July 2014 Market Microstructure Who Gets the Short End of the ‘Tick? by Phil Mackintosh CONTENTS Origins of the pilot 3 The Crib Sheet Greater impact is looming… 5 On June 24, the SEC released its directive for a new tick-size pilot …But not necessarily on the stocks you’d expect 6 Good news: Wider spreads should increase depth 7 Bad news: Market impact may also increase 9 for the market. Three separate pilots affecting 900 stocks for 12 months. The initial impetus for wider tick sizes was to boost initial public offerings and research in small-cap stocks. The $5 billion market cap cutoff, however, means this pilot is including a number of companies in the S&P 500. The inclusion of a one million average daily volume cap and a trade-at requirement makes this pilot look more like a review of liquidity and transparency, rather than a stimulus for small-cap trading. The SEC set the general parameters for the program, requesting three pilot groups, each with 300 stocks and its own set of rules: 1. Quoted (displayed) at 5 cents (Can trade anywhere within the NBBO) 2. Quoted and traded at 5 cents (Dark allowed at midpoint and touch only) 3. Quoted and traded at 5 cents (Dark restricted to midpoint unless removing lit NBBO) The exchanges and FINRA are responsible for setting up the pilot and quantifying the results for the SEC. KCG | MARKET MICROSTRUCTURE 1 Who Gets the Short End of the ‘Tick? We hope it makes illiquid stocks easier to trade In theory, wider tick sizes should make the top of book deeper and less volatile, making it safer to make markets and easier to trade size. Exhibit 1: Full implementation of the rules would see 66% of stocks quoted in 5-cent increments (green). Captured by Pilot Rules By design, the wider ticks are expected to increase market making 1000 Yes profits. The intention is to encourage more research and facilitation No of small-cap trades. But complexity will increase This tick-size proposal has the potential to be quite disruptive. We estimate that two-thirds of the stocks institutions trade regularly will pass the tests for a 5-cent trading increment (Exhibit 1). Ironically, over 60% of these will not see their spreads widen, as their spreads are already more than 5-cents wide. But the additional requirements will increase the complexity of order routing and limit trading (especially during the three-tier pilot).This Number of Stocks 800 600 400 200 appears to be contrary to the overarching desire to make the market Transaction costs are almost certain to go up for institutional investors, as they are typically liquidity takers who cross the spread. NanoCap MicroCap SmallCap MidCap LargeCap And it’s likely that trade costs will go up 0 MegaCap less complex. Source: KCG Data Transferring volume into dark pools would mitigate some of the wider spread costs—this naturally occurs in stocks with wider spreads now. The rules set out in Pilots 2 and 3, however, specifically counter this, and thus will likely increase the effects of lit signaling, as well as exchange payments. KCG | MARKET MICROSTRUCTURE 2 Who Gets the Short End of the ‘Tick? Back in April 2012, the JOBS Act was passed to include a directive that the SEC examines how decimalization impacted small and mid-cap companies. Specifically, the legislation focused on boosting IPOs and support for small-cap risk trading and research. The SEC staff report in July 2012 was mostly a review of academic literature. It noted benefits of lower spreads and lower trading costs. However, the report doubted that lower spreads have impacted capital formation and questioned the link between spreads and incentivizing block risk trading. A simpler way to incentivize block risk trading in small-cap stocks would be to increase the commissions paid on those trades. Consequently, the report concluded that the SEC should not proceed with the specific rulemaking to increase tick sizes. Despite this report, in February 2014 the House passed the Duffy-Carney bill to force the SEC to create a pilot program. Is small-cap liquidity really a problem? It’s all relative. Small-cap stocks are, by definition, well smaller. So it’s no surprise that they trade less value than large-cap stocks. However, we can adjust for their smaller