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[转贴] 美证交会拟禁闪电交易并对评级公司实施新规定

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发表于 2009-9-17 09:30 AM | 显示全部楼层 |阅读模式


美证交会拟禁闪电交易并对评级公司实施新规定

2009年09月17日 21:08  新浪财经

  新浪财经讯 北京时间9月17日晚间消息,据国外媒体今日报道,美国证券交易委员会(SEC)将考虑禁止“闪电命令”(Flash Order)交易,并对信用评级公司实施新的规定,防止其误读投资不良抵押贷款债券的风险。

  证券交易委员会定于美国东部时间14:30(北京时间2:30)召开会议,就是否禁止“闪电命令”交易的问题进行投票。此外,该委员会还将考虑加强对穆迪投资者服务机构(Moody’s Investors Service)、标准普尔和惠誉评级(Fitch Ratings)等信用评级机构的信息披露要求。

  所谓“闪电命令”交易,是指大投行用高速计算机比一般人早0.03秒获取市场信息,再通过高频交易赚取暴利。以纳斯达克股票交易市场为例,投资者的买卖交易信息往往一闪而过便进入计算机的这些高频买卖集合中,这比在市场上向每个人公开要早0.03秒。在半秒的时间内,大型投行所使用的高速计算机软件就能洞察出有价值的信息,如某些股票需求的增加或减少。因此,大型投行可以利用这一优势,先于市场上的其他投资者参与股票交易,从而将股价推高或打压。
发表于 2009-9-17 09:32 AM | 显示全部楼层
good news for us!
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发表于 2009-9-17 09:46 AM | 显示全部楼层
Seriously, I think the uproar about flash order affecting price is a joke.

How many times you see stock price change more than 1 penny per second?

If not many, what is the big deal?

How many times you buy stock at exact top or bottom? Even for that 30 minute period?

If not many, what is the big deal?

I have some issues with HFT, but mainly because it will increase volatility, not that it will change eventual outcome.
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发表于 2009-9-17 09:53 AM | 显示全部楼层
Seriously, I think the uproar about flash order affecting price is a joke.

How many times you see stock price change more than 1 penny per second?

If not many, what is the big deal?

How many  ...
polopolo 发表于 2009-9-17 10:46


但是有一点是肯定的- 高频Flash Order 获利还是十分巨大的。这些利润从哪来的呢?不是凭空而来,是他们从买、卖双方手中挤出来的。所以,他们的获利就是其它人的亏损。
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发表于 2009-9-17 10:30 AM | 显示全部楼层
本帖最后由 polopolo 于 2009-9-17 11:32 编辑

4# yaobooyao

My bet is, it is not significant.

Sure, a couple of millions here, a couple of millions there. You add them up, maybe a couple of billions (even that I think it is a gross overestimation).

Flash order is nothing new, one can refer to a 2006 era presentation by Intel's CEO (Woodcrest release event or analyst meeting of 2006). One example in that presentation? Extremely high speed/frequency trading on AAPL (because he was counting the extra profit earned by the computer by the end of day using newer Intel chip).
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发表于 2009-9-17 10:58 AM | 显示全部楼层
4# yaobooyao

My bet is, it is not significant.

Sure, a couple of millions here, a couple of millions there. You add them up, maybe a couple of billions (even that I think it is a gross overest ...
polopolo 发表于 2009-9-17 11:30


The Intel story is really good.

It's both Pros and Cons with those flash order.  It really depends on the evaluation of SEC.
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发表于 2009-9-17 05:21 PM | 显示全部楼层
It does matter!  I place order though fidelity and optionshouse. fidelity is fast and I always get better price (1-2 cents/spy option) than optionshouse though optionshouse is cheaper.
That is why I have been looking for a new broker - optionshouse is sheaper but slower while fidelity is fast but more expensive.
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发表于 2009-9-17 05:32 PM | 显示全部楼层
as I remmber Quan MM cares about having a broker that is 15 seconds fast. I might remember wrong.
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发表于 2009-9-17 05:43 PM | 显示全部楼层
GS的暴利会不会骤减??
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发表于 2009-9-20 09:23 PM | 显示全部楼层
Flash Order 不是这个意思!
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发表于 2009-9-20 09:37 PM | 显示全部楼层
From Flash Orders to Dark Pools
Posted on September 9th, 2009 at 10:06 am by Scott Boyd

Much has been written lately around two controversial trading approaches known as flash orders and dark pools. For the uninitiated, the recent focus on these practices may lead one to believe they only recently arrived on the scene, but in fact, they have been in use for several years. Both concepts rely heavily on the use of sophisticated computer systems and dedicated software and for this reason, are often lumped into the larger category of High Frequency Trading (HFT). On the surface, this may be an accurate categorization, but whereas HFT seeks to use computers and technology to send many trades to the market to take advantage of miniscule price changes, flash orders and dark pools use technology – and a little help from certain exchanges – to try to take advantage of other market participants.

