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FX Trading:
A Changing Landscape

FX Trading and Technology Trends in 2011




1
    This report is based on an online survey conducted by StreamBase Systems in 2011.
Overview
Rules of swap trading regulations in the Dodd-Frank Act are expected to be finalized in 2011. As the initial
deadline (July, 2011) has passed1, market participants continue to express their skepticism on the timing of
these rules implementations, the technical costs associated with implementing them, and the impact of the
regulations on their business and market liquidity. Nevertheless, Congress has set a strong tone by granting
the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) full
authority to oversee financial institutions and their trading activities. These activities include pre-trade risk
controls, collateral and margin requirements, over-the-counter (OTC) trading, clearing, proprietary trading,
and high frequency trading.

During this time of regulatory change, much attention has also centered on the global foreign exchange (FX)
market, which has a $4 trillion daily turnover according to the latest Triennial Central Bank Survey conducted
by the Bank for International Settlements2. Surprisingly, the 20% increase in daily turnover since 2007 is not
driven by the global commercial banks, but instead by non-reporting banks, hedge funds, pension funds,
mutual funds, insurance companies and institutional investors. The growing participation in the FX market
from these so-called “non-financial institutions” is a result of fast-adopted electronic execution methods. Aite
Group estimates the use of electronic trading to exceed 70% by the end of 2012.3

In early 2011, StreamBase Systems carried out its 3rd annual online survey to explore the latest trends and
developments in FX trading and technology. A total of 135 respondents participated in the survey – 55%
identified themselves as buy-side firms and 36% on the sell side. Some 84% were from the Americas, 10%
were from the Europe, Middle East and Africa (EMEA) region, and the remaining 6% were from other regions
(see Figure 1).

Some 31% of respondents use a custodian bank to handle their FX transactions, 8% use a currency overlay
management firm, and 60% do not use services provided by either type of organization.



                                                             6%
                                                             Others
                                                                        10%
                                                                        EMEA



                                                                        84%
                                                                        Americas




Figure 1 – Survey Participants by Region




1
    “Dealers see delay for swaps reforms”, The Financial Times, Aline van Duyn, May 1, 2010.
2
    According to the Dow Jones Newswires analysis “Global Forex Turnover Continues to Increase” on July 26, 2011, the average daily global foreign
    exchange turnover has grown to $4.71 trillion.
3
    High Frequency Trading in FX: Open to Business, Aite, April 2010.

                                                         2
FX Products and Currency Management
As expected, majors were the most traded currency pair. Some 95% of respondents traded the majors, some
67% traded crosses4 and some 25% traded exotics or emerging markets pairs. With regard to FX products,
the most noticeable difference between this year’s survey and last year’s was the 23% increase in trading of
emerging markets pairs.5

Spot transactions were the most traded instrument among all respondents, with almost 91% involved in FX
spot trading. About 56% of respondents
traded outright forwards, some 48%          100%

traded FX swaps, some 48% traded                       90%
                                             80%
currency swaps and about 50% traded
FX options and other products (see
                                             60%
Figure 2).                                                       56%
                                                                                                                      48%                  48%           50%
A range of different products were                               40%

traded by over 60% of sell-side firms
                                                                 20%
while buy-side firms mainly focused on
FX spot trading. About 54% of buy-
                                                                   0%
side respondents also traded outright                                                Spot
                                                                                 Transactions
                                                                                                        Outright
                                                                                                        Forwards
                                                                                                                     FX Swaps              Currency
                                                                                                                                            Swaps
                                                                                                                                                       Options and
                                                                                                                                                         Others
forwards. Less than 40% of buy-side
                                                              Figure 2 – Primary FX Instruments Traded
respondents traded FX swaps, currency
swaps, options, and other FX products.
                                                                100%

In terms of hedging strategies, 78%
of all respondents applied active                                80%
                                                                                                                   77%                                         78%
management strategies, about 60%                                                                                                  74%
                                                                 60%
used dynamic approaches, and 53%                                                                  61%

used passive approaches.                                                          51%
                                                                 40%
                                                                                                                                                      40%
About 78% of sell-side firms applied
dynamic strategies, but only 40% of                              20%

buy-side firms applied these types of
                                                                   0%
strategies (see Figure 3).                                                              Passive                          Active                         Dynamic
                                                                                                                   Buy              Sell

                                                              Figure 3 – FX Trading Strategies




4
    Crosses are major currency pairs that do not involve the US dollar.
5
    According to BIS Triennial Central Bank Survey 2010, the most significant increases in emerging market currencies were seen for the Turkish lira,
    Chinese renminbi, Korean won, Brazilian real, and Singapore dollar.


                                                          3
Electronic FX Trading
                          The survey results indicated a wide adoption of electronic trading in the FX market. About 93% of participants
                          executed their trades via automated order matching systems, single bank proprietary platforms, or multi-
                          bank dealing systems. However, some 26% of respondents still execute their trades through telephone
                          communication with an FX voice broker (see Figure 4).6


                                100%
26% say they execute
                                                    93%
their trades with an FX          80%
voice broker
                                 60%


                                 40%


                                 20%                                26%                24%             26%
                                                                                                                17%

                                  0%
                                                   Electronic     Inter-dealer        Customer         Voice    Online
                                                   Methods           Direct            Direct          Broker   Broker

                              Figure 4 – FX Execution Methods



                          Specifically, 55% used single bank platforms, some 44% used multi-bank platforms, another 37% used third
                          party platforms, and 32% had in-house built FX platforms (see Figure 5).

                                60%

                                                   55%
                                40%                                        44%
                                                                                                     37%
                                                                                                                   32%
                                20%


                                 0%
                                                  Propietary             Mulit-bank              Third Party    In-house Built
                                               (bank) Platforms          Platforms                Platforms       Platforms


                              Figure 5 – Electronic FX Trading Platforms




                          Some 41% of buy-side firms used third party or independent platforms, 38% used multi-bank platforms and
                          about 34% used single bank platforms. Although the percentage of in-house built platforms is the lowest, the
                          survey still found a moderate 31% of buy-side firms built their FX trading systems internally.

