7.78 per cent to December 31, 2010 and the six month bankers’ acceptance rate plus 2.37 per cent thereafter. The units are not redeemable by the holders. The Trust may redeem the units on any distribution date, subject to regulatory approval.

Hellzapoppin’ on the Canadian preferred share market today, with PerpetualDiscounts rocketting up 55bp and FixedResets soaring 17bp, taking the median weighted average pre-tax yield to worst on the latter index down to 2.86%. Volume continued at elevated levels. All entries in the Performance table are in the black and my snarky remarks about MFC on the weekend appear to have attracted considerable interest … from contrarians.

HIMIPref™ Preferred Indices
These values reflect the December 2008 revision of the HIMIPref™ Indices

Values are provisional and are finalized monthly
Index Mean
Current
Yield
(at bid)
Median
YTW
Median
Average
Trading
Value
Median
Mod Dur
(YTW)
Issues Day’s Perf. Index Value
Ratchet 0.00 % 0.00 % 0 0.00 0 0.9241 % 2,229.2
FixedFloater 4.90 % 3.49 % 26,665 19.20 1 -0.0900 % 3,433.8
Floater 2.67 % 2.34 % 61,573 21.40 4 0.9241 % 2,407.0
OpRet 4.77 % 2.71 % 81,117 1.87 9 0.3562 % 2,400.9
SplitShare 5.84 % -12.93 % 67,059 0.08 2 0.0403 % 2,411.2
Interest-Bearing 0.00 % 0.00 % 0 0.00 0 0.3562 % 2,195.4
Perpetual-Premium 5.62 % 4.96 % 164,121 3.08 24 0.2291 % 2,029.6
Perpetual-Discount 5.30 % 5.29 % 257,807 14.87 53 0.5459 % 2,059.9
FixedReset 5.19 % 2.86 % 343,587 3.21 50 0.1738 % 2,297.3
Performance Highlights
Issue Index Change Notes
BAM.PR.K Floater 1.01 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 17.05
Evaluated at bid price : 17.05
Bid-YTW : 3.10 %
BAM.PR.P FixedReset 1.08 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-10-30
Maturity Price : 25.00
Evaluated at bid price : 28.09
Bid-YTW : 3.82 %
PWF.PR.A Floater 1.24 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 21.88
Evaluated at bid price : 22.12
Bid-YTW : 2.34 %
SLF.PR.C Perpetual-Discount 1.33 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 21.29
Evaluated at bid price : 21.29
Bid-YTW : 5.30 %
ELF.PR.G Perpetual-Discount 1.58 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 20.61
Evaluated at bid price : 20.61
Bid-YTW : 5.83 %
SLF.PR.D Perpetual-Discount 1.62 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 21.35
Evaluated at bid price : 21.35
Bid-YTW : 5.28 %
SLF.PR.A Perpetual-Discount 1.66 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 22.53
Evaluated at bid price : 22.72
Bid-YTW : 5.29 %
BAM.PR.I OpRet 1.81 % YTW SCENARIO
Maturity Type : Call
Maturity Date : 2010-12-08
Maturity Price : 25.50
Evaluated at bid price : 27.00
Bid-YTW : -49.79 %
MFC.PR.B Perpetual-Discount 1.87 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 21.75
Evaluated at bid price : 21.75
Bid-YTW : 5.43 %
MFC.PR.C Perpetual-Discount 3.03 % YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 21.45
Evaluated at bid price : 21.45
Bid-YTW : 5.33 %
Volume Highlights
Issue Index Shares
Traded
Notes
RY.PR.I FixedReset 227,675 National crossed 80,000 at 26.61; RBC crossed 94,200 at 26.62. National crossed two more blocs, of 20,000 and 18,000 shares, both at 26.61.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-03-26
Maturity Price : 25.00
Evaluated at bid price : 26.60
Bid-YTW : 2.87 %
TD.PR.P Perpetual-Premium 196,484 Desjardins crossed 175,000 at 25.19.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2016-12-01
Maturity Price : 25.00
Evaluated at bid price : 25.14
Bid-YTW : 5.19 %
SLF.PR.E Perpetual-Discount 138,425 Nesbitt crossed blocks of 45,000 and 20,000, both at 21.40. RBC crossed 55,400 at 21.51.
YTW SCENARIO
Maturity Type : Limit Maturity
Maturity Date : 2040-11-08
Maturity Price : 21.51
Evaluated at bid price : 21.51
Bid-YTW : 5.30 %
RY.PR.X FixedReset 114,790 RBC crossed 20,200 at 28.10; Scotia crossed 50,000 at the same price; RBC crossed another 10,000 at the same price again.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-09-23
Maturity Price : 25.00
Evaluated at bid price : 28.05
Bid-YTW : 2.86 %
CM.PR.D Perpetual-Premium 108,060 Nesbitt crossed blocks of 40,000 and 59,800, both at 25.60.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2011-05-30
Maturity Price : 25.25
Evaluated at bid price : 25.56
Bid-YTW : 3.71 %
MFC.PR.E FixedReset 73,900 RBC crossed blocks of 25,000 and 16,600, both at 26.90. Nesbitt crossed 20,000 at 27.00.
YTW SCENARIO
Maturity Type : Call
Maturity Date : 2014-10-19
Maturity Price : 25.00
Evaluated at bid price : 26.85
Bid-YTW : 3.78 %
There were 50 other index-included issues trading in excess of 10,000 shares.

