Eliminating every trading error is impossible and the way to address malfunctions that have plagued equity markets this year is to improve testing and oversight, industry executives said at a meeting in Washington.
Making risk measures redundant, designing systems that operate independently of each other and making frequent, incremental changes to software will limit the inevitable mistakes by humans and computers, Getco LLC said in written testimony. Assertions that markets were more orderly in the past are baseless and inflexible regulation won’t automatically improve the performance of trading systems, Citadel LLC said.
Spurred into action after Knight Capital Group Inc. (KCG) bombarded exchanges with erroneous orders on Aug. 1, the Securities and Exchange Commission called today’s meeting to explore ways to avoid technology malfunctions and limit the disruption they cause. SEC Chairman Mary Schapiro said the Knight event was “unacceptable” in August and promised to issue regulations to help prevent similar mishaps.
“We believe that a firm’s systems, protocols and procedures should be designed with the knowledge that there will be human mistakes and technology breakdowns that lead to trading errors and system failures,” Jonathan Ross, chief technology officer for Chicago-based Getco, wrote. “Good testing protocols increase the likelihood that errors are identified and corrected.”
Knight, one of the biggest market makers in U.S. stocks, lost $440 million and avoided bankruptcy only after a cash infusion from investors following its software breakdown. The error followed mishandled initial public offerings by Facebook Inc. and exchange-operator Bats Global Markets Inc.
“Technology has pitfalls,” Schapiro said today. “And when it doesn’t work quite right, the consequences can be severe. Trading can be disrupted, investors can suffer financial loss, firms can be imperiled and confidence in our markets broadly can erode.”
She compared the potential consequences of trading errors to traffic lights that flash the wrong color or railroad track switches that send a train to the right instead of left. When trading goes awry it doesn’t take long for an “enormous amount of damage” to occur, she said.
Getco, which makes markets on the floor of the New York Stock Exchange and on other venues across asset classes, outlined a set of programming values it said would minimize trading disruptions.
It said systems should be independent of each other to keep errors from affecting other programs, firms should prefer smaller changes over larger ones so that when errors occur they can be easily fixed, and risk controls should be layered and redundant, according to its written testimony.
“There is not a specific testing discipline that is appropriate for all firms,” the firm wrote. “Instead, the specific procedures will vary depending on the size, scope, trading strategies and business lines of that firm.”
Software testing protocols vary across brokers and trading firms, Lou Pastina, executive vice president for NYSE operations at exchange operator NYSE Euronext, said at the meeting. The cycle of coding, testing and implementing software may encompass anything from specifications written on a napkin in a bar to a “more disciplined approach where an idea has to pass through a set of filters,” he said.
An approach to testing should be implemented where exchanges make so-called test symbols available to firms so they see how the tactics work, according to Chris Isaacson, chief operating officer of Bats. While testing individual components of software and how entire programs operate after changes are made is critical, it remains difficult to “simulate the market” and the complexity of trading, he said.
NYSE Euronext’s (NYX) Pastina said regulators may want to review the frequency with which brokers and other firms use exchanges’ systems to test their algorithms and trading.
“It’s amazing to me how many times software gets introduced and firms don’t test with you,” he said. “Whether we have test symbols in production or we run industry tests, it’s always the same firms that come in and test and those are the firms that generally don’t have issues. There’s a long list of firms that never show up.”
While Knight’s mishap started on Aug. 1 with a software error, it lingered for another half hour because of a “risk- management and control and management processes problem,” Jamil Nazarali, head of Citadel Execution Services, said today. The unit of Citadel, the hedge fund founded by Ken Griffin, competes in electronic market making with Knight, where Nazarali worked before joining the Chicago-based firm.
Deciding when enough testing has been done for a strategy or program to be deployed is a judgment call, he said.
“You never really know if the testing is enough,” Nazarali said. “It’s really just a business judgment where you look at the cost-benefit of a potential error.” Larger firms like his, which are more likely to be affected if a problem hurts the broader market and investor confidence, tend to be more careful than smaller brokers, he said.
Beyond testing a new version of software, firms should examine what may happen if it fails, said Sudhanshu Arya, a managing director at broker Investment Technology Group Inc. They should test whether a previous version can be reinstated if a mishap occurs and build into software ways to address “double failures” such as risk controls or shutdown mechanisms that don’t work, he said.
While the panel focused on testing software and processes for trading firms, Getco’s Ross said internal operations departments need more standards and rules for when and how individuals can implement shut-downs or halts.
“Operations are really where the rubber hits the road,” Ross told the SEC. “Their ability to shut off their system and not face their feet being held to the fire is incredible. That’s a command and control thing. It’s absolutely important.”
The SEC fueled the march to electronic trading when it passed rules starting in the 1990s designed to drive down costs for investors. In 2005 it approved rules to increase competition with the then-dominant New York Stock Exchange. Now more than 50 venues get trades that are mostly handled by computers.
Critics say the policy may have worked too well, fostering so much fragmentation that the SEC and other regulators can’t get a handle on what is happening in far-flung trading venues until it’s too late. Knight’s loss is a “wake-up call” highlighting the connectedness of markets, Schapiro said.
“Our multi-venue, interlinked market structure also means that an infrastructure failure by one party or at one venue may cascade into other venues and affect many other participants,” Schapiro said. “And of course the inherent speed of trading, which itself is partly a result of the competitive nature of our markets, means that even small, short-lived infrastructure issues can cause drastic harm.”
Citadel said in its written testimony that computerized trading has lowered costs, improved transparency and increased competition. Critics of today’s structure are wrong when they say the old days were better, Nazarali wrote.
“Before widespread computerized trading, markets were notoriously opaque and errors and control breakdowns were the norm,” the firm wrote, saying profits were larger for market makers and trade breaks and delays more frequent. “Although some choose to reminisce fondly about the past, the reality was much different.”
Minimizing the effect of technology breakdowns requires regulators to define and enforce “minimum frameworks” for system controls and to give exchanges the authority to halt activity that is erroneous, Citadel said.
“Nonetheless, we caution against adopting recommendations based on an overly simplistic ‘one size fits all’ perspective,” the firm said. “Trading systems are necessarily complex and malfunctions are inherent in complex automated systems. Therefore, markets will be best protected by multiple, effectively designed layers of protections that reduce the frequency and impact of malfunctions.”
After trading errors occur, it would be useful if a central clearinghouse of information existed to tell other firms about the details and circumstances, according to testimony signed by Richard Gorelick of RGM Advisors Inc., Cameron Smith of Quantlab Financial LLC and Peter F. Nabicht of Allston Trading LLC.
“This would help to avoid future errors, in part, by industry participants learning from each other,” they wrote. “The reporting system would be voluntary and anonymous, yet contain enough information about the nature of events that other participants can learn something from the disclosure.”
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