                          According to the survey, Citibank’s proprietary platform was being used by the largest number of
                          respondents, replacing Deutsche Bank, which slipped to number two this year (see Figure 6). The most used
                          multi-bank platforms are FX Connect, Thomson Reuters, Bloomberg, and Currenex (see Figure 7).




                          6
                              BIS Triennial Central Bank Survey 2010 indicated that 41% of FX market turnover is conducted by electronic methods, 24% by customer direct, 19%
                              by inter-dealer direct, and 16% by voice broker.




                                                                                                 4
50%
  45%          46%
  40%
                             39%             39%
  35%
  30%
                                                        29%               29%
  25%
                                                                                       25%          25%
  20%
  15%
                                                                                                                14%
  10%
                                                                                                                           11%
    5%                                                                                                                                7%
                                                                                                                                                     4%
    0%




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Figure 6 – Primary Proprietary (Bank) Platforms Used




  50%
  45%          47%

  40%
  35%
                                35%
  30%                                             32%        32%
                                                                                29%           29%
  25%
  20%                                                                                                      25%
  15%
                                                                                                                          15%        15%
  10%
                                                                                                                                                     9%
    5%
    0%
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              ct



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                                                                                                               36
                                Tra
              ete



                             FX
          Ru




Figure 7 – Primary Multi-bank and Independent Platforms Used




The study found little difference in the usage of single bank platforms – Citibank, Deutsche Bank, and
Barclays Capital topped the list among both buy and sell sides (see Table 1 and Table 2).

However, the study indicated some differences between the buy and sell side regarding the usage of
multi-bank platforms (see Table 3 and Table 4).




                                                                                     5
RANKING                   BUY-SIDE                       RANKING                    SELL-SIDE
        1                 Deutsche Bank                           1                     Citibank
        2                     Citibank                            2                Barclay’s Capital
        3                Barclay’s Capital                        3                 Deutsche Bank
        3                        UBS                              4                  Credit Suisse
        5                  Credit Suisse                          5                Goldman Sachs
       5=                Goldman Sachs                           5=                    JP Morgan
       5=                    JP Morgan                           5=                        UBS
        8                        RBS                              8                Morgan Stanley
        9                Morgan Stanley                           9                   BNP Paribas
                                                                 10                       HSBC
 Table 1 – Primary Propietary (Bank) Platforms Used by
           Buy-Side Respondents                                 10=                        RBS

                                                         Table 2 – Primary Propietary (Bank) Platforms Used by
                                                                   Sell-Side Respondents



   RANKING                   BUY-SIDE                       RANKING                    SELL-SIDE
        1                   FX Connect                            1               Thomson Reuters
        2                       FXall                             2                   Bloomberg
        3                     Currenex                            3                    ICAP (EBS)
        4                   Bloomberg                             4                     Currenex
       4=                   HotSpotFXi                            5                   FX Connect
       4=                    ICAP (EBS)                           6                        CME
       4=               Thomson Reuters                          6=                       FXall
        8             360 Treasury Systems                       6=                   HotspotFXi
        9                        CME                             6=              Integral – FX Inside
                                                                 10             360 Treasury Systems
Table 3 – Primary Multi-Bank and Independent
          Platforms Used by Buy-Side Firms
                                                         Table 4 – Primary Multi-Bank and Independent
                                                                   Platforms Used by Sell-Side Firms




Customer Satisfaction

Overall, 95% of respondents were satisfied with the services received from banks and electronic brokers.
Although some 14% of buy-side respondents were not satisfied with the prices they received from the
multi-bank and independent platforms. Respondents believed that improvements in pricing, venue and
counterparty selections would secure better prices. However, the study found that only 40% of buy-side firms
had benchmarks or mechanisms in place to compare prices.




                                                   6
FX Execution
Algorithmic Trading in FX

There was a 3% decrease year-over-year in using algorithms for FX execution; some 43% of respondents used
algorithms in their FX trading and among those, 64% developed their algos internally.

57% of sell-side firms used algos for FX trading and about a quarter of respondents planned to do so. The
number is slightly lower on the buy side as only 34% used algos for FX trading, and some 17% planned to do
so. However, among those buy-side firms who used algos for FX trading, 92% developed them internally. Only
39% of sell-side firms used in-house developed FX algos.

The different behaviors in algorithmic trading between the buy and sell side were also reflected in the types of
FX algos they used. 92% of buy-side firms used alpha seeking algos, 42% used algos for liquidity aggregating,
and about a quarter of them used algos for smart order routing, time-slicing and FX hedging.

About 92% of sell-side respondents used algos for smart order routing, 46% of them used algos for liquidity
aggregating, some 39% used algos for alpha seeking and FX hedging, and only 15% used time slice algos (see
Figure 8).


  100%

                              92%                                                              92%
   80%


   60%


                                                                             46%
   40%                                                            42%
                                                                                                       39%            39%

                    25%                    25%                                                               25%
   20%
                                                     15%
     0%
                      Smart Order            Time-slice               Liquidity                   Alpha       FX Hedging
                       Routing                                       Aggregating                 Seeking

                                                              Buy-side             Sell-side

Figure 8 – Primary FX Algo Functionality



Quality of execution is measured by various parameters. The study found that the importance of different
criteria was varied between buy and sell sides. On the buy side, “implicit cost of execution” was ranked the
most important criterion, followed by “speed of execution”. “Fill rates” and “minimizing market impact” were
cited the third and the fourth most important, respectively, and were scored much lower than the first two
items (see Table 5).

On the sell side, “fill rates” was the most important measure regarding the quality of execution, followed by
“implicit cost of execution”. “Speed of execution” and “minimizing market impact” were ranked third and forth
respectively (see Table 6).

Other measurements mentioned by the respondents included “ease and accuracy of confirmation and
clearing”, and “slippage rates”. Several participants noted that the consistency of speed is more important than
the absolute speed.