MUH.PR.A Contemplating Reorganization

Monday, November 8th, 2010

Mulvihill Premium Split Share Corp. has announced:

that its manager Mulvihill Capital Management Inc. has voluntarily agreed to decrease the management fee from 1.25% per annum of the net asset value to 0.50% per annum of net asset value for an indefinite period. The Fund implemented its Priority Equity Portfolio Protection Plan as required, to protect the original value of the Priority Equity Shares and is consequently invested in cash and cash equivalents. At this time, the manager has determined to consider strategic alternatives regarding the Fund and its operations.

The Priority Equity Portfolio Protection Plan was grafted on to the structure with the 2007 reorganization. In the Semi-annual Financials for July 31, 2010, the company disclosed:

Due to the above strategy to protect the Priority Equity shares the Fund is entirely in cash and cash equivalents. The Priority Equity shares have residual risk now, since they will be expected to cover expenses of the Fund in future years.

MUH.PR.A was last mentioned on PrefBlog when the company announced an issuer bid. MUH.PR.A is tracked by HIMIPref™, but is relegated to the Scraps index on credit concerns.

The Flash Crash: The Impact of High Frequency Trading on an Electronic Market

Sunday, November 7th, 2010

Themis Trading refers me to a comment letter from R T Leuchtkafer which in turn referred me to an excellent paper by Andrei A. Kirilenko, Albert S. Kyle, Mehrdad Samadi and Tugkan Tuzun titled Flash Crash: The Impact of High Frequency Trading on an Electronic Market.

We define Intermediaries as those traders who follow a strategy of buying and selling a large number of contracts to stay around a relatively low target level of inventory. Specifically, we designate a trading account as an Intermediary if its trading activity satisfies the following two criteria. First, the account’s net holdings fluctuate within 1.5% of its end of day level. Second, the account’s end of day net position is no more than 5% of its daily trading volume. Together, these two criteria select accounts whose trading strategy is to participate in a large number of transactions, but to rarely accumulate a significant net position.

We define High Frequency Traders as a subset of Intermediaries, who individually participate in a very large number of transactions. Specifically, we order Intermediaries by the number of transactions they participated in during a day (daily trading frequency), and then designate accounts that rank in the top 3% as High Frequency Traders. Once we designate a trading account as a HFT, we remove this account from the Intermediary category to prevent double counting.

This seems like an entirely sensible division, although one might quibble about the 3% cut-off. Why not 2% or 4%? It might also be illuminating to make the division based on the technology used.

Some Fundamental Traders accumulate directional positions by executing many small-size orders, while others execute a few larger-size orders. Fundamental Traders which accumulate net positions by executing just a few orders look like Noise Traders, while Fundamental Traders who trade a lot resemble Opportunistic Traders. In fact, it is quite possible that in order not to be taken advantage of by the market, some Fundamental Traders deliberately pursue execution strategies that make them appear as though they are Noise or Opportunistic Traders. In contrast, HFTs appear to play a very distinct role in the market and do not disguise their market activity.

Naturally, the better you are at disguising your activity, the better you are going to do for your clients. This point is lost upon the regulators, who generally take the view that an order cancellation is an indication of fraudulent activity and spend their time crafting rules to penalize smart traders and their clients.

It will also be noted that the ultimate disguise consists of not showing your order publicly at all – which means using a dark pool.

In order to further characterize whether categories of traders were primarily takers of liquidity, we compute the ratio of transactions in which they removed liquidity from the market as a share of their transactions.[Footnote] According to Table 2, HFTs and Intermediaries have aggressiveness ratios of 45.68% and 41.62%, respectively. In contrast, Fundamental Buyers and Sellers have aggressiveness ratios of 64.09% and 61.13%, respectively. This is consistent with a view that HFTs and Intermediaries generally provide liquidity while Fundamental Traders generally take liquidity. The aggressiveness ratio of High Frequency Traders, however, is higher than what a conventional definition of passive liquidity provision would predict. [Footnote]

In order to better characterize the liquidity provision/removal across trader categories, we compute the proportion of each order that was executed aggressively.[Footnote] Table 3 presents the cumulative distribution of ratios of order aggressiveness.

Footnote: When any two orders in this market are matched, the CME Globex platform automatically classifies an order as ‘Aggressive’ when it is executed against a ‘Passive’ order that was resting in the limit order book. From a liquidity standpoint, a passive order (either to buy or to sell) has provided visible liquidity to the market and an aggressive order has taken liquidity from the market. Aggressiveness ratio is the ratio of aggressive trade executions to total trade executions. In order to adjust for the trading activity of different categories of traders, the aggressiveness ratio is weighted either by the number of transactions or trading volume.

