AFME/FINBOURNE study shows need for longer deferrals for large fixed income trades
03 May 2022
This shows that the majority of fixed income trades could be made transparent in near real-time, but also finds there is a clear need for a longer deferral period for the publication of larger or illiquid trades.
The Association for Financial Markets in Europe (AFME) has today
published a first of its kind study consolidating fixed income trading
data from numerous sources for the period of March to December 2021.
This shows that the majority of fixed income trades could be made
transparent in near real-time, but also finds there is a clear need for a
longer deferral period for the publication of larger or illiquid
trades. Data provided by FINBOURNE Technology for this study
demonstrates that an inadequate deferral calibration - as currently
proposed by the European Commission - could have potentially significant
negative implications for market liquidity.
In 2021, as part of the Markets in Financial Instruments Regulation
(MiFIR) review, the Commission set out changes to bond market
transparency which included harmonising the deferral regime and
shortening post-trade publication delays.
The AFME paper analyses recent European fixed income trade data from
around 5500 of the most frequently traded securities. The analysis
focuses on the corporate bond landscape (rather than government bonds)
to identify which types of trades could be subject to near real-time
price and volume transparency, and which types of trades should be
subject to deferrals.
From the data set studied, AFME and Finbourne find that different
deferral periods need to be applied based on the trade size and issuance
volume, among other characteristics. Applying the Commission’s proposed
deferral regime to all trades, especially those larger in size or
illiquid, risks exposing liquidity providers to potential undue risks,
which could negatively impact the amount of liquidity/pricing that
market makers are able to provide.
Adam Farkas, Chief Executive of AFME, said: “This
report demonstrates both the value of having a high quality,
consolidated view of bond trading in the EU and the potentially
significant implications of inadequate deferral calibration. Current
proposals to reduce the amount of time that post-trading information can
be deferred from publication could have a negative impact on liquidity
for corporate bonds. This is especially true for large transactions or
trades in bonds that are less liquid, as this would force liquidity
providers to disclose their books to the market before they have unwound
or hedged their positions, resulting in negative outcomes for investors
and a direct hit to liquidity provision. In turn, this could impact the
availability and pricing of funding for EU corporates in primary debt
markets, which is counterintuitive and not in line with the goals of the
Capital Markets Union. Even the Commission proposals implicitly
recognise that there can be downsides to publishing trade information
too quickly because sovereign bonds will benefit from lengthy
publication deferral periods.
“AFME is therefore calling on the co-legislators to ensure that
corporate bonds are not treated less favourably than government bonds
and to avoid hardwiring the proposed price and volume deferral
calibration into primary legislation. A wider range of deferral periods
calibrated to the realities of the fixed income market as demonstrated
in this report is needed instead.”
Thomas McHugh, CEO and Co-Founder, at FINBOURNE Technology,
said: “We are pleased to contribute data analysis to AFME’s study and
support the formulation of evidence-based policy. Combining our data
management expertise and publicly available MiFID transaction records,
we have been able to aggregate over one million transaction records for
this study. This includes, linking transactions to ESMA’s FIRDS
database, normalising the divergent formats, and scenario-testing at a
granular (ISIN by ISIN) level. Our belief is that by making the data
fully transparent, we will help the market to address key issues that
have hindered the successful development of a consolidated tape to
date.”
Key findings:
- Small trades (of less than EUR 500k) account for the
majority (c. 70%) of the overall number of trades in the data set and
can support being reported in near real-time. Therefore, making
these small transactions transparent will significantly improve
transparency by almost 10 fold, increasing from 8% of transactions
currently being reported real-time to almost 70% of transactions
becoming real-time transparent.
- The smaller the trade size and the more liquid the
instrument, the less risk is associated with rapid dissemination of
price and volume information for liquidity providers, with the
‘trade out’ (i.e. moving the risk off the bank’s balance sheet) being
less than 1 day for liquidity providers.
- However, this 70% reflects 13% of market volume. Therefore these
transactions represent a much smaller percentage of market volume than
of the number of trades.
- Larger transactions (of more than EUR 500k) reflect a
relatively small percentage of total transactions, accounting for c. 30%
of total transactions but a much larger share of market volume.
The data set demonstrates that the larger the transaction, the longer
it takes to 'trade out' and clear the market. For trades larger than EUR
1 million, it takes on average 6 business days to ‘trade out’ of
positions. For trades over EUR 5 million it takes on average 19 days to
trade out, while larger trades take even longer.
- The deferral regime should have a conceptual link between trade
size categories (i.e. real-time transparency), bond liquidity and
deferral periods (i.e. for a regime with a higher trade size, or deemed
illiquid the deferral period should be longer);
- Investors who will benefit most from increased transparency are smaller, less sophisticated investors whose trading activity will be concentrated in smaller sized trades.
- At the same time, longer deferrals for the small number of
large transactions should limit the risk of liquidity reduction in the
market for institutional investors.
AFME therefore opposes a hardwiring of price and volume deferral
calibration in primary legislation (as is currently proposed). Since
each fixed income asset class will include a significant number of
illiquid bonds, AFME urges the co-legislators to adopt a range of
deferral periods, going beyond the Commission’s proposal for maximum
deferral period for prices (by the end of the day) and volume (within
two weeks). ESMA will then be able to calibrate the details of which
bonds should go into the various deferral categories, which should be
based off detailed and high-quality data.
AFME
© AFME
