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