Footnote: One possible explanation for the order aggressiveness ratios of HFTs is that some of them may actively engage in “sniping” orders resting in the limit order book. Cvitanic and Kirilenko (2010) model this trading behavior and conclude that under some conditions this trading strategy may have impact on prices. Similarly, Hasbrouck and Saar (2009) provide empirical support for a possibility that some traders may have altered their strategies by actively searching for liquidity rather than passively posting it. Yet another explanation is that after passively buying at the bid or selling at the offer, HFTs quickly reduce their inventories by trading aggressively if necessary.

Footnote: The following example illustrates how we compute the proportion of each order that was executed aggressively. Suppose that a trader submits an executable limit order to buy 10 contracts and this order is immediately executed against a resting sell order of 8 contracts, while the remainder of the buy order rests in the order book until it is executed against a new sell order of 2 contracts. This sequence of executions yields an aggressiveness ratio of 80% for the buy order, 0% for the sell order of 8 contracts, and 100% for the sell order of 2 contracts.

This is a much better indicator of order intent than the puerile “Order Toxicity” metric, but remains flawed, as shown by the last footnote. If somebody needs to sell a large block, for instance, and places an offer well below the prevailing market price, the vast majority of it will execute as buyers take advantage of this low offer (this happens on a routine basis in the preferred share market). However, since this order is “resting”, these execution will indicate that the seller is providing liquidity and the buyers are taking it – when the actual situation is the other way around.

In fact, the first quoted section above explicitly demonstrates this fact of trading, with Fundamental Traders going to great lengths to look like Noise and Opportunistic traders.

According to Figure 4, HFTs do not accumulate a significant net position and their position tends to quickly revert to a mean of about zero. The net position of the HFTs fluctuates between approximately +/- 3000 contracts. Figure 5 presents the net position of the Intermediaries during May 3-6, 2010.

According to Figure 5, Intermediaries exhibit trading behavior similar to that of HFTs. They also do not accumulate a significant net position. Compared to the HFTs, the net position of the Intermediaries fluctuates within a more narrow band of +/- 2000 contracts, and reverts to a lower target level of net holdings at a slower rate.

We also find a notable decrease in the number of active Intermediaries on May 6. As the Figure 6 shows, the number of active Intermediaries dropped from 66 to 33, as the large price decline ensues.

In contrast, as presented in Figure 7, the number of active HFTs decreases from 13 to 10.

This demonstrates the position limits highlighted by the SEC report.

We interpret these results as follows. HFTs appear to trade in the same direction as the contemporaneous price and prices of the past five seconds. In other words, they buy, if the immediate prices are rising. However, after about ten seconds, they appear to reverse the direction of their trading – they sell, if the prices 10-20 seconds before were rising. These regression results suggest that, possibly due to their speed advantage or superior ability to predict price changes, HFTs are able to buy right as the prices are about to increase. HFTs then turn around and begin selling 10 to 20 seconds after a price increase.

The Intermediaries sell when the immediate prices are rising, and buy if the prices 3-9 seconds before were rising. These regression results suggest that, possibly due to their slower speed or inability to anticipate possible changes in prices, Intermediaries buy when the prices are already falling and sell when the prices are already rising.

So in other words, part of the thing that differentiates HFT and Intermediaries is not simply the volume of trade, but also that the HFT guys can do it better. In many cases, HFT strategies attempt to predict the (short-term) future direction of the market by looking at the order book … if there’s a huge volume of offers compared to the bids, get out of the way! One method of counter-attack against this is, as mentioned above, the use of dark pools for trading.

We consider Intermediaries and HFTs to be very short term investors. They do not hold positions over long periods of time and revert to their target inventory level quickly. Observed trading activity of HFTs can be separated into three parts. First, HFTs seem to anticipate price changes (in either direction) and trade aggressively to profit from it. Second, HFTs seem to provide liquidity by putting resting orders in the direction of the anticipated the price move. Third, HFTs trade to keep their inventories within a target level. The inventory management trading objective of HFTs may interact with their price-anticipation objective. In other words, at times, inventory-management considerations of HFTs may lead them to aggressively trade in the same direction as the prices are moving, thus, taking liquidity. At other times, in order to revert to their target inventory levels, HFTs may passively trade against price movements and, thus, provide liquidity.

This is consistent with my speculation on October 25 that HFT acts as a capacitator that will discharge if a certain inventory level is breached.

We find that compared to the three days prior to May 6, there was an unusually level of HFT “hot potato” trading volume — due to repeated buying and selling of contracts accompanied a relatively small change in net position. The hot potato effect was especially pronounced between 13:45:13 and 13:45:27 CT, when HFTs traded over 27,000 contracts, which accounted for approximately 49% of the total trading volume, while their net position changed by only about 200 contracts.

We interpret this finding as follows: the lack of Opportunistic and Fundamental Trader, as well as Intermediaries, with whom HFTs typically trade, resulted in higher trading volume among HFTs, creating a hot potato effect. It is possible that during the period of high volatility, Opportunistic and Fundamental Traders were either unable or unwilling to efficiently submit orders. In the absence of their usual trading counterparties, HFTs were left to trade with other HFTs.

So in other words, it wasn’t the HFTs that left the market, it was the Opportunistic and Fundamental Traders.