How Flash Orders Damage Market Integrity

Flash orders hit the airwaves again in early August when Senator Charles Schumer pronounced they were unfair and were a threat that “seriously compromises the integrity of our markets and creates a two-tiered system where a privileged group of insiders receives preferential treatment, depriving others of a fair price for their transactions.”

So adamant was Schumer, that he basically threatened Securities and Exchange Commission (SEC) officials to either outlaw the practice willingly, or he would introduce legislation himself to mandate the change. Within days, word came from SEC head Mary Shapiro that the SEC would see that flash orders were banned from all U.S. exchanges.

Flash orders were first developed by Direct Edge, a financial electronic communication network (ECN) providing an electronic exchange for equity trading. In order to take order flow from older, more established exchanges, Direct Edge pioneered the concept of the flash order which provides a “sneak peak” at prices ahead of the general market. It works like this.

Smaller exchanges are forced to pass parts of large orders to the major exchanges including the New York Stock Exchange and Nasdaq if they cannot fill them with their own market participants. Naturally, they lose much of the revenue the trade would generate, so in order to encourage greater participation within their own exchange, orders are flashed to the ECN’s biggest customers for up to half a second before the order is released to the market.

Armed with an advanced look at the market price, and by using computers to quickly look at the total depth of the market for the security across all exchanges together with all outstanding orders, these automated systems can quickly determine if there is a profit opportunity by entering into a trade – even if they take a position for only a fraction of a second. For instance, if the price for a particular stock is increasing, and the preferred customer receiving the early look sees that the availability is limited yet demand is relatively high, the broker’s automated trading system will buy up the stock ahead of the rest of the market. The system can then turn around and sell the stock back at a profit and while the difference may not be that great, the volumes involved ensure significant profits.

Proponents of flash orders argue that flashing orders makes it more likely that a transaction will be completed, thus ensuring sufficient liquidity for the stock, but this is at best, a weak defense. The reality is that flash orders give preferred customers a chance to – at the very least – influence prices in their favor. At worst, it actually leads to outright price manipulation. Either way, flash orders make a mockery out of the notion that all market participants are equal.

Using Dark Pools to Hide Market Activity

Not to be outdone by Schumer, Senator Edward Kaufman has set his sights on “dark pools”. On the surface, dark pools are not as sinister perhaps as flash orders but ultimately, their purpose is to deceive the market with respect to the positions being traded. Perhaps “deceive” is a bit harsh – let’s say they are used to hide the size of positions being traded in an attempt to reduce price volatility.

Yes, I can hear you saying that this sounds like a simple iceberg order where large trades are broken into smaller orders. This is a well-used tactic designed to obscure the actions of a single broker, and is so common-place that most trading platforms can be configured to “slice” large orders into a series of smaller orders automatically. Each slice is then submitted as an individual order to camouflage the fact that all these orders are coming from one source. This practice is often defended using the logic that if a broker were to submit one massive sell order for example, the price would be pushed downwards, and because it is usually hedge funds or mutual funds dealing in this size of order, individual investors could suffer.

There is merit to that argument, but dark pools have an important distinction from iceberg orders. Dark pools – like flash orders – incorporate “early looks” for dark pool participants providing advance knowledge not only with respect to bid and offer prices, but also the total size of the order and not just each individual slice. This information is not available to the general market, thus calling into question the idea of true transparency of the market.

As testament to how effective dark pools can be, one of the largest dark pools in operation is known as “Sigma X”. It is managed by Goldman Sachs and is thought to be largely responsible for Goldman Sachs’s tremendously profitable trading program earlier this year.
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发表于 2009-9-20 09:38 PM | 显示全部楼层
How You Finance Goldman Sachs’ Profits
An insider’s view of Wall Street’s rebound.
—By Nomi Prins


This is perhaps the most important thing I learned over my years working on Wall Street, including as a managing director at Goldman Sachs: Numbers lie. In a normal time, the fact that the numbers generated by the nation's biggest banks can't be trusted might not matter very much to the rest of us. But since the record bank profits we're now hearing about are essentially created by massive federal funding, perhaps it behooves us to dig beneath their data. On July 27, 10 congressmen, led by Rep. Alan Grayson (D-Fla.), did just that, writing a letter to Federal Reserve Chairman Ben Bernanke questioning the Fed's role in Goldman's rapid return to the top of Wall Street.

