Research Results on Payment For Order Flow Couldn’t Be Clearer: EU Must Ensure a Level Playing Field to Protect Retail Investors

Research Results on Payment For Order Flow Couldn’t Be Clearer: EU Must Ensure a Level Playing Field to Protect Retail Investors

FIA EPTA has been clear from the start: Payment for Order Flow as it is currently practiced in the EU stifles competition and delivers a bad deal for retail investors.

Now, the Dutch Autoriteit Financiële Markten (AFM) has released a comprehensive study that proves our point. We revisit the question through this brief explainer, detailing the reasons why FIA ETPA urges the EU to ban PFOF practices in Europe.

To begin, what is payment for order flow (PFOF) and why is it detrimental to retail investors? 

PFOF as currently practiced in the EU means that a retail broker receives a monetary incentive (payment) from a market maker, in exchange for steering the broker clients’ order flow to a specific trading system. That market maker, thanks to its association with the retail broker, becomes the exclusive counterparty to the retail investors’ orders steered by the broker.

In theory, there can be benefits to this type of arrangement, notably cost savings. Some smaller brokerage firms don’t have the capacity to handle thousands of orders and may find it beneficial to route their orders via market makers to keep their costs low. Market makers, in turn, benefit from this growth in share volume and compensate the brokers financially for the ‘’routing’’. 

However, PFOF practices can often lead to conflicts of interest, and the lack of competition between liquidity providers means that retail investors risk getting a worse deal. The retail investors’ orders may trade at worse prices compared to a competitive execution market. In EU markets where PFOF is practiced there are no guarantees to ensure a transparent and objective process around it. Retail investors are oftentimes not aware of the PFOF arrangements between their broker and a specific market maker, giving them no say in an operation that could negatively impact them.

“PFOF practices can often lead to conflicts of interest, and the lack of competition between liquidity providers means that retail investors risk getting a worse deal.

In light of these investor protection and competition risks, FIA EPTA has called upon the European Commission to ensure a harmonised approach PFOF to practices in the EU that ensures a fair outcome to investors –banning EU PFOF will be the most straightforward way of achieving this.

What is the AFM’s latest research paper on PFOF and how does it support FIA EPTA’s concerns?

In the summer of 2021, the European Securities and Markets Authority (ESMA) called upon national supervisory authorities to investigate the risks of PFOF.

Taking the lead, the Dutch AFM conducted a comprehensive study of the practice. It developed an assessment methodology, the so-called Comparative Pricing Model, which provides an indicator of a trading venue’s execution quality based on post-trade data. It then compared the execution quality of two PFOF trading venues and one non-PFOF trading venue, all three used by pan-European operating low-cost neo-brokers, as well as one low-cost investment firm.  

The study showed that execution prices a retail investor receives or pays for trading on a PFOF venue are consistently worse than on non-PFOF venues. The AFM has shared its analysis with other EU supervisory authorities to do their own analyses. This study will contribute to the ongoing discussions on PFOF in the MiFIR review.

Of note, recent research papers by the French Autorités des Marchés Financiers (AMF) and  Spain’s CNMV reached similar conclusions as the AFM. However, German regulators questioned the AFM’s and CNMV’s conclusions, stating they believed the sample size was likely too small. Germany remains a supporter of PFOF practices and claims banning them would lead to a serious setback in retail investor participation in financial markets. This perspective is disputed by a number of EU members.

 

“Study showed that execution prices a retail investor receives or pays for trading on a PFOF venue are consistently worse than on non-PFOF venues.

What changes has the MiFIR Review yielded so far on PFOFs and why does FIA EPTA propose to go further than what is currently proposed?

Concerned by the negative impact of PFOF practices on retail investors, the European Commission, through its ongoing MiFIR Review, has decided to ban its use in the EU. However, FIA EPTA remains concerned that the proposal, as currently drafted, will be ineffective as it still leaves huge gaps regarding what is considered as PFOF, how it is practiced, and between whom.

It will be critical to close the loopholes contained in the proposal which would otherwise still allow PFOF practices that currently occur in various guises in the EU. In FIA EPTA’s view, the current practices, which are observed in some Member States, constitute an inappropriate conflict of interest which undermines fair competition between market participants as well as best execution for end-clients. These practices undercut EU investor protection standards and ultimately risk to disadvantage and, in due course drive away, the very retail investors whose participation in European capital markets will be critical to their success

As its preferred solution, FIA EPTA is advocating for a broad PFOF ban in the EU encompassing all direct and indirect monetary and non-monetary inducements, including all possible execution and routing scenarios between investment firms and all types of third-parties, including trading venues.

In Conclusion

Studies like the AFM’s come at an important time as the MiFIR review progresses and they reinforce FIA EPTA’s call to action. As the AFM reminds us, ‘’most retail investors are laypersons when it comes to order execution, let alone capable to influence the execution quality of their orders. In the current MiFID II best execution framework, the responsibility to substantiate the decision for (a) particular execution venue(s) lies primarily with the investment firm.’’[1]

It is high time to ensure a level the playing field, protecting retail investors from practices that undermine their standing in the market and potentially even their trust in the system.