Aggressiveness Imbalance is constructed as the difference between aggressive buy transactions minus aggressive sell transactions. Figure 8 shows the relationship between price and cumulative Aggressiveness Imbalance (aggressive buys – aggressive sells).

In addition, we calculate Aggressiveness Imbalance for each category of traders over one minute intervals. For illustrative purposes, the Aggressiveness Imbalance indicator for HFTs and Intermediaries are presented in Figures 9 and 10, respectively.

According, to Figures 9 and 10, visually, HFTs behave very differently during the Flash Crash compared to the Intermediaries. HFTs aggressively sold on the way down and aggressively bought on the way up. IN contrast, Intermediaries are about equally passive and aggressive both down and up.

As suggested above, this could simply be a result of HFT looking at the order book and taking a view, in addition to the considerations implied by their inventories.

I have added emphasis below to what I suggest is the central conclusion to be drawn from the Flash Crash.

We believe that the events on May 6 unfolded as follows. Financial markets, already tense over concerns about the European sovereign debt crisis, opened to news concerning the Greek government’s ability to service its sovereign debt. As a result, premiums rose for buying protection against default on sovereign debt securities of Greece and a number of other European countries. In addition, the S&P 500 volatility index (“VIX”) increased, and yields of ten-year Treasuries fell as investors engaged in a “flight to quality.” By midafternoon, the Dow Jones Industrial Average was down about 2.5%.

Sometime after 2:30 p.m., Fundamental Sellers began executing a large sell program. Typically, such a large sell program would not be executed at once, but rather spread out over time, perhaps over hours. The magnitude of the Fundamental Sellers’ trading program began to significantly outweigh the ability of Fundamental Buyers to absorb the selling pressure.

HFTs and Intermediaries were the likely buyers of the initial batch of sell orders from Fundamental Sellers, thus accumulating temporary long positions. Thus, during the early moments of this sell program’s execution, HFTs and Intermediaries provided liquidity to this sell order. However, just like market intermediaries in the days of floor trading, HFTs and Intermediaries had no desire to hold their positions over a long time horizon. A few minutes after they bought the first batch of contracts sold by Fundamental Sellers, HFTs aggressively sold contracts to reduce their inventories. As they sold contracts, HFTs were no longer providers of liquidity to the selling program. In fact, HFTs competed for liquidity with the selling program, further amplifying the price impact of this program.

Furthermore, total trading volume and trading volume of HFTs increased significantly minutes before and during the Flash Crash. Finally, as the price of the E-mini rapidly fell and many traders were unwilling or unable to submit orders, HFTs repeatedly bought and sold from one another, generating a “hot-potato” effect. Yet, Opportunistic Buyers, who may have realized significant profits from this large decrease in price, did not seem to be willing or able to provide ample buy-side liquidity. As a result, between 2:45:13 and 2:45:27, prices of the E-mini fell about 1.7%.

At 2:45:28, a 5 second trading pause was automatically activated in the E-mini. Opportunistic and Fundamental Buyers aggressively executed trades which led to a rapid recovery in prices. HFTs continued their strategy of rapidly buying and selling contracts, while about half of the Intermediaries closed their positions and got out of the market. In light of these events, a few fundamental questions arise. Why did it take so long for opportunistic buyers to enter the market and why did the price concessions had to be so large? It seems possible that some opportunistic buyers could not distinguish between macroeconomic fundamentals and market-specific liquidity events. It also seems possible that the opportunistic buyers have already accumulated a significant positive inventory earlier in the day as prices were steadily declining. Furthermore, it is possible that they could not quickly find opportunities to hedge additional positive inventory in other markets which also experienced significant volatility and higher latencies. An examination of these hypotheses requires data from all venues, products, and traders on the day of the Flash Crash.

I suggest that the reason this happened is because Opportunistic traders are simply not very smart people. They’re prep-school smiley-boys who got their jobs through Daddy’s connections and can make a fat living without the necessity of labour or thought. This will not change until performance genuinely becomes a desirable metric in the marketplace (as opposed to consumer-goods style branding) and regulators dispose of their fixation on turnover, which is simply a hangover from legitimate concern regarding commission-driven churning.

But a lot of it is simply ultimate investors’ desire for a good story. In general, investors want to hear “I bought it because Bernanke this and Buffet that and in-depth macro-economic analysis the other thing”, not “I bought it because somebody really, really wanted to sell it and it was outside its fair-value range compared to what I sold. I think. Maybe. This type of trade works about 60% of the time.”

That being said, however, I will also suggest that it is possible that the Opportunistic Buyers were dissuaded from entering the market through the quote-stuffing identified by Nanex, which has yet to be explained in a satisfactory manner.

And, I think, one piece of information we need is a look at the order book at the time – such as it was! It is possible that the selling by HFT was not due merely to a desire to square their books, but there was also the motivation supplied by a huge volume of resting sells relative to resting buys. Appendix IV.2 of the SEC Flash Crash Report gave order-book data for seven securites, but not the eMini contract. I republished two of the depth-charts (for Accenture) in my post regarding the report.