To understand this particular giveaway, look back to September 21, 2008. It was a frenzied night for Goldman Sachs and the only other remaining major investment bank, Morgan Stanley. Their three main competitors were gone. Bear Stearns had been taken over by JPMorgan Chase in March, 2008, Lehman Brothers had just declared bankruptcy due to lack of capital, and Bank of America had been pushed to acquire Merrill Lynch because the firm didn't have enough cash to survive on its own. Anxious to avoid a similar fate, hat in hand, they came to the Fed for access to desperately needed capital. All they had to do was become bank holding companies to get it. So, without so much as clearing the standard five-day antitrust waiting period for such a change, the Fed granted their wish.

Bank holding companies (which all the biggest financial firms now are) come under the regulatory purview of the Fed, the Office of the Comptroller of the Currency, and the FDIC. The capital they keep in reserve in case of emergency (like, say, toxic assets hemorrhaging on their books, or credit derivatives trades not being paid) is supposed to be greater than investment banks'. That's the trade-off. You get access to federal assistance, you pony up more capital, and you take less risk.

Goldman didn't like the last part. It makes most of its money speculating, or trading. So it asked the Fed to be exempt from what's called the Market Risk Rules that bank holding companies adhere to when computing their risk.

Keep in mind that by virtue of becoming a bank holding company, Goldman received a total of $63.6 billion in federal subsidies (that we know about—probably more if the Fed were ever forced to disclose its $7.6 trillion of borrower details). There was the $10 billion it got from TARP (which it repaid), the $12.9 billion it grabbed from AIG's spoils—even though Goldman had stated beforehand that it was protected from losses incurred by AIG's free fall, and if that were the case, would not have needed that money, let alone deserved it. Then, there's the $29.7 billion it's used so far out of the $35 billion it has available, backed by the FDIC's Temporary Liquidity Guarantee Program, and finally, there's the $11 billion available under the Fed's Commercial Paper Funding Facility.

Tactically, after bagging this bounty, Goldman asked the Fed, its new regulator, if it could use its old risk model to determine capital reserves. It wanted to use the model that its old investment bank regulator, the SEC, was fine with, called VaR, or value at risk. VaR pretty much allows banks to plug in their own parameters, and based on these, calculate how much risk they have, and thus how much capital they need to hold against it. VaR was the same lax SEC-approved risk model that investment banks such as Bear Stearns and Lehman Brothers used, with the aforementioned results.

On February 5, 2009, the Fed granted Goldman's request. This meant that not only was Goldman getting big federal subsidies, but also that it could keep betting big without saving aside as much capital as the other banks. Using VaR gave Goldman more leeway to, well, accentuate the positive. Yes, Goldman is a more risk-prone firm now than it was before it got to play with our money.

Which brings us back to these recent quarterly earnings. Goldman posted record profits of $3.4 billion on revenues of $13.76 billion. More than 78 precent of those revenues came from its most risky division, the one that requires the most capital to operate, Trading and Principal Investments. Of those, the Fixed Income, Currency and Commodities (FICC) area within that division brought in a record $6.8 billion in revenues. That's the division, by the way, that I worked in and that Lloyd Blankfein managed on his way up the Goldman totem pole. (It's also the division that would stand to gain the most if Waxman's cap-and-trade bill passes.)

Since Goldman is trading big with our money, why not also use it to pay big bonuses? It's not like there are any strings attached. For the first half of 2009, Goldman set aside $11.4 billion for compensation—34 percent more than for the first half of 2008, keeping them on target for a record bonus year—even though they still owe the federal government $53.6 billion, a sum more than four times that bonus amount.

But capital is still key. Capital is the lifeblood that pumps through a financial organization. You can't trade without it. As of June 26, 2009, Goldman's total capital was $254 billion, but that included $191 billion in unsecured long-term borrowing (meaning money it had borrowed without putting up any collateral for it). On November 28, 2008 (4Q 2008), it had only $168 billion in unsecured long-term borrowing. Thus, its long-term unsecured debt jumped 14 percent. Though Goldman doesn't disclose exactly where all this debt comes from, given the $23 billion jump, we can only wonder whether some of it has come from government subsidies or the Fed's secret facilities.