                                                          7
TOTAL SCORE             OVERALL RANK
                              Implicit Cost of Execution                                91                    1
                              Speed of Execution                                        90                    2
                              Fill Rates                                                78                    3
                              Minimizing Market Impact                                  65                    4

                             Table 5 – Measurements of FX Execution (Buy-side)



                                                                                 TOTAL SCORE             OVERALL RANK
                              Fill Rates                                                53                    1
                              Implicit Cost of Execution                                52                    2
                              Speed of Execution                                        48                    3
                              Minimizing Market Impact                                  46                    4

                             Table 6 – Measurements of FX Execution (Sell-side)




                             FX Market Data
                             Due to the fragmented nature of the FX market, effectively integrating different feed formats from various
                             liquidity providers was top of mind. “Integrating feed/data formats from different liquidity providers” was
                             cited as the biggest data challenge to optimize algo trading. In second place was “accessing low-latency
                             sources for high-speed algo trading”. In third was “reducing cost of direct feeds” for FX trading (see Figure 9).


36% cited “integrating                    Integrated feed/data formats from
                                                                                                                        36%
feed/data formats                                di erent liquidity providers
from different liquidity                      Access low-latency sources for
                                                   high-speed algo trading                                        22%
providers” as the biggest
data challenge to optimize                      Reduced cost of direct feeds                           13%
algo trading.
                                        No need for algos plenty of liquidity                      11%

                                                    Obtain actionable prices                      8%

                                Find historical datasets required for building                    8%
                                         and back-testing trading strategies

                                                                       Others                5%




                             Figure 9 – Biggest Data Challenge for Effective Algo Trading in FX




                             The increased participation of high frequency traders and hedge funds in the FX market drives the demand
                             for low-latency market data. Respondents were less concerned about accessing low-latency sources for
                             high-speed algo trading compared to 2010. It might be a result of increased competition between different




                                                                                    8
electronic platforms that provides more accessible and cheaper real-time, indicative pricing.

                          However, the proliferation of liquidity venues also highlights the challenge of developing a flexible
                          and extensible infrastructure within which one can more easily add and maintain components. A
                          robust FX trading system should perform consistently in obtaining competitive and executable
                          quotes with low slippage rates during highly volatile market conditions.


                          FX Trading Systems
                          Liquidity Aggregation

                          This year’s survey found a substantial increase in the implementation and satisfaction with liquidity
                          aggregation services. A year ago, about 35% of respondents were unable to aggregate prices and
                          volumes electronically across various venues, and 26% of firms who had liquidity aggregation
                          thought the systems needed to be improved.

                          This year, the study found a 29% difference regarding the usage of liquidity aggregation services
                          between 2010 and 2011. This year, 89% of buy-side firms used some liquidity aggregation services
                          and all sell-side respondents had some liquidity aggregation capabilities in their current trading
                          systems.

                          Respondents were generally satisfied with their current liquidity aggregation capabilities,
                          particularly among sell-side firms. Nevertheless, both buy and sell sides expressed their plans to
                          further improve their liquidity aggregation in 2011 and 2012.

                          Algorithmic Signal Generation, Algorithmic Order Execution and Management

Low Latency Sources for   Among all FX trading capabilities, “algorithmic signal generation” and “algorithmic order execution
high-speed trading are    and management” scored the lowest in the satisfaction questions from both buy and sell sides.
More Accessible           About 22% of sell-side respondents expressed directly that they were “not satisfied” with their
                          current algorithmic signal generation systems, and 17% of them were not satisfied with their current
                          algorithmic OEM systems (see Figure 10 and Figure 11).

                          Auto Hedging and Risk Management

                          The majority of respondents currently have auto hedging and risk management capabilities
                          in place, 71% on the buy side and 83% on the sell side. More sell-side firms than buy-side
                          firms inclined to improve the current auto hedging and risk management systems in the upcoming
                          year.

                          Pricing and Rates Engines (sell-side specific)

                          About 52% of sell-side firms had neutral opinions about their current pricing and rates engines;
                          some 44% of sell-side firms were satisfied, but 4% of them were not. The study also found that 30%
                          of sell-side firms were planning to improve or add pricing and rates engines capabilities in 2011 and
                          2012.




                                                           9
60%
Increased for
implementations of                              57%
                              50%
liquidity aggregation
in both buy and
                              40%
sell-side firms
                                                                              37%
                              30%                                                           34%                      34%                              34%
                                                          29%                                                                29%
                                                                                                                                                                 26%
                              20%


                              10%


                                0%                                   3%                             0%                                  0%                                    3%
                                                        Liquidity                  Auto Hedging and                    Algorithmic Signal                   Algorithmic OEM
                                                       Aggregation                 Risk Management                        Generation

                                                                                 Satis ed                 Neutral                  Not Satis ed

                            Figure 10 – Buy Side’s Satisfaction in Their FX Trading Capabilities
 About 20% of sell-side
 firms are not satisfied
 with their current
                               80%
 algorithmic signal
 generation and OEM
                               70%           70%


                               60%

                               50%                                                                                                52%
                                                                      48%                                                                        48% 48%                  48%
                                                                                                         44%                44%
                               40%
                                                                35%                   35%                                                                          35%
                               30%                 30%                                      30%
                                                                                                               26%
                               20%                                                                22%
Top Technology Iniatives                                                                                             17%
in 2011/12
                               10%
1. Liquidity Aggregations
                                                         0%                 4%                                                              4%              4%                     4%
                                0%
2. Algorithmic OEM                               Liquidity      Auto Hedging and      Algorithmic        Algorithmic OEM       Pricing and        Market Data         Quoting and
                                                Aggregation     Risk Management    Signal Generation                          Rates Engines       Distribution      Price Distribution
3. Algorithmic Signal
                                                                              Satis ed                   Neutral                  Not Satis ed
   Generation
                            Figure 11 – Sell Side’s Satisfaction in Their FX Trading Capabilities




                                                                                 10
Regulatory Impacts on FX
Regulatory Enforcements Raise Concerns Over FX Transactions

Regulatory uncertainty has not helped an already stressed market. In the U.S., the tension between various
state prosecutors and custodian banks has brought unfavorable public attention to the FX market. This is
reflected in the survey, with 43% of buy-side respondents expecting increased regulatory scrutiny over the
global FX market, and some 37% believing that the market needs more transparency and that firms need to
have better price discovery mechanisms in place (see Figure 12).