Based on our analysis, we believe that High Frequency Traders exhibit trading patterns consistent with market making. In doing so, they provide very short term liquidity to traders who demand it. This activity comprises a large percentage of total trading volume, but does not result in a significant accumulation of inventory. As a result, whether under normal market conditions or during periods of high volatility, High Frequency Traders are not willing to accumulate large positions or absorb large losses. Moreover, their contribution to higher trading volumes may be mistaken for liquidity by Fundamental Traders. Finally, when rebalancing their positions, High Frequency Traders may compete for liquidity and amplify price volatility. Consequently, we believe, that irrespective of technology, markets can become fragile when imbalances arise as a result of large traders seeking to buy or sell quantities larger than intermediaries are willing to temporarily hold, and simultaneously long-term suppliers of liquidity are not forthcoming even if significant price concessions are offered. We believe that technological innovation is critical for market development. However, as markets change, appropriate safeguards must be implemented to keep pace with trading practices enabled by advances in technology.

Update: This is probably as good a place as any to pass on some information about Stop-Loss orders, from Mary Schapiro’s September 7 speech to the Economic Club of New York, titled Strengthening Our Equity Market Structure:

To understand where individual investors are coming from, we must truly recognize the impact of severe price volatility on their interests: one example is the use and impact of stop loss orders on May 6. Stop loss orders are designed to help limit losses by selling a stock when it drops below a specified price, and are a safety tool used by many individual investors to limit losses.

The fundamental premise of these orders is to rely on the integrity of market prices to signal when the investor should sell a holding. On May 6, this reliance proved misplaced and the use of this tool backfired.

A staggering total of more than $2 billion in individual investor stop loss orders is estimated to have been triggered during the half hour between 2:30 and 3 p.m. on May 6. As a hypothetical illustration, if each of those orders were executed at a very conservative estimate of 10 percent less than the closing price, then those individual investors suffered losses of more than $200 million compared to the closing price on that day.

I disagree with her view of the fundamental premise of a stop-loss order. The purpose of a stop-loss order is to demonstrate that you’re an ignorant little turd who deserves to go bankrupt. If we consider an earlier section of Ms. Schapiro’s speech …:

Those who purchase stock in an initial public offering, for example, can have confidence that they will be able to sell that stock at a fair and efficient price in the secondary market when they need or want to. And of course, the values assigned to stocks in the secondary market play an important role in the ability of companies to raise additional funding.

Markets are powerful and they are the most efficient and effective tools for turning savings into capital and growth.

But, if the equity market structure breaks down — if it fails to provide the necessary and expected fairness, stability, and efficiency — investors and companies pull back, raising costs and reducing growth.

… we see that the fundamental premise of a market is to indicate a fair value of a listed company. I have no arguments with that. A stop-loss order says “I don’t want to sell this stock at $50. But if it goes down to $40, that’s the time I want to sell it.” – a sentiment completely divorced from the objective of fairly valuing a listed company.

Update: Despite all this – despite the complete lack of evidence that either HFT or algorithmic trading was in any way the root cause of the debacle – there are some who don’t want to be confused with facts:

“While I do not believe that the Flash Crash was the direct result of reckless misconduct in the futures market, I question what the CFTC could have done if the opposite were true. When does high frequency or algorithmic trading cross the line into being disruptive to our markets? And, along those same lines, who is responsible when technology goes awry? Do we treat rogue algorithms like rogue traders? These are the issues I hope to explore at our October 12th meeting,” stated Commissioner O’Malia.

Nothing wrong with the world that a few extra rules wouldn’t cure, eh Commisioner?

YPG: Ticker Change to YLO

Saturday, November 6th, 2010

Yellow Media Inc. has announced:

that Yellow Pages Income Fund (the Fund) has completed today the previously announced plan of arrangement pursuant to which the Fund’s income trust structure has been converted into a dividend paying publicly traded corporation named Yellow Media Inc. On May 6, 2010, unitholders of the Fund approved the conversion to a corporate structure by a vote of 99.8 percent. Under the plan of arrangement, unitholders of the Fund received, for each unit of the Fund held, one common share of the resulting public corporation. Common shares of Yellow Media Inc. will commence trading on the Toronto Stock Exchange on November 1, 2010 under the symbol YLO.

This ticker change applies to the company’s four series of preferred shares outstanding: The Operating Retractibles, YPG.PR.A and YPG.PR.B are now YLO.PR.A and YLO.PR.B, respectively. The FixedResets YPG.PR.C and YPG.PR.D, are now YLO.PR.C and YLO.PR.D respectively.

It is of interest to note the following from the 3Q10 Management Discussion and Analysis:

On June 8, 2010, Yellow Media Inc. received approval from the Toronto Stock Exchange on its notice of intention to renew its normal course issuer bid for its preferred shares, Series 1 and preferred shares, Series 2 through the facilities of the Toronto Stock Exchange from June 11, 2010 to no later than June 10, 2011, in accordance with applicable rules and regulations of the Toronto Stock Exchange.

Under its normal course issuer bid, Yellow Media Inc. intends to purchase for cancellation up to but not more than 1,174,691 and 720,000 of its outstanding preferred shares, Series 1 and preferred shares, Series 2, respectively, representing 10% of the public float of each series of preferred shares outstanding on June 8, 2010.