 

[1] https://www.afm.nl/en/nieuws/2022/februari/kwaliteit-orderuitvoering-pfof

Meet Marija Puljić, The Next Gen Market Maker

Meet Marija Puljić, The Next Gen Market Maker

Tell us a bit more about yourself and the work you currently do. 

My name is Marija Puljić. I’m a Croatian currently living in Amsterdam. I work as a research intern at Webb Traders, carrying out research as part of my Master’s in Computational Science. My focus is on a comparative analysis of two stochastic volatility models. These are models used in finance to evaluate derivative securities such as options. My goal is to investigate these models, see how well they perform, and see how well they can replicate market option prices and actual stock price and volatility that we find in the stock market. Ultimately, the objective is to determine which model can best be used in the real world to mitigate risk. 

You are already in the deep end with financial modelling. But let’s take it back a little, what initially brought you to finance? What sparked your interest? 

I’ve always been fascinated by numbers and equations. I knew growing up that I wanted to harness their power, I just didn’t know to what end. In high school I started participating in math competitions. This led to me to enrol in an undergraduate degree in mathematics. As I progressed throughout my studies, I started wondering what type of career a math degree would lead me to. I kind of stumbled upon finance, driven by the stereotypical image of the trader crunching numbers on a big screen. It seemed like an exciting and fast paced environment. The idea of dealing with the unknown and using mathematics to turn the unknown into probability was particularly interesting to me.  

Throughout my undergraduate degree, I also developed a passion for programming. Seeking to ally both programming and finance,  I then applied to the Masters in Computational Science at the University of Amsterdam. So far, it has been pretty much what I was hoping for. I now have the opportunity to intern with Webb Traders as I finish my dissertation work.  

I kind of stumbled upon finance, driven by the stereotypical image of the trader crunching numbers on a big screen. It seemed like an exciting and fast paced environment. The idea of dealing with the unknown and using mathematics to turn the unknown into probability was particularly interesting to me.

It seems you really found the intersection between markets and technology. Tell me a bit more about the tech side. What have you been learning in your degree in computational science?  

Indeed, my goal was to find a way to connect both my interests in finance and tech. This is what computational science offers me. As for the tech itself, my interest lies within algorithms. I love the fact you can make the computer do basically anything you want by creating the right algorithm. Add to that the knowledge that a computer can crunch numbers with a speed and accuracy that no human can match, and you’ve got a pretty potent tool at your disposal. I believe it’s possible to utilize programming to make something great out of it.  

Could you detail what kind of career this will eventually lead you to?  

 In my case, I am quite interested in option pricing. I hope to keep working on models that are specifically related to that. In other words, I would be working on creating programs that attempt to model and to some extent predict the movement of the stock market. The idea is to get an as close as possible rendition of a real-life stock market volatility through modelling.  

 Specifically, the role my kind of research leads to is the ‘’Quantitative Analyst’’ role. As a quant analyst, I would also be working closely with quantitative traders. My mandate would be to carry out research, analyse the results, and give insights to the traders so they in turn can use these findings for use in the market.  

Let’s zoom in on your current internship at Webb Traders. Tell us more about the organization, its internal culture, and what led you to work for them.  

 In truth, I came to Webb Traders by chance. As I was advancing through my masters, I asked a professor who I respect and is very accomplished in my field of interest if he could guide me towards an organization that did the kind of research I focus on. He pointed me in the direction of Webb Traders, a firm that is encourages the rise of a new generation of researchers. Webb Traders provides a great environment for carrying out the kind of research you are interested in. The culture is very focused on cooperation and teamwork. Everyone is very friendly, and our common competitive spirit is channelled in finding solutions to problems together.  

 I feel lucky to have an environment like this to start my career in.  

Webb Traders provides a great environment for carrying out the kind of research you are interested in. The culture is very focused on cooperation and teamwork. Everyone is very friendly, and our common competitive spirit is channelled in finding solutions to problems together.

With your interest in both technology and finance, you decided to work in two fields that have traditionally been heavily staffed by men. How does it feel to be a woman studying and working in financial modelling? 

 There’s been a lot of progress over the years. Firms are more open to hiring women. It’s still a male dominated field, but big barriers to women participation, I feel, are much less present today. Coming here, I never felt judged or looked down upon because of the fact I’m a woman.  

 Nevertheless, I think there still aren’t enough women in the field. If the community was more gender balanced, I believe it would be more inviting for everyone. So, for anyone interested in this field, I would encourage you to try and join. It’s an interesting and challenging field that many can benefit from.

What advice would you give to someone starting their studies and looking up to someone like you. Would you have done anything differently?  

 That’s a tall order for someone just starting their career! I still need some advice myself. But the bottom line is that if you have a passion and focus, if you are willing to give it enough time, anything is possible.  

