We have moved on from the conference season which highlighted AI, Machine Learning and Algo trading as core topics de jour. Interspersed in this were concerns over information security, predictions of a greater take-up of cloud computing and regulatory attention on cybersecurity. Now we have moved well into Advent and the festive season is getting into full swing. So what has been cropping up behind the doors of the Advent calendar this year?
On 12th December the British electorate will head to the polls for the third time in four years. Each political party is asking the public to put their faith in its manifesto and to fund a splurge in public spending after years of austerity. This has sparked a broader topic of discussion in relation to (i) the extent to which the opportunity to cast our vote represents a chance to hold the conduct of our politicians to account, (ii) assess the policies of the incumbent party during the previous parliamentary period, and (iii) whether there are more efficient (and frequent) ways of making politicians accountable.
Meanwhile, today the Senior Managers Certification Regime (SMCR) comes into effect for solo-regulated firms in the financial sector.
In the UK, one demon that will not be roaming the streets is a hard Brexit following the extension. This has paved the way to a General Election in the festive season. One demon in the UK that has been stalking the European and USA markets will be in the financial news. The opposition party is resurrecting the alchemy of financial taxation, and this could blast an icy chill into the Christmas season if an upset at the polls occurs.
When it’s time to review systems and processes how do you best go about that? Chat to your peers in similar organisations to identify what they’re using? Search the internet? Employ the services of a consultancy firm to do the research for you? They’re all familiar options widely used, and the outcome of each can actually be quite different.
I have always been a fan of the concept of a shared platform across banks. Looking at some of the big examples such as SWIFT and CLS, and the shared ownership/consortium concept such as EBS and FXall, you can see how the utility aspect can be put to good use. As the increased automation of FX trading evolves, customers now have a wide range of choices when it comes to execution of trades. Central Limit Order Books (CLOBs) such as Reuters Matching and EBS have spawned single dealer platforms (SDP) and multi-bank platforms (MBPs) alongside anonymous ECN’s, so a wide choice of platforms have become available, suiting all types of market participant’s preferred execution choices. Technology has allowed for aggregation in what remains a fragmented market place and algorithmic techniques are a growing component across a wide spectrum of the market.
The Women’s World Cup (WWC) has been in full swing and finally we entered the knock out phases after 36 games, 106 goals and plenty of technological controversy, 24 teams became 16 after many dramatic twists and turns. With the climax approaching this weekend, the semi-finals have so far followed suit. Like football, with a team’s coaches, goalkeeper, defence, midfield and strikers with a communicated strategy, a treasury has similar requirements of its technology. As the knockout stages progress we have again seen technology (VAR) continuing to make a difference in key games!
In November last year we held a Breakfast Briefing entitled “New Horizons for Treasury Regulation”, two of the topics we covered were IBOR reforms especially from the legal aspects and the Fundamental Review of the Trading Book and predicted these would come centre stage in 2019.
Delving beyond the world of algo’s/AI, the drive for ever faster speeds and platform consolidation is potentially the return of the utility platform were a shared platform offers efficiencies to a group of participants. For example, the concept of a Regulatory Reporting utility for an association of banks could well lead to better transparency in reporting, higher quality/more accurate data, and lower costs. The benefit of a shared platform would bring efficiencies to the changing reporting requirements and probably lead to a faster deployment.
Following two high profile fines for regulatory reporting failures, totalling nearly £62 million by the UK’s FCA, the fines prompted an interesting observation by the Director of Enforcement and Market Oversight at the FCA.
Here we are … always following new market developments to inform our product development teams … and one item caught my eye in the last week:– Digital Regulatory Reporting (DRR) starring the FCA and a host of collaborative partners! As Ronald Reagan noted having seen the film Back to the Future “Never has there been a more exciting time to be alive, a time of rousing wonder and heroic achievement.”
This week I have been dusting off the Q&A release from ESMA in September 2018 regarding the reporting of FX Swaps to ensure we have successfully planned for the impending changes. The aforementioned Q&A included reference data and transaction reporting scenarios where an FX Swap is reported as a single stand-alone financial instrument. This Q&A implementation period was six months and to ensure a consistent approach across reporting requirements, ESMA also published a Q&A on FX Swaps reporting under EMIR, which should be implemented 12 months after its publication, as it is more difficult to implement, but the two are harmonised to ensure consistency.
Last week we looked at the recent GFXC note on Disclosures and today we take a deep dive into the accompanying report. As will be seen, it continues the theme of the importance of disclosures.