For the first nine months of 2010, Yellow Media Inc. purchased for cancellation 604,748 preferred shares, Series 1 for a total cash consideration of $15 million including brokerage fees at an average price of $24.76 per share and 260,250 preferred shares, Series 2 for a total cash consideration of $5.2 million including brokerage fees at an average price of $20.17 per share. The carrying value of these preferred shares, Series 1 and Series 2 was $14.9 million and $6.4 million, respectively.

Since June 11, 2009, the total cost of repurchasing preferred shares amounted to $33.9 million, including brokerage fees.

MFC and the John Hancock LTC Fiasco

Saturday, November 6th, 2010

In their 2Q10 Quarterly Report to Shareholders, MFC stated:

The Company expects to complete its annual review of all actuarial methods and assumptions in the third quarter. In that regard, we expect that the methods and assumptions relating to our Long Term Care (“LTC”) business may be updated for the results of a comprehensive long-term care morbidity experience study, including the timing and amount of potential in-force rate increases. The study has not been finalized but is scheduled to be completed in the third quarter. We cannot reasonably estimate the results, and although the potential charges would not be included in the calculation of Adjusted Earnings from Operations, they could exceed Adjusted Earnings from Operations for the third quarter. There is a risk that potential charges arising as a result of the study may not be fully tax effected for accounting and reporting purposes.

JH LTC sales in the second quarter increased by 72 per cent compared to the prior year. This reflected the increased group sales from new member enrollments and new group clients as well as increased retail sales in advance of price increases and product re-positioning to improve margins. The Federal Long Term Care Insurance Program, where John Hancock is now the sole carrier, also contributed to the increase in sales from the prior year. As a result of the price increases, JH LTC retail sales are expected to slow during the second half of the year.

In both the second quarter of 2010 and 2009, John Hancock reported unfavourable long-term care morbidity experience. A comprehensive morbidity experience study is expected to be completed in the third quarter of 2010 and if the study concludes that the recent level of experience is expected to continue, price increases and policy liability increases would be required.

In the 3Q10 News Release they stated:

[Chief Financial Officer Michael] Bell added, “There were a number of notable items impacting our financial results this quarter. We completed our annual review of all actuarial methods and assumptions in the third quarter, and this resulted in a total net charge of just over $2 billion. This reserve strengthening included a significant charge related to our John Hancock Long-Term Care (“LTC”) business, where we completed a comprehensive long-term care claims experience study, including an assessment of the positive expected impacts of in-force rate increases.”

John Hancock Long-Term Care (“JH LTC”) sales increased 20 per cent in the third quarter compared to the prior year, driven by sales of retail products which increased in advance of June new business price increases taking effect. As a result of the recently completed claims experience study and the continuing low interest rate environment, JH LTC has temporarily suspended new group sales and is planning other retail product changes. JH LTC sales are expected to decline in the fourth quarter of 2010. In addition, JH LTC will be raising premiums on in-force business and is actively working with regulators to implement increases that are on average 40 per cent and affect the majority of the in-force business.

They also provide a handy table of their enormous actuarial charge:

(C$ millions)
Assumption
To
Policy Liabilities
To Net Income
Attributable to
Shareholders
Mortality and morbidity
   Long-term care $1,161 $ (755)
   Other (258) 182
 
Lapses and policyholder behaviour 648 (485)
Expenses (116) 104
Investment returns
   Variable annuity parameter update 872 (665)
   Ultimate reinvestment rates/grading for corporate spreads 441 (309)
   Other 94 (175)
 
Other valuation model methodology and model refinements (10) 72
Net Impact $2,832 $(2,031)

This charge of over a billion dollars on LTC pricing is explained as follows:

Long-term care mortality and morbidity changes

John Hancock Long-Term Care completed a comprehensive long-term care claims experience study, including estimated favourable impacts of in-force rate increases. As a result:

  • Expected claims costs increase primarily due to increased ultimate incidence at higher attained ages, anti-selection at older issue ages and improved mortality, partially offset by better experience on business sold in the last seven years due to evolving underwriting tools. These collectively resulted in an increase in Active Life Reserves of $ 3.2 billion.
  • Disabled Life Reserves were also strengthened by $0.3 billion to reflect emerging continuance and salvage experience for Retail and Fortis blocks.
  • Claims margins were harmonized for the pre and post rate stabilization blocks. The reduction in margins resulted in a reserve release of $0.2 billion.
  • Expected future premium increases reduced reserves by $2.2 billion resulting in a total of $3.0 billion of future premium increases assumed in the reserves. Premium increases averaging approximately 40 per cent will be sought on 80 per cent of the in-force business. We have factored into our assumptions our best estimate of the timing and amount of state approved premium increases. Our actual experience obtaining price increases could be materially different than we have assumed, resulting in further policy liability increases or reserve releases which could be material.