 On a more practical level, look for internships. In my case, this internship at Webb Traders has been quite beneficial in letting me see the actual applicability of my research. In university, the theory can quickly become rather abstract. Internships help you see the way things really operate, and also remind you that what you learn in school is in fact quite useful!  

It’s still a male dominated field, but big barriers to women participation, I feel, are much less present today. Coming here, I never felt judged or looked down upon because of the fact I’m a woman.

What are three skills you think are particularly useful to have when working in the industry? 

 I would say focus is particularly important. We deal with numbers and equations. It’s important not to make mistakes. If you can hone in on the task at hand without letting the rest of the world distract you, you will have a leg up on others.  

 Another important trait is determination. You will likely get stuck on difficult problems at work. Perseverance will be key to getting through them. There’s always a solution, but sometimes, you just need to give it more time.  

 Finally, an eagerness to learn, and to always be ready to volunteer. This is an ever-changing field, where you need to stay informed of new ideas and findings. You always need to keep progressing in order not to fall behind.  

To find out more about Webb Traders visit Webbtraders.com

EUREX EPTA Webinar Brings Together Industry Experts to Assess Rapid Pace of Innovation in Bond and Fixed Income Markets 

EUREX EPTA Webinar Brings Together Industry Experts to Assess Rapid Pace of Innovation in Bond and Fixed Income Markets 

More democratic access, truly bespoke trading, and new asset classes about to emerge.

This was the picture painted for the future of Europe’s capital markets on a FIA EPTA-Eurex Group co-hosted webinar on December 2. The landscape is being transformed as a consequence of fundamental shifts in liquidity provision, the rise of automated trading, and a thirst for innovation.

And these changes have already disrupted the traditional buy-side/sell-side relationship and seen asset managers moving from liquidity takers to liquidity makers.  

The webinar was centred on the impact of Covid on liquidity provision in Europe’s capital markets, the structural shifts which are taking root and the implications for future market development.

It featured Robert Miller, Executive Consultant with Vanguard Asset Management, Mike Kuehnel CFO of Flow Traders,  Piebe Teeboom, Secretary General of FIA EPTA, and Jonas Ullman, COO ofEUREX. It follows a new research report written by Redlap Consulting and commissioned by FIA EPTA – which represents Europe’s market-making community – detailing alternative liquidity providers’ growing role and their embrace by the buy-side.

Contrary to what most expected at the time, panelists agreed the pandemic had actually opened the gates to a new wave of innovation. This was made possible by the adoption of electronic trading, an innate advantage for independent market makers who have seen their reach multiply. With capital markets drying up during the pandemic’s peak, these alternative liquidity providers earned themselves the buy-side’s trust by jumping in to keep the wheels of the finance going.

As a result, many capital allocators are now seeking to change their liquidity formation practices. Redlap’s survey shows 53% have already done so, a deep shift for an industry with entrenched habits. The rise of electronic trading and ETFs,  providing more price data for corporate bonds and price discovery, have helped cement these changes even as pandemic turmoil withdrew.

The webinar, which addressed last year’s liquidity turmoil, lessons learnt from the crisis, and the future of liquidity formation, became most animated when discussing ongoing technological innovations. 

Market participants shifting to electronic execution are harnessing a transparency not seen before. This is enabling all participants (retail and institutional) to understand what liquidity is available, where it resides, and how to engage with it. Innovation in alternative asset classes is contributing to the buy-side ownership of the order routing processes becoming truly agnostic. The future of liquidity formation will also include advances in pricing mechanisms – the traditional role of inventory vs liquidity premium/discounts – along with a growing use of ETFs in Fixed Income.

Further driven by a parallel rise in retail involvement, these developments are altering the market eco-structure. 

 The diversification of liquidity providers will continue to increase democratic access, leading up-and-coming challengers to improve offerings and prices. Panelists hoped these developments would change regulators’ approach from a more reactive approach to being one of a pro-active architect, enabling innovation and choice for end-investors.

Panelists reminded the audience that all have a role to play in engaging with regulators, ‘’to build the foundations of a forward-looking market architecture’’. Importantly, there is a need to demonstrate the industry’s positive impact in the lives of everyday European citizens who rely on firms for their pensions.   

The final portion of the talk was dedicated to the hopes panelists had for the future of capital markets. Opinions ranged from  embracing asset classes not yet in use to ever more transparent data for the buy-side. Some posited reduced frictions for capital mobility will increase retail participation, and illiquid assets today will become increasingly liquid through tokenization.

However, all agreed it was necessary to partner with policymakers and regulators to keep laws in line with the rapid pace of market innovation.  As summarized by one speaker: ‘’What I dream for the future is of a European capital market that truly achieves better outcomes for society and for the end investor. We are working towards a fully integrated single market for financial instruments and a shared consolidated tape.’’ Looking back ten years from now, panelists asserted 2020 – 2021 would be seen as pivotal years for liquidity provision, and as catalysts for renewed innovation in finance.