Additionally, an online poll conducted by the Wall Street Journal in February 2011 showed that 86% of 504
readers think custodian banks should provide transaction-time records for FX traders.7


               Increased regulatory scrutiny
                  over the global FX market                                                              43%

      Increased call for market transparency                                                   37%

     Enhancing price discovery mechanisms                                               34%

           I am not familiar with the matter                                            34%

         Regulatory push towards a central                                           31%
                     exchange model in FX
       E orts to develop a market-accepted                              20%
                       industry benchmark

                                     Others        6%


Figure 12 – Potential implications arising from the recent lawsuits against custodian banks regarding their handling of FX
transactions (buy-side specific)


On the flip side, over 50% of sell-side firms believe regulatory requirements will have the biggest impact on their
FX business and some 22% of sell-side firms thought that high frequency traders would affect their FX business.
Financial reform is underway in both Europe and the United States. Many market participants are worried
about the upcoming challenges of upgrading their systems while maintaining business profitability in the new
regulatory regime (see Figure 13).



                       Compliance requirements                                                            44%

     Mandated central clearing and execution for                                         35%
                FX swaps and outright forwards
     Real-time counterparties position reporting                  13%

                                          Other         6%



Figure 13 – Concerns regarding the Dodd-Frank rules (sell-side specific)




7
    “Should custody banks be required to provide transaction-time records for FX trades?”, http://online.wsj.com/community/groups/market-view-845/
    topics/should-custody-banks-required-provide, the Wall Street Journal Online




                                                             11
In the latest iteration of the Dodd-Frank Act, the SEC and CFTC intended to include most foreign exchange
derivative products into the “swap” category.8 Foreign exchange swaps, and forwards, foreign currency
options, non-deliverable forwards in foreign exchange, and cross-currency swaps all fall into the definition
and will need to be traded on the designated venue — Swap Execution Facility (SEF), and centrally cleared.
All swap dealers and major swap participants are required to meet certain capital or margin requirements;
maintain trade reporting and recordkeeping of counterparties and customers.

However, the U.S. Department of the Treasury shortly issued a proposal that aimed to exempt FX swaps and
forwards from the definition of swap under the Commodity Exchange Act (CEA).9 Although the Treasury’s
position created an agreeable atmosphere among many market participants, there are few signs of how the
global FX market will evolve.

Other foreign exchange derivative products including non-deliverable forwards and options might not be
exempt from the Dodd-Frank Act and would be regulated to trade and clear on SEFs, which are closer to the
existing functionality and infrastructure offered by multi-bank and independent platforms. This might further
change the competitive landscape in the FX market while dealing banks currently having the advantage of
providing multiple FX products with an integrated service.



Conclusion
Turbulent economic conditions and sovereign debt crisises have put FX in the spotlight, and the call for
greater transparency and efficiency has never been greater. With increased demand for more control on FX
trades from clients, banks are looking to 1) provide customizable algorithms for their customers that would
allow them to execute trades within the bank or route to other venues; and 2) enhance existing trading
infrastructure to include a robust pricing engine and internalization capabilities to help manage their risk
portfolios in real-time.

The growth of high frequency trading has changed the traditional two-tier market structure in FX. However
it is still difficult to pin down the actual percentage of high frequency trading in terms of overall FX trading
volume10. Participants from both the equities and FX markets may argue that high frequency traders provide
only “fake” liquidity to the market, but the fact that they contribute to increased trading volume and tighter
spreads is indisputable.

While the intent of U.S. legislation is to increase market transparency and maintain fairness, regulators need
to consider the different characteristics between the equities and FX markets, and so do market participants.
The percentage of high frequency trading in the FX market is unlikely to reach the same level as the
equities market, as most of the trading is still driven by firms who want to hedge the risk in their investment
strategies. For those firms, speed is not the most important criteria for achieving best execution, as they must
take into account the geographical distance between FX trading centers, fill rates, and the relationships with
different counter-parties.

It is also arguable that a more transparent FX market is beneficial to all participants. In general, more
transparency will give liquidity takers and arbitragers more information in deciding how and where to
execute their trades, but it also puts banks in a tougher position in clearing out their risk.




8
    “SEC Proposes Product Defections for Swaps”, U.S. Securities and Exchange Commission, April 27 2011
9
    “Determination of Foreign Exchange Swaps and Foreign Exchange Forwards under the Commodity Exchange Act”, Department of the Treasury, April
    29, 2011
10
     Aite Group estimated that high frequency trading would account for more than 40% by the end of 2010.


                                                      12
In addition, the adoption of algorithmic trading also changes the customer expectations in terms of how
banks should handle their FX trades. Buy-side firms, including traditional fund managers, are requesting ever
more sophisticated algorithms and benchmarks to reduce the cost of their execution and improve the prices
during illiquid trading periods. The competition between different ECNs also makes low latency data more
accessible to firms that wish to build in-house liquidity aggregators.

The inherent complexity of a globally fragmented FX market and the proliferation of FX ECNs are the main
challenges in 2011 for building FX trading systems. Coupled with the specter of regulatory oversight from
multiple jurisdictions, all firms, sell-side or buy-side, need to build their trading system on technologies that
allow for rapid modification as the trading environment continues to evolve.




                                          13
About StreamBase Systems, Inc.
             StreamBase Systems, Inc, a leader in high-performance Complex Event Processing (CEP), provides
             software for rapidly building systems that analyze and act on real-time streaming data for
             instantaneous decision-making. The World Economic Forum recently awarded StreamBase the title
             of 2010 Technology Pioneer.