Not only that, by virtue of how it's set up, most of Goldman's unsecured funding comes in through its parent company, Group Inc. (Think the top point of an umbrella with each spoke being a subsidiary.) This parent parcels that money out to Goldman's subsidiaries, some of which are regulated, some of which aren't. This means that even though Goldman is supposed to be regulated by the Fed and other agencies, it has unregulated elements receiving unsecured funding—just like before the crisis, but with more of our money involved.

As for JPMorgan Chase, its profit of $2.7 billion was up 36 percent for the second quarter of 2009 vs. the same quarter last year, but a lot of that also came from trading revenues, meaning its speculative endeavors are driving its profits. Over on the consumer side, the firm had to set aside nearly $30 billion in reserve for credit-related losses. Riding on its trading laurels, when its consumer business is still in deterioration mode, is not a recipe for stability, no matter how much cheering JPMorgan Chase's results got from Wall Street. Betting is betting.

Let's pause for some reflection: The bank "stars" made most of their money on speculation, got nearly $124 billion in government guarantees and subsidies between them over the past year and a half, yet saw continued losses in the credit products most affected by consumer credit problems. Both are setting aside top-dollar bonuses. JPMorgan Chase CEO Jamie Dimon mentioned that he's concerned about attracting talent, a translation for wanting to pay investment bankers big bucks—because, after all, they suffered so terribly last year, and he needs to stay competitive with his friends at Goldman. This doesn't add up to a really healthy scenario. It's more like bad déjà vu.

As a recent New York Times article (and many other publications in different words) said, "For the most part, the worst of the financial crisis seems to be over." Sure, the crisis may appear to be over because the major banks of Wall Street are speculating well with government subsidies. But that's a dangerous conclusion. It doesn't mean that finance firms could thrive without the artificial, public-funded assistance. And it certainly doesn't mean that consumers are any better off than they were before the crisis emerged. It's just that they didn't get the same generous subsidies.

Additional research by Clark Merrefield.
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发表于 2009-9-20 09:39 PM | 显示全部楼层
By Justin Schack

Published: August 2 2009 17:50 | Last updated: August 2 2009 17:50

It finally happened. After years of operating in obscurity, high-frequency
traders have been thrust into the public spotlight. What started with a
publicity-hungry critic or two ranting on the internet has given way to
breathless media coverage — and questions from Washington policy makers.

Unfortunately, much of this publicity has been riddled with errors and half-
truths. And the cumulative effect has been to demonise high-frequency
trading as a shadowy activity through which sophisticated elites exploit
unfair advantages to reap billions in profits at the expense of ordinary
Americans.

In other words, high-frequency trading is in danger of joining short selling
and commodity speculation in the post-crisis pantheon of misunderstood
market practices. This process typically begins with self-interested
business people “raising questions” about whether a little-known activity
is harming the public. Then, well-intentioned but under-informed financial
journalists (trust me, I used to be one) rush to be the first to “expose”
these allegedly damaging practices. Politicians pounce on a fresh wave of
populist rage. Congressional hearings are scheduled. Regulators are pressed
to “do something” about a problem that doesn’t exist. And, sometimes, we
wind up with new regulation that does more harm than good.

That’s why it’s important to inject some balance into the high-frequency
debate. First, full disclosure: my employer, Rosenblatt Securities, provides
brokerage, consulting and research services to high-frequency firms. But we
do no proprietary trading, and the vast majority of our revenues comes from
“high-touch” trading for traditional institutions that manage trillions
in average Americans’ savings. We want to educate investors about both the
negative and positive effects of high-frequency strategies.

Make no mistake, this phenomenon has complicated traditional traders’ lives
. Superior mathematics and computing power lets high-frequency firms manage
risk better than ever, routinely quote the best prices first and,
consequently, reap most of the rebates exchanges pay to liquidity providers.

Less-sophisticated traders can find themselves hitting bids and lifting
offers — and paying exchange fees — even in situations when they’d rather
provide liquidity and earn rebates too. The end result: their exchange-fee
bills rise. This cuts profit margins for brokers, making them less likely to
reduce commission rates for end customers. It also can force potential
counterparties to trade with high-frequency firms rather than directly with
each other, inflating overall market volume. That can confuse algorithms
that traditional institutions use to buy or sell set percentages of a stock
’s daily volume, and potentially increase their implicit transaction costs.

