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EU defines HFT trading

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 Ron Leplae, Global PaaS - eComm at Verifone

 Saturday, April 30, 2016

I haven't seen a lot of people talking (yet) about the recent definition by the EU regulator of HFT. I am not active in any form of HFT but this recent definition puts my algorithmic trading clearly into the same basket as HFT, while I don't feel this is correct. The 1 million euro question will be, what are the consequences of being put into that basket ? If my algo fires 2+ different orders for an instrument, I like to see them filled and executed. I'm not playing any games based on speed, front-running or obfuscation. Am I the only one that thinks like this ? http://www.out-law.com/en/articles/2016/april/eu-defines-high-frequency-trading/


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7 comments on article "EU defines HFT trading"

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 Glen Whitehead, Consultant in Artificial Intelligence and Critical Infrastructure

 Saturday, April 30, 2016



That definition must be incomplete. In 2012, the UK Government Office for Science made these comments on EC definitions:

"... the majority of market participants would appear to be caught by this requirement..." and "the impact of such a requirement would .. extend significantly beyond high-frequency traders."

The context specifically refers to low-frequency market making, but it is clear that the EC definition risks classifying almost every intra-day tactic a HFT.

https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/289062/12-1080-eia21-economic-impact-mifid-rules-high-frequency-trading.pdf


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 Ron Leplae, Global PaaS - eComm at Verifone

 Saturday, April 30, 2016



Here is a link to the full text :

http://ec.europa.eu/transparency/regdoc/rep/3/2016/EN/3-2016-2398-EN-F1-1.PDF

See Article 19 which reads :

Article 19

High frequency algorithmic trading technique

(Article 4(1)(40) of Directive 2014/65/EU)

1. A high message intraday rate in accordance with Article 4(1)(40) of Directive

2014/65/EU shall consist of the submission on average of any of the following:

(a) at least 2 messages per second with respect to any single financial instrument

traded on a trading venue;

(b) at least 4 messages per second with respect to all financial instruments traded

on a trading venue.


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 Glen Whitehead, Consultant in Artificial Intelligence and Critical Infrastructure

 Saturday, April 30, 2016



The key statement in the full text is "on average", such that 2 messages per second could be similar to 7,200 messages per hour. The only problem with this definition is that units of time are irrelevant to order submissions that are triggered by price action. The article also refers to capability, "A person shall be considered not capable of electronically transmitting orders relating to a financial instrument directly to a trading venue .. where that person cannot exercise discretion regarding the exact fraction of a second of order entry and the lifetime of the order within that timeframe", which implied to me that most market participants are not impacted by the directive.


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 Marc Verleysen, founder at TSA-Europe -systematic trading and money management

 Wednesday, May 4, 2016



If I get this correctly, strategies based on timeframes (1 minute, 5 min, 1 hour) are not impacted by this proposal unless you send out thousands of messages (orders) on thousands of financial instruments.

That leaves me off the hook. Anyone in this forum really affected by this ?


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 Glen Whitehead, Consultant

 Wednesday, May 4, 2016



I don't think so because sending thousands of orders on thousands of instruments is not dependent on having the capability to control fraction of second order entry. I think that systems that execute at the current moment (an infinitively small timescale) but which submit their messages via the Internet are also unaffected. Different infrastructure is used by those institutions using direct market access from black-boxes located inside exchanges, and I think they are more likely to be impacted by the directive.


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 Ron Leplae, Global PaaS - eComm at Verifone

 Wednesday, May 4, 2016



My systems fires several orders, more than 2 per second (as per the definition) in 1 instrument but I do not have a direct CME connection and I don't control the exact fraction of the second of execution (not important for my algorithms) and I don't kill the order unless conditions change, the order is placed to get filled.


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 Jose Penalva, Associate Professor, Universidad Carlos III

 Thursday, May 5, 2016



I am just surprised that regulators insist on trying to label traders while their role should be about avoiding inappropriate behavior. Regulate the actions, not the people

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