             StreamBase’s Event Processing Platform™ combines a rapid application development environment,
             an ultra low-latency high-throughput event server, and the broadest connectivity to real-time and
             historical data. Leading investment banks, hedge funds, and government agencies use StreamBase
             to power mission-critical applications that increase revenue, lower costs, and reduce risk.
             Applications in Capital Markets include FX Aggregation and Pricing, Smart Order Routing, Market
             Data Management and Algorithmic Trading.

             StreamBase customers include CME Group, BM&FBOVESPA, SunGard, ConvergEx Group, RBC
             Capital Markets, CMC Markets, City Index and BlueCrest Capital Management. The company
             is headquartered in Lexington, Massachusetts with offices in New York and London. For more
             information, visit www.streambase.com.



             Additional Reading and Resources
             Visit www.streambase.com/webinar-fx-trends-roundtable-2011.htm to watch the roundtable
             discussion on FX Trading and Technology Trends in 2011.




Corporate Headquarters                               New York Office                                      European Headquarters
181 Spring Street                                    370 Lexington Avenue                                 60 Cannon Street
Lexington, MA 02421                                  20th Floor, Suite 2002                               London, EC4N 6NP
+1 (866) 787-6227                                    New York, NY 10022                                   +44 (0) 20 7002 1095
                                                     +1 (866) 787-6227



  © StreamBase Systems, Inc. All rights reserved. StreamBase and StreamBase Studio are trademarks of StreamBase Systems, Inc.
                                 All other trademarks are the property of their respective owners.



                                                           14

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FX Trading and Technology Trends 2011