But high-frequency traders also bring substantial benefits to the market. As
the US market has changed in the past decade, automated market-making and
arbitrage strategies have supplanted New York Stock Exchange specialists and
old-style Nasdaq market makers as the primary source of liquidity for the
investing public. Competition among high-frequency firms has improved quoted
prices, compressed bid-ask spreads and reduced transaction costs
dramatically for all investors. Statistics strongly support this trend.

Most importantly, high-frequency trading is not the same as “flash”
trading. Flash programmes let exchanges and ECNs [electronic communications
networks] delay routing orders to the best quoted prices so that customers
who opt in can view and elect whether or not to trade with them first. Flash
orders raise serious market-structure and surveillance questions, and
deserve the regulatory scrutiny they are receiving. High-frequency firms are
likely the chief recipients of flashed orders, but this constitutes a tiny
fraction of their overall trading activity. And at least one huge high-speed
firm is publicly against the practice.

One prominent critic recently suggested during a television appearance that
if flash orders went away, exchanges would lose the 70 per cent of their
volume that comes from high-frequency traders. This is grossly inaccurate.
Flash orders have become popular only in the last several months, but high-
frequency firms have dominated US trading for far longer. According to our
data, flash orders accounted for just 2.4 per cent of US equity trading in
June. The vast majority of high-frequency activity occurs in markets that
display firm quotes and, unlike most flash orders, helps investors transact
at the best possible prices.

Some have suggested that high-frequency trading unnaturally props up stock
prices. Others, including a recent New York Times opinion piece, warn that
its “sudden popularity” could “destabilise the market,” creating the
potential for panics triggered by computer errors. An additional line of
attack centres on the practice of co-location, through which high-frequency
firms house their servers in exchange data centres to minimise the time it
takes to execute trades.

Here is the truth: most high-frequency firms aim to end each day flat. Some
will carry overnight positions, but these typically stem from arbitrage
strategies that attempt to counter and profit from inefficiencies, not
contribute to them. They do not take a view on the market and are not
artificially inflating or deflating share prices.

Additionally, their notoriety may be “sudden,” but their popularity is
anything but. High-frequency firms have accounted for a very big chunk of US
equity trading for years (we estimated them at two thirds of overall volume
about 18 months ago). They were the biggest source of liquidity on exchange
-traded markets that performed incredibly well during the worst financial
crisis in eight decades — the very same markets that regulators, before all
this high-frequency hysteria was whipped up, were celebrating and looking
to bolster by encouraging the migration of OTC [over-the-counter] activity
onto exchanges.

And co-location is merely the information-age manifestation of traders
wanting to be as close as possible to the point of sale. It’s no different
than brokers manning every room of the NYSE floor to be close to every stock
’s specialist, or commodity traders elbowing — or sometimes punching —
their way to the top step of the pit.

In short, high-frequency traders have made the US stock market more
efficient than ever. However, a hyper-efficient market is, by definition,
not the most democratic market. High-frequency firms have decided to invest
in technology and brainpower that give them an edge over others. Competition
in free markets has always been thus. They are not, as one dark-pool
executive said: “the natural enemy of institutional investors.” Rather
than complain that old trading methods are no longer as effective in this
new environment, critics would do better to adapt, so they may reap the
benefits of the high-frequency explosion while minimising its complications
and costs.

Justin Schack is vice president, market structure analysis, at Rosenblatt
Securities, a New York agency brokerage. This essay is a preview of a
forthcoming paper by Rosenblatt on the topic of high-frequency trading.

Copyright The Financial Times Limited 2009
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发表于 2009-9-20 10:05 PM | 显示全部楼层
GS的暴利会不会骤减??
GoodLand 发表于 2009-9-17 18:43


应该不会吧。 FO 交易只占高频交易的很少一部分。
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发表于 2009-9-20 10:19 PM | 显示全部楼层
13# yaobooyao

High Frequency Trading makes the market much more liquid and efficient, and so that any speculation or manipulation is much more difficult
than ever before.  Amongst the main benefits, a bigger part (momentum part is smaller) of HFT is of mean reversion type: for instance, if the opening price is too low, they buy.  Hence it stabilizes the market. Most big money must earn by manipulation. They are losing money now
because their failing to manipulate.
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