Kimberly Lankford reported in October:

The specific size of the increase may vary, depending on your age and when you purchased the policy, says Marianne Harrison, president of John Hancock Long-Term Care. The increase applies to both individual and group policies, and the largest increases will be restricted to older policies. But the rate hike will not apply to Leading Edge or Custom Care II Enhanced policies, two of their newer policies that are subject to stricter standards for setting premiums. Nor will the price hikes affect the long-term-care policy run by John Hancock for federal employees, which already had a premium increase of up to 25% in the spring.

But for many policyholders, the proposed price hike comes on top of a rate increase of 13% to 18% in 2008. The other long-term-care insurance leaders, Genworth and MetLife, also increased premiums for many of their policies around that time.

John Hancock is raising rates after a study found that the number of claims, the length of claims and the use of benefits from 1990 to 2010 were much higher than the company had expected — particularly the open-ended expense of providing lifetime benefits in an era when people live longer thanks to medical advances and then require extensive long-term care. “The claims on the lifetime coverage on our older policies were higher than our original policy assumptions,” says Harrison. (John Hancock stopped selling new policies with lifetime benefits in June 2010.)

“This is a last resort, from our perspective,” says Harrison. “But this is not a viable product if we do not have the appropriate money there to pay claims in the long term.”

It has also been reported:

[Marianne Harrison, president of John Hancock Long Term Care] is disclosing the rate increase and group policy suspension in a telephone conference with the company’s LTC insurance distributors [September 20, 2010].

Hancock announced the moves after its recent claims study showed unfavorable claims patterns, Harrison said in an interview.

Hancock’s claims studies, conducted every few years, examine LTC morbidity and termination claim trends based on actual experience. The last time Hancock undertook a thorough LTC claims review was in 2006, the company says.

This year’s study encompassed both open and closed claims, looking at all LTC claims Hancock received from 1990 to 2010.

As the LTC block continued to mature, Hancock’s latest study found it had twice the number of claims it found in its 2006 study. For older policy holders—ages 80 and up—the block had 4 times as many.

The severity and duration of claims in 2010 also were much higher than in 2006, Harrison says, while claims terminations were lower than expected.

Hancock has more than 1.2 million LTC insurance customers–700,000 individual, 350,000 group, and 224,000 under the federal program. Of all these policies, 47,000 have received benefits. Hancock says it has paid more than $3 billion in LTC claims, and now pays more than $1.5 million in claims per day.

Hancock announced in January:

John Hancock has launched a new interactive microsite, www.GetMoreWithMultilifeLTC.com, to help brokers and consultants explore and establish LTC insurance plans for businesses with up to 1,000 employees.

“Over the past 22 years, we have seen LTC insurance increase in popularity among large employers,” said Marianne Harrison, President, John Hancock Long-Term Care. “Today, we’re seeing small and mid-size employers showing greater interest in meeting the LTC needs of their employees, yet few of them know who to turn to for LTC advice and services. This site, in addition to the access to our team of experts, will be very helpful to brokers and consultants who want to provide this important coverage to businesses throughout the US.”

All this may be compared with the action taken by their competitors:

Genworth Financial Inc. says it will raise rates 18% on two older blocks of comprehensive long term care (LTC) insurance.
The policies, no longer marketed, were sold by two Genworth subsidiaries, Genworth Life and Genworth Life of New York.

Genworth, Richmond, Va. (NYSE:GWN), is increasing the rates because the percentage of policyholders in the blocks who have let policies lapse has been lower than expected, the company says.

Now, I will be the first to agree that insurance is a complicated business. And I will also agree wholeheartedly that I am not an expert on insurance and its pricing. But this fiasco goes to the root of investor confidence in MFC, because it is a very real indication that questions need to be asked about their basic competence.

This is a massive write-off, and the degree of under-pricing indicated by the proposed rate increases is astronomical. How can you possibly underprice something by 40% and not know that something is out of whack? Why was a major sales initiative on this product initiated in January, only to have sales through that channel cancelled in October? Shouldn’t you have a reasonable idea of profitability before you spend money on new increasing sales?

Isn’t anybody looking at a report of actual versus actuarial claims expenses and thinking ‘Claims are at 200% of projections for this product, and at 400% for this subgroup … gee, maybe we should have a proper look at it’?

Why was the actuarial review of LTC not done sooner? The prior one was in 2006, so that’s four years between reviews. How are the topics for review chosen? Is there some system of monitoring in place so that an informed decision can be made regarding the areas in which review is required? If not, why not? If so, then it seems as if the system failed: write-offs and price increases on this scale indicate that the review was well overdue. If there is a system, why did it fail and how can investors have any confidence that it will not fail in the future?

Update 2010-11-11: MetLife is exiting the LTC business:

MetLife Inc., the largest U.S. life insurer, will halt the sale of new long-term care coverage after citing “financial challenges” in the business.

Long-term care policies provide coverage to help pay for home-health aides or residence in a nursing home or assisted- living facility. New York-based MetLife will accept applications for new coverage through Dec. 30 and continue to honor previously written contracts after that date, the company said.

“Many Americans remain at risk for needing long-term care services,” MetLife said. The insurer is reviewing a way to combine the coverage with other contracts “ which the company believes can effectively address the long-term care financing needs of the public as well as its business goals.”

