Simplifying the Approach to Complex Regulation
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- Milo Sutton
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1 Simplifying the Approach to Complex Regulation Achieving Dynamic Compliance in today s Regulatory Landscape 25 th January 2017
2 simple solution Implement a future proofed solution and still meet the deadlines smart 2
3 Functional Requirements for a Regulatory Solution Multi Asset & Multi Market High performance data capture (rates, trades, orders, news) across multiple asset classes and markets Alerts Flexible CEP engine and alerts definition for instant deployment and detection of trading patterns indicating market abuse, erroneous trading or malfunctioning algorithms Reporting & Visualization Highly flexible dashboards for surveillance analysts to monitor real-time trading activity and perform posttrade analytics and reporting Market Replay To reconstruct market conditions and step forward and backward through order book activity for crossmarket and single-market analysis Back-testing & Calibration Allows surveillance analysts to test new alert algorithms against historical data and to recalibrate alerts to minimize false positives 3
4 For the Techies -- Solution Architecture!! Manual Entry Scalability: [Horizontal/Vertical] and Standby Native Lambda/HTAP Architecture Stream for Kx Reference Data ecomms Market Data Orders & Executions Pricing Batch Batch Loader Loader Stream Feed Feed Handler Handler Stream Engine Ticker Plant Stream/ Complex Event Processing Micro-services Queries Transforms Event-triggered Time-synched Sequenced... Third-Party Interoperability pub/sub, web services, change data capture, Core In In Memory Memory Database Database Historical Database q language & scripting R, Python, Matlab, Java, ODBC, web sockets 4
5 Key Non-technical requirements Dynamic, End user oriented, Interactive Simple architecture Performance is essential Fast to implement and proven Future Proof 5
6 Compliance out of the Box MiFID II Systematic Internaliser Best Ex RTS 27/28 MAR Alerts and more Alerts Dodd Frank 6
7 Solutions Using Kx - Mifid II Examples European Best Bid & Offer Trade Reconstruction Transaction Cost Analysis Best Execution SI Determination PnL Impact Analysis Fast to ingest data, fast to retrieve data, fast to build modules and applications 7
8 Report Templates for Best Execution Reporting Requirements under MiFID II 8
9 Mifid: Systematic Internaliser Highlights Market Share per Instrument Market Share, Trade Size, SI Max and SI Alert level Instrument breakdown Volume, Size & Market Share In-house Volume vs Market total 9
10 MAR: Abuse examples FX Equities Fixed Income Commodities Rates Credit Derivatives 1 Abusive Squeeze Yes NA Yes Yes NA NA 2 Inappropriate Barrier Running Yes NA NA Yes NA NA 3 Creating Floor or Ceiling in Price Pattern Yes NA NA Yes NA NA 4 Inappropriate Stop Loss Triggering Yes Yes Yes Yes NA NA 5 Prearranged Trading Yes Yes Yes Yes Yes NA 6 Ping Orders Yes Yes Yes Yes Yes NA 7 High Order Rate Yes Yes Yes Yes Yes NA 8 Front Running Yes NA Yes Yes Yes NA 9 Inappropriate Client Allocation during Benchmark Window Yes NA Yes Yes Yes NA 10 Inappropriate Assignment (Client Orders) Yes NA Yes Yes Yes NA 11 Large Order Yes Yes Yes Yes Yes Yes 12 Bait & Switch Yes Yes Yes Yes Yes NA 13 Benchmark Manipulation Yes Yes Yes Yes Yes NA 14 Trade Cancel/Amend (Fixing Window) Yes Yes Yes Yes Yes NA 15 Marking the Close NA Yes NA Yes NA NA 16 Pre-Auction Spoofing NA Yes NA Yes NA NA 17 Mark Up Breach Yes Yes Yes Yes Yes Yes 18 Trade Out of Bounds Yes Yes Yes Yes Yes Yes 19 RFQ Out of Bounds Yes Yes Yes Yes Yes Yes 10
11 More: Abuse examples FX Equities Fixed Income Commodities Rates Credit Derivatives 20 Order to Trade Ratio Yes Yes Yes Yes Yes NA 21 Parking NA Yes Yes NA Yes Yes 22 Partial Fills Yes Yes Yes Yes NA NA 23 Rapid Price Dislocation & Reversion Alert NA Yes NA Yes NA NA 24 Unusual Price Movement Yes Yes Yes Yes Yes Yes 25 Breaking the Market Yes Yes Yes Yes Yes Yes 26 Spoofing Yes Yes Yes Yes Yes NA 27 Time-Order Priority Yes Yes Yes Yes Yes Yes 28 High Order Rate Yes Yes Yes Yes Yes Yes 29 Unusual Trade Volume Yes Yes Yes Yes Yes Yes 30 Wash Trades Yes Yes Yes Yes Yes Yes 31 Inter Trading (Cross Instrument Manipulation) Yes Yes Yes Yes Yes Yes 32 Phishing Yes Yes Yes Yes Yes NA 33 Painting the Tape Yes Yes Yes Yes Yes NA 34 Pump and Dump / Trash and Cash Yes Yes Yes Yes Yes NA 35 Fictitious Quotes Yes Yes Yes Yes Yes NA 36 Momentum Ignition Yes Yes Yes Yes Yes NA 37 Smoking Yes Yes Yes Yes Yes NA 38 Insider Trading Yes Yes Yes Yes Yes Yes 39 Attempts to Inside Trade Yes Yes Yes Yes Yes Yes 11
12 MAR: Alert Dashboard 12
13 Reconstruction 13
14 Simple, Powerful Architecture Proven and Future Proofed Solutions 14
15 Contact James Corcoran Senior Vice President, Engineering Kx and kdb+ are registered trademarks of Kx Systems, Inc., a subsidiary of First Derivatives plc 15
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