  • 1. FX Trading: A Changing Landscape FX Trading and Technology Trends in 2011 1 This report is based on an online survey conducted by StreamBase Systems in 2011.
  • 2. Overview Rules of swap trading regulations in the Dodd-Frank Act are expected to be finalized in 2011. As the initial deadline (July, 2011) has passed1, market participants continue to express their skepticism on the timing of these rules implementations, the technical costs associated with implementing them, and the impact of the regulations on their business and market liquidity. Nevertheless, Congress has set a strong tone by granting the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) full authority to oversee financial institutions and their trading activities. These activities include pre-trade risk controls, collateral and margin requirements, over-the-counter (OTC) trading, clearing, proprietary trading, and high frequency trading. During this time of regulatory change, much attention has also centered on the global foreign exchange (FX) market, which has a $4 trillion daily turnover according to the latest Triennial Central Bank Survey conducted by the Bank for International Settlements2. Surprisingly, the 20% increase in daily turnover since 2007 is not driven by the global commercial banks, but instead by non-reporting banks, hedge funds, pension funds, mutual funds, insurance companies and institutional investors. The growing participation in the FX market from these so-called “non-financial institutions” is a result of fast-adopted electronic execution methods. Aite Group estimates the use of electronic trading to exceed 70% by the end of 2012.3 In early 2011, StreamBase Systems carried out its 3rd annual online survey to explore the latest trends and developments in FX trading and technology. A total of 135 respondents participated in the survey – 55% identified themselves as buy-side firms and 36% on the sell side. Some 84% were from the Americas, 10% were from the Europe, Middle East and Africa (EMEA) region, and the remaining 6% were from other regions (see Figure 1). Some 31% of respondents use a custodian bank to handle their FX transactions, 8% use a currency overlay management firm, and 60% do not use services provided by either type of organization. 6% Others 10% EMEA 84% Americas Figure 1 – Survey Participants by Region 1 “Dealers see delay for swaps reforms”, The Financial Times, Aline van Duyn, May 1, 2010. 2 According to the Dow Jones Newswires analysis “Global Forex Turnover Continues to Increase” on July 26, 2011, the average daily global foreign exchange turnover has grown to $4.71 trillion. 3 High Frequency Trading in FX: Open to Business, Aite, April 2010. 2
  • 3. FX Products and Currency Management As expected, majors were the most traded currency pair. Some 95% of respondents traded the majors, some 67% traded crosses4 and some 25% traded exotics or emerging markets pairs. With regard to FX products, the most noticeable difference between this year’s survey and last year’s was the 23% increase in trading of emerging markets pairs.5 Spot transactions were the most traded instrument among all respondents, with almost 91% involved in FX spot trading. About 56% of respondents traded outright forwards, some 48% 100% traded FX swaps, some 48% traded 90% 80% currency swaps and about 50% traded FX options and other products (see 60% Figure 2). 56% 48% 48% 50% A range of different products were 40% traded by over 60% of sell-side firms 20% while buy-side firms mainly focused on FX spot trading. About 54% of buy- 0% side respondents also traded outright Spot Transactions Outright Forwards FX Swaps Currency Swaps Options and Others forwards. Less than 40% of buy-side Figure 2 – Primary FX Instruments Traded respondents traded FX swaps, currency swaps, options, and other FX products. 100% In terms of hedging strategies, 78% of all respondents applied active 80% 77% 78% management strategies, about 60% 74% 60% used dynamic approaches, and 53% 61% used passive approaches. 51% 40% 40% About 78% of sell-side firms applied dynamic strategies, but only 40% of 20% buy-side firms applied these types of 0% strategies (see Figure 3). Passive Active Dynamic Buy Sell Figure 3 – FX Trading Strategies 4 Crosses are major currency pairs that do not involve the US dollar. 5 According to BIS Triennial Central Bank Survey 2010, the most significant increases in emerging market currencies were seen for the Turkish lira, Chinese renminbi, Korean won, Brazilian real, and Singapore dollar. 3
  • 4. Electronic FX Trading The survey results indicated a wide adoption of electronic trading in the FX market. About 93% of participants executed their trades via automated order matching systems, single bank proprietary platforms, or multi- bank dealing systems. However, some 26% of respondents still execute their trades through telephone communication with an FX voice broker (see Figure 4).6 100% 26% say they execute 93% their trades with an FX 80% voice broker 60% 40% 20% 26% 24% 26% 17% 0% Electronic Inter-dealer Customer Voice Online Methods Direct Direct Broker Broker Figure 4 – FX Execution Methods Specifically, 55% used single bank platforms, some 44% used multi-bank platforms, another 37% used third party platforms, and 32% had in-house built FX platforms (see Figure 5). 60% 55% 40% 44% 37% 32% 20% 0% Propietary Mulit-bank Third Party In-house Built (bank) Platforms Platforms Platforms Platforms Figure 5 – Electronic FX Trading Platforms Some 41% of buy-side firms used third party or independent platforms, 38% used multi-bank platforms and about 34% used single bank platforms. Although the percentage of in-house built platforms is the lowest, the survey still found a moderate 31% of buy-side firms built their FX trading systems internally. According to the survey, Citibank’s proprietary platform was being used by the largest number of respondents, replacing Deutsche Bank, which slipped to number two this year (see Figure 6). The most used multi-bank platforms are FX Connect, Thomson Reuters, Bloomberg, and Currenex (see Figure 7). 6 BIS Triennial Central Bank Survey 2010 indicated that 41% of FX market turnover is conducted by electronic methods, 24% by customer direct, 19% by inter-dealer direct, and 16% by voice broker. 4
  • 5. 50% 45% 46% 40% 39% 39% 35% 30% 29% 29% 25% 25% 25% 20% 15% 14% 10% 11% 5% 7% 4% 0% e l i ley k S an S s BC chs Cit ita ba s an UB RB uis org HS tan p Sa ari eB Ca it S M YP n nS ch ’s ma d JP ay BN uts rga Cre ld rcl De Mo Go Ba Figure 6 – Primary Proprietary (Bank) Platforms Used 50% 45% 47% 40% 35% 35% 30% 32% 32% 29% 29% 25% 20% 25% 15% 15% 15% 10% 9% 5% 0% de ct ct rg ex ll Xi E s P em CM Fxa ICA ne ire otF be n nsi rre yst n 0D om tsp XI Co Cu yS 00 -F Blo Ho FX sur g3 ral on rea lin eg ing ea Int 0T d rs D 36 Tra ete FX Ru Figure 7 – Primary Multi-bank and Independent Platforms Used The study found little difference in the usage of single bank platforms – Citibank, Deutsche Bank, and Barclays Capital topped the list among both buy and sell sides (see Table 1 and Table 2). However, the study indicated some differences between the buy and sell side regarding the usage of multi-bank platforms (see Table 3 and Table 4). 5
  • 6. RANKING BUY-SIDE RANKING SELL-SIDE 1 Deutsche Bank 1 Citibank 2 Citibank 2 Barclay’s Capital 3 Barclay’s Capital 3 Deutsche Bank 3 UBS 4 Credit Suisse 5 Credit Suisse 5 Goldman Sachs 5= Goldman Sachs 5= JP Morgan 5= JP Morgan 5= UBS 8 RBS 8 Morgan Stanley 9 Morgan Stanley 9 BNP Paribas 10 HSBC Table 1 – Primary Propietary (Bank) Platforms Used by Buy-Side Respondents 10= RBS Table 2 – Primary Propietary (Bank) Platforms Used by Sell-Side Respondents RANKING BUY-SIDE RANKING SELL-SIDE 1 FX Connect 1 Thomson Reuters 2 FXall 2 Bloomberg 3 Currenex 3 ICAP (EBS) 4 Bloomberg 4 Currenex 4= HotSpotFXi 5 FX Connect 4= ICAP (EBS) 6 CME 4= Thomson Reuters 6= FXall 8 360 Treasury Systems 6= HotspotFXi 9 CME 6= Integral – FX Inside 10 360 Treasury Systems Table 3 – Primary Multi-Bank and Independent Platforms Used by Buy-Side Firms Table 4 – Primary Multi-Bank and Independent Platforms Used by Sell-Side Firms Customer Satisfaction Overall, 95% of respondents were satisfied with the services received from banks and electronic brokers. Although some 14% of buy-side respondents were not satisfied with the prices they received from the multi-bank and independent platforms. Respondents believed that improvements in pricing, venue and counterparty selections would secure better prices. However, the study found that only 40% of buy-side firms had benchmarks or mechanisms in place to compare prices. 6