size by looking at their annual turnover. This shows that smaller stocks are materially less liquid, and that this is especially true for stocks outside major benchmarks. Despite this, on average, most trade more than half their market cap each year. exhibit 2: Annual turnover for different sized stocks 4 Annual Turnover Origins of the pilot 3 2 for the market. This pilot has a significantly different objective than the proposals from the JOBS Act or the Duffy-Carney bill. It appears that the SEC has recognized that widening spreads will not lead to the intended outcome of the Duffy-Carney bill—job creation and capital formation. The focus seems to have shifted to enhancing market quality, specifically looking at: NanoCap On June 24, the SEC released its directive for a new tick-size pilot MicroCap 0 SmallCap Pilot focuses on institutions, transparency and liquidity MidCap 1 LargeCap reports, it encouraged the SEC to revisit a pilot tick-size program. MegaCap Although this had not passed the Senate, according to recent CAP SIZE GUIDE Size Market Cap Range Mega Over $50bn Large $2.5bn - $50bn Mid $750m - $2.5bn Small $300m - $750m Micro $100m - $300m Nano Below $100m • Institutional investors: This is possibly in reaction to comments that the winners from decimalization have been retail investors. Source: KCG Data Liquidity = annualized turnover for each company • Transparency: Two of the three pilots will restrict dark pool trading to preference lit venues without any changes to mandated exchange pricing, as we discuss below. KCG | MARKET MICROSTRUCTURE 3 Who Gets the Short End of the ‘Tick? • Liquidity: Market cap cutoffs are materially expanded and, at $5 billion, include companies in the S&P 500. The focus has moved to address companies that trade less than one million shares a day. • Preserving retail investor benefits: By providing for a retail exemption, the SEC seems to be attempting to meet the demands from Congress for implementing the pilot, but also ensuring that retail investors don’t subsidize other market participants by paying higher prices than they should. Key pilot features—and why they may not all align with SEC goals There are three pilots, each with different rules about what price increments stocks can be quoted in and where trades can print (see Table 1). Although the tick-size rules potentially affect thousands of stocks, the pilot will only affect trading in 900 stocks. • The 5-cent spread is designed to increase liquidity at the new, wider NBBO while also making it easier to make markets in the affected stocks. However, the addition of new trading increments and trade-at rules in Pilots 2 and 3 add complexity to the program. • By mandating, in Pilot 3, that broker dealers first take out the NBBO before crossing internally, the SEC is directing significant flow to exchanges. This seems an unusual step, given the overlapping concerns over the impact of access fees on routing, as it will force broker dealers to pay access fees to exchanges. • Increasing transparency also appears to be at odds with the desire to improve institutional investor trading. Under the rules, institutions Table 1: How the pilots will work Lit Market Increments Trading in Dark/Grey Markets Beneficiaries Pilot 1 Pilot 2 Pilot 3 5-cent ticks 5-cent ticks 5-cent ticks Anywhere in the NBBO Midpoint and touch only a Midpoint only a, b Dark pools Block traders Exchanges a There is a retail exemption, provided price improvement is at least a half-cent. Dark pools can trade at the touch in Pilot 3, provided they first sweep lit books. Blocks are allowed to cross internally at the touch. b KCG | MARKET MICROSTRUCTURE 4 Who Gets the Short End of the ‘Tick? will signal their trades to others more quickly and will be forced to interact with market makers even though their broker already has both sides of a trade. Pilot 3 could lead to faulty conclusions exhibit 3: A majority of stocks will be impacted by the tick-size rules proposed, although value traded is less affected. Stocks captured by pilot rules Tick Size Impacted Will quote 5 cents Will trade 5 cents Testing the trade-at requirement without also coupling the test with potential changes to maker-taker, locked markets or order types, for No 1000 example, will make it difficult to draw actionable conclusions, since these issues are all inter-linked. 