Flash Crash Report Criticism Continues

Saturday, November 6th, 2010

Hal Weitzman of the Financial Times highlights a purported Need for consistent market structure to avoid ‘flash crash’:

Gary Katz, head of the International Securities Exchange, owned by Deutsche Boerse, dismissed the suggestion that US regulators should focus on creating incentives for market-makers.

“When the market begins to fall like that, there are no incentives big enough to persuade market-makers to catch a falling knife,” Mr Katz said.

Tom Whittman, president of Nasdaq OMX, which operates one of the biggest US options-trading platforms, agreed. “Market-makers wouldn’t have stayed in the market on May 6,” he said. “They’d rather pull out and pay a fine.”

Ed Boyle, who runs NYSE Euronext’s options business, said the “flash crash” indicated there were bigger and more serious structural issues for regulators, such as the existence of “dark pools” for share trading.

“There has to be a more consistent market structure than simply incentives for market-makers,” Mr Boyle said.

Bill Brodsky, chief executive of the Chicago Board Options Exchange, said the Securities and Exchange Commission’s report on the “flash crash”, which pinpointed a single trade by Waddell and Reed, a Kansas City-based firm, was suspect.

“The SEC never figured out what happened on May 6,” Mr Brodsky said. “The SEC report just doesn’t add up in my view.”

In the absence of any argument to support the idea that structural issues were at the root of the crash, I’ll have to dismiss Ed Boyle’s remarks as self-serving.

Brodsky’s remarks were also reported by Reuters:

“We went on for months and months and still didn’t know what happened,” William Brodsky, chief executive of Chicago Board Options Exchange parent CBOE Holdings Inc (CBOE.O), told a Futures Industry Association conference.

The report’s explanation of the May 6 crash “just doesn’t add up in my view,” he said on Thursday

Brodsky, who recently headed up the World Federation of Exchanges, criticized the report’s “vague reference to a Kansas City firm (Waddell),” adding, “we need to know what happened across all markets” that day.

“We failed because it took so long to figure out what happened, and they never figured out what happened,” he said of the CFTC and the SEC, which is expected to make further changes to the marketplace to avoid a repetition of the crash.

The Wall Street Journal continues to tout “order toxicity”:

“Complementary to circuit breakers based on price action, they could have circuit breakers based on our metric,” said Marcos Lopez de Prado, one of the authors of the study released last month and head of high frequency futures at hedge fund Tudor Investment Corp.

The study has already caught the attention of regulators as they look for ways to avoid another flash crash, especially given that Maureen O’Hara, one of the Cornell professors that co-authored the study, is a member of the Joint CFTC-SEC Advisory Committee on Emerging Regulatory Issues. The committee’s first task after it was formed in mid-May was to review the market events of May 6, when stock prices fell dramatically before staging a rapid rebound, and make recommendations related to market structure issues that may have contributed to that day’s volatility.

Richard Ketchum, chairman and chief executive of the Financial Industry Regulatory Authority, mentioned the study Friday during a meeting of the Joint CFTC-SEC Advisory Committee. Ketchum noted that a way for market participants to predict toxicity and hedge accordingly “could be really valuable.” The question, he said, is “how do you create an environment where people can offload some of that toxicity risk?”

That ain’t the question, Ketchum. The question is “is it possible to predict future toxicity?”. As has been noted on PrefBlog there is not a shred of evidence in the paper regarding predictive power of “Order Toxicity” – it’s just another piece of Technical Analytical gargage (fifty year old technical analytical garbage, at that) that explains everything and predicts nothing. But one of the authors has good political connections, so we haven’t heard the last of it.

Meanwhile, an executive with the CME has flatly contradicted a central element of the SEC report’s conclusions:

An algorithm-powered order to sell 75,000 futures contracts linked to the S&P 500 stock index, entered by a mutual fund as the session’s volatility ramped up, did take into account price and time parameters, according to Scot Warren, managing director of equity indexes for CME.

“This was a sophisticated algorithm that took time and price into consideration,” said Warren, contesting descriptions of the trade as an emergency bet that helped spark a rout in stock prices.

Warren said the session’s activity revealed a “fundamental supply and demand imbalance” that spooked buyers from the market.

The second paragraph above is a bit puzzling, because the part that says he is “contesting descriptions” is not a direct quote – it might very well be the reporter’s interpretation. If somebody really, really, needed to unload 75,000 contracts, then I am prepared to believe that the algorithm executed this task in an efficient manner – the same way I would unload 100,000 horribly illiquid preferred shares in a day if the client insisted on it (after acknowledging in writing that I considered it a really stupid idea!).

The question is, was it really in Waddell Reed’s clients’ best interests to unload 75,000 contracts as quickly as possible? With no limit price? That’s a $4.6-billion trade, which Waddell Reed has defended as being a highly astute hedge based on a keen awareness of risk. You mean to tell me they were $4.6-billion worried about the market in the afternoon of May 6 and were $0.00 worried in the morning? I’m prepared to listen, but to me the whole Flash Crash story is just another tale of a cowboy vaporizing his clients’ money.

The SEC report was discussed on PrefBlog in the post Flash Crash: Incompetence, Position Limits, Retail.