  • 7. FX Execution Algorithmic Trading in FX There was a 3% decrease year-over-year in using algorithms for FX execution; some 43% of respondents used algorithms in their FX trading and among those, 64% developed their algos internally. 57% of sell-side firms used algos for FX trading and about a quarter of respondents planned to do so. The number is slightly lower on the buy side as only 34% used algos for FX trading, and some 17% planned to do so. However, among those buy-side firms who used algos for FX trading, 92% developed them internally. Only 39% of sell-side firms used in-house developed FX algos. The different behaviors in algorithmic trading between the buy and sell side were also reflected in the types of FX algos they used. 92% of buy-side firms used alpha seeking algos, 42% used algos for liquidity aggregating, and about a quarter of them used algos for smart order routing, time-slicing and FX hedging. About 92% of sell-side respondents used algos for smart order routing, 46% of them used algos for liquidity aggregating, some 39% used algos for alpha seeking and FX hedging, and only 15% used time slice algos (see Figure 8). 100% 92% 92% 80% 60% 46% 40% 42% 39% 39% 25% 25% 25% 20% 15% 0% Smart Order Time-slice Liquidity Alpha FX Hedging Routing Aggregating Seeking Buy-side Sell-side Figure 8 – Primary FX Algo Functionality Quality of execution is measured by various parameters. The study found that the importance of different criteria was varied between buy and sell sides. On the buy side, “implicit cost of execution” was ranked the most important criterion, followed by “speed of execution”. “Fill rates” and “minimizing market impact” were cited the third and the fourth most important, respectively, and were scored much lower than the first two items (see Table 5). On the sell side, “fill rates” was the most important measure regarding the quality of execution, followed by “implicit cost of execution”. “Speed of execution” and “minimizing market impact” were ranked third and forth respectively (see Table 6). Other measurements mentioned by the respondents included “ease and accuracy of confirmation and clearing”, and “slippage rates”. Several participants noted that the consistency of speed is more important than the absolute speed. 7
  • 8. TOTAL SCORE OVERALL RANK Implicit Cost of Execution 91 1 Speed of Execution 90 2 Fill Rates 78 3 Minimizing Market Impact 65 4 Table 5 – Measurements of FX Execution (Buy-side) TOTAL SCORE OVERALL RANK Fill Rates 53 1 Implicit Cost of Execution 52 2 Speed of Execution 48 3 Minimizing Market Impact 46 4 Table 6 – Measurements of FX Execution (Sell-side) FX Market Data Due to the fragmented nature of the FX market, effectively integrating different feed formats from various liquidity providers was top of mind. “Integrating feed/data formats from different liquidity providers” was cited as the biggest data challenge to optimize algo trading. In second place was “accessing low-latency sources for high-speed algo trading”. In third was “reducing cost of direct feeds” for FX trading (see Figure 9). 36% cited “integrating Integrated feed/data formats from 36% feed/data formats di erent liquidity providers from different liquidity Access low-latency sources for high-speed algo trading 22% providers” as the biggest data challenge to optimize Reduced cost of direct feeds 13% algo trading. No need for algos plenty of liquidity 11% Obtain actionable prices 8% Find historical datasets required for building 8% and back-testing trading strategies Others 5% Figure 9 – Biggest Data Challenge for Effective Algo Trading in FX The increased participation of high frequency traders and hedge funds in the FX market drives the demand for low-latency market data. Respondents were less concerned about accessing low-latency sources for high-speed algo trading compared to 2010. It might be a result of increased competition between different 8
  • 9. electronic platforms that provides more accessible and cheaper real-time, indicative pricing. However, the proliferation of liquidity venues also highlights the challenge of developing a flexible and extensible infrastructure within which one can more easily add and maintain components. A robust FX trading system should perform consistently in obtaining competitive and executable quotes with low slippage rates during highly volatile market conditions. FX Trading Systems Liquidity Aggregation This year’s survey found a substantial increase in the implementation and satisfaction with liquidity aggregation services. A year ago, about 35% of respondents were unable to aggregate prices and volumes electronically across various venues, and 26% of firms who had liquidity aggregation thought the systems needed to be improved. This year, the study found a 29% difference regarding the usage of liquidity aggregation services between 2010 and 2011. This year, 89% of buy-side firms used some liquidity aggregation services and all sell-side respondents had some liquidity aggregation capabilities in their current trading systems. Respondents were generally satisfied with their current liquidity aggregation capabilities, particularly among sell-side firms. Nevertheless, both buy and sell sides expressed their plans to further improve their liquidity aggregation in 2011 and 2012. Algorithmic Signal Generation, Algorithmic Order Execution and Management Low Latency Sources for Among all FX trading capabilities, “algorithmic signal generation” and “algorithmic order execution high-speed trading are and management” scored the lowest in the satisfaction questions from both buy and sell sides. More Accessible About 22% of sell-side respondents expressed directly that they were “not satisfied” with their current algorithmic signal generation systems, and 17% of them were not satisfied with their current algorithmic OEM systems (see Figure 10 and Figure 11). Auto Hedging and Risk Management The majority of respondents currently have auto hedging and risk management capabilities in place, 71% on the buy side and 83% on the sell side. More sell-side firms than buy-side firms inclined to improve the current auto hedging and risk management systems in the upcoming year. Pricing and Rates Engines (sell-side specific) About 52% of sell-side firms had neutral opinions about their current pricing and rates engines; some 44% of sell-side firms were satisfied, but 4% of them were not. The study also found that 30% of sell-side firms were planning to improve or add pricing and rates engines capabilities in 2011 and 2012. 9
  • 10. 60% Increased for implementations of 57% 50% liquidity aggregation in both buy and 40% sell-side firms 37% 30% 34% 34% 34% 29% 29% 26% 20% 10% 0% 3% 0% 0% 3% Liquidity Auto Hedging and Algorithmic Signal Algorithmic OEM Aggregation Risk Management Generation Satis ed Neutral Not Satis ed Figure 10 – Buy Side’s Satisfaction in Their FX Trading Capabilities About 20% of sell-side firms are not satisfied with their current 80% algorithmic signal generation and OEM 70% 70% 60% 50% 52% 48% 48% 48% 48% 44% 44% 40% 35% 35% 35% 30% 30% 30% 26% 20% 22% Top Technology Iniatives 17% in 2011/12 10% 1. Liquidity Aggregations 0% 4% 4% 4% 4% 0% 2. Algorithmic OEM Liquidity Auto Hedging and Algorithmic Algorithmic OEM Pricing and Market Data Quoting and Aggregation Risk Management Signal Generation Rates Engines Distribution Price Distribution 3. Algorithmic Signal Satis ed Neutral Not Satis ed Generation Figure 11 – Sell Side’s Satisfaction in Their FX Trading Capabilities 10
  • 11. Regulatory Impacts on FX Regulatory Enforcements Raise Concerns Over FX Transactions Regulatory uncertainty has not helped an already stressed market. In the U.S., the tension between various state prosecutors and custodian banks has brought unfavorable public attention to the FX market. This is reflected in the survey, with 43% of buy-side respondents expecting increased regulatory scrutiny over the global FX market, and some 37% believing that the market needs more transparency and that firms need to have better price discovery mechanisms in place (see Figure 12). Additionally, an online poll conducted by the Wall Street Journal in February 2011 showed that 86% of 504 readers think custodian banks should provide transaction-time records for FX traders.7 Increased regulatory scrutiny over the global FX market 43% Increased call for market transparency 37% Enhancing price discovery mechanisms 34% I am not familiar with the matter 34% Regulatory push towards a central 31% exchange model in FX E orts to develop a market-accepted 20% industry benchmark Others 6% Figure 12 – Potential implications arising from the recent lawsuits against custodian banks regarding their handling of FX transactions (buy-side specific) On the flip side, over 50% of sell-side firms believe regulatory requirements will have the biggest impact on their FX business and some 22% of sell-side firms thought that high frequency traders would affect their FX business. Financial reform is underway in both Europe and the United States. Many market participants are worried about the upcoming challenges of upgrading their systems while maintaining business profitability in the new regulatory regime (see Figure 13). Compliance requirements 44% Mandated central clearing and execution for 35% FX swaps and outright forwards Real-time counterparties position reporting 13% Other 6% Figure 13 – Concerns regarding the Dodd-Frank rules (sell-side specific) 7 “Should custody banks be required to provide transaction-time records for FX trades?”, http://online.wsj.com/community/groups/market-view-845/ topics/should-custody-banks-required-provide, the Wall Street Journal Online 11
  • 12. In the latest iteration of the Dodd-Frank Act, the SEC and CFTC intended to include most foreign exchange derivative products into the “swap” category.8 Foreign exchange swaps, and forwards, foreign currency options, non-deliverable forwards in foreign exchange, and cross-currency swaps all fall into the definition and will need to be traded on the designated venue — Swap Execution Facility (SEF), and centrally cleared. All swap dealers and major swap participants are required to meet certain capital or margin requirements; maintain trade reporting and recordkeeping of counterparties and customers. However, the U.S. Department of the Treasury shortly issued a proposal that aimed to exempt FX swaps and forwards from the definition of swap under the Commodity Exchange Act (CEA).9 Although the Treasury’s position created an agreeable atmosphere among many market participants, there are few signs of how the global FX market will evolve. Other foreign exchange derivative products including non-deliverable forwards and options might not be exempt from the Dodd-Frank Act and would be regulated to trade and clear on SEFs, which are closer to the existing functionality and infrastructure offered by multi-bank and independent platforms. This might further change the competitive landscape in the FX market while dealing banks currently having the advantage of providing multiple FX products with an integrated service. Conclusion Turbulent economic conditions and sovereign debt crisises have put FX in the spotlight, and the call for greater transparency and efficiency has never been greater. With increased demand for more control on FX trades from clients, banks are looking to 1) provide customizable algorithms for their customers that would allow them to execute trades within the bank or route to other venues; and 2) enhance existing trading infrastructure to include a robust pricing engine and internalization capabilities to help manage their risk portfolios in real-time. The growth of high frequency trading has changed the traditional two-tier market structure in FX. However it is still difficult to pin down the actual percentage of high frequency trading in terms of overall FX trading volume10. Participants from both the equities and FX markets may argue that high frequency traders provide only “fake” liquidity to the market, but the fact that they contribute to increased trading volume and tighter spreads is indisputable. While the intent of U.S. legislation is to increase market transparency and maintain fairness, regulators need to consider the different characteristics between the equities and FX markets, and so do market participants. The percentage of high frequency trading in the FX market is unlikely to reach the same level as the equities market, as most of the trading is still driven by firms who want to hedge the risk in their investment strategies. For those firms, speed is not the most important criteria for achieving best execution, as they must take into account the geographical distance between FX trading centers, fill rates, and the relationships with different counter-parties. It is also arguable that a more transparent FX market is beneficial to all participants. In general, more transparency will give liquidity takers and arbitragers more information in deciding how and where to execute their trades, but it also puts banks in a tougher position in clearing out their risk. 8 “SEC Proposes Product Defections for Swaps”, U.S. Securities and Exchange Commission, April 27 2011 9 “Determination of Foreign Exchange Swaps and Foreign Exchange Forwards under the Commodity Exchange Act”, Department of the Treasury, April 29, 2011 10 Aite Group estimated that high frequency trading would account for more than 40% by the end of 2010. 12
  • 13. In addition, the adoption of algorithmic trading also changes the customer expectations in terms of how banks should handle their FX trades. Buy-side firms, including traditional fund managers, are requesting ever more sophisticated algorithms and benchmarks to reduce the cost of their execution and improve the prices during illiquid trading periods. The competition between different ECNs also makes low latency data more accessible to firms that wish to build in-house liquidity aggregators. The inherent complexity of a globally fragmented FX market and the proliferation of FX ECNs are the main challenges in 2011 for building FX trading systems. Coupled with the specter of regulatory oversight from multiple jurisdictions, all firms, sell-side or buy-side, need to build their trading system on technologies that allow for rapid modification as the trading environment continues to evolve. 13
  • 14. About StreamBase Systems, Inc. StreamBase Systems, Inc, a leader in high-performance Complex Event Processing (CEP), provides software for rapidly building systems that analyze and act on real-time streaming data for instantaneous decision-making. The World Economic Forum recently awarded StreamBase the title of 2010 Technology Pioneer. StreamBase’s Event Processing Platform™ combines a rapid application development environment, an ultra low-latency high-throughput event server, and the broadest connectivity to real-time and historical data. Leading investment banks, hedge funds, and government agencies use StreamBase to power mission-critical applications that increase revenue, lower costs, and reduce risk. Applications in Capital Markets include FX Aggregation and Pricing, Smart Order Routing, Market Data Management and Algorithmic Trading. StreamBase customers include CME Group, BM&FBOVESPA, SunGard, ConvergEx Group, RBC Capital Markets, CMC Markets, City Index and BlueCrest Capital Management. The company is headquartered in Lexington, Massachusetts with offices in New York and London. For more information, visit www.streambase.com. Additional Reading and Resources Visit www.streambase.com/webinar-fx-trends-roundtable-2011.htm to watch the roundtable discussion on FX Trading and Technology Trends in 2011. Corporate Headquarters New York Office European Headquarters 181 Spring Street 370 Lexington Avenue 60 Cannon Street Lexington, MA 02421 20th Floor, Suite 2002 London, EC4N 6NP +1 (866) 787-6227 New York, NY 10022 +44 (0) 20 7002 1095 +1 (866) 787-6227 © StreamBase Systems, Inc. All rights reserved. StreamBase and StreamBase Studio are trademarks of StreamBase Systems, Inc. All other trademarks are the property of their respective owners. 14