400 200 Don’t expect an early arrival of results It will be quite some time before we see the true effects and results of 100B upon approval, it will run for a full year. Greater impact is looming… volume curves. Stocks that are captured by the tick-size rules then need to pass all these tests: • NMS common stocks: Around half of all stocks in our universe • Market cap up to $5 billion: Over 80% of all stocks in our universe • Share price at least $2: Over 93% of all stocks in our universe • ADV up to one million shares: Over 78% of stocks in our universe 40B 20B 0B NanoCap We start with a universe of just over 7,000 securities with available 60B MegaCap the proposal on stocks that are most commonly traded by institutions. 80B Trading Value In the pages that follow we study the impact of full implementation of NanoCap Value traded captured by pilot rules MicroCap All told, the pilot seems unlikely to start before 2015. Then, of course, SmallCap followed by an SEC evaluation of all comments. MicroCap MegaCap how they’ll implement the pilot. Next up will be a public comment period SmallCap 0 the tick-size pilot. The SEC is giving exchanges 60 days to agree on MidCap be considered for reform. MidCap unrelated areas of market structure—prompting that they, too, should 600 LargeCap risk that results might mistakenly be used to draw conclusions on LargeCap to isolate the impact of wider spreads on liquidity. There is also greater Number of Stocks The inclusion of trade-at rules in the tick-size pilot will make it difficult 800 Source: KCG Data KCG | MARKET MICROSTRUCTURE 5 Who Gets the Short End of the ‘Tick? Big impact on all traders Stocks with spreads wider than 5 cents will still be impacted, as their quote increment will be a multiple of 5 cents (see the green areas in Exhibits 3 and 4). We estimate over 2,700 stocks (two-thirds) pass all these tests. Adding very illiquid stocks would increase this percentage. Amazingly, over 60% of these stocks already trade with spreads wider than 5 cents (Exhibit 3). However the impact on value traded, which sums less This may mean they will quote with 10-, 15- or even 25-cent spreads. than $8 billion a day, is negligible. …But not necessarily on the stocks you’d expect Looking at the impact on a stock-by-stock basis, it’s interesting how wide the spreads already are on many small-cap stocks. It’s also surprising how broadly the proposed tick-size rules will be felt. All of the stocks colored green and light blue in Exhibits 3 and 4 will be impacted by the tick-size rule. In Exhibit 4: • Light blue circles represent stocks that are likely to see their spread increase up to 500%, as they currently trade with spreads under 5 cents. • Green circles represent stocks that already trade at spreads wider than 5 cents. However, because they don’t pass the liquidity test, these stocks are also captured by the pilot rules, and will quote in 5-cent increments. exhibit 4: Stocks that will see their spreads widened are shown in range. (Circle size shows quote depth.) CSPI SBSA 0.2 BVA MXC IPDN TIK CRV DGLY FFNM TRT Spread ($) 0.1 0.05 EDUC AHPI PBIB RCON ELSE COBR USU GPRC CRVP GVP AEY $10M IDI TRK IRG JBT HPJ INTT CIMT CLUB GILT IMN TINY YOD BIOD CAMT APRI NX AFG IMI $100M PLX IFT HBIO ENZ UIS III IG AZC RP DO TWI LTS AEL AF PF TDS ATU AAN HE $1,000M ST EV P CCK OI Will quote 5 cents AMZN No PPG PRGO AR RL CHTR CP VRX CELG MCK CMI LMT GMCR BEAV MTB VMW PH NOC APH HUM AGN APD CBI PX AMP FDX CPG ECL KORS CHKP SRE HSY JAH FL Will trade 5 cents ALXN UNP H Q GIL KN CPIX PRXI CRDS CBMX CAS FLT BCR IT HI I CUI FCSC ARG SHW HSIC HAR TSLA CLR ICE PXD ACT PII XEC CXO TW ANSS R B TBI ILMN ADS WYNN LNKD BAP TDG AAP CVD CR HNI GNE JVA AMCF DARA DCTH API TPI KIPS HAST BODY COOL TG MFI IEC CEMI GTIM KEX SPW BLFS ANCI CPA BOKF IOC ZU IRIX CF EQIX Z THS DW ALTV BVSN AXR RTGN FRD HIHO EFUT BASI PZZI VIRC MAGS WGA INS ARIS CAW FCVA IGC 0.01 DRQ HITT LL FFG AYI AEHR FFHL 0.02 AXE CKH GNCA FCZA NETE DVCR ERS EVK HUB.B ATK ROG IMMY BG DTE CMA FTI LNC IR EXPD $10,000M CB A CM ACE APC ETN AFL HLT K EL ADP D ADBE BHI GS EOG UTX MMM COST BMO BNS AXP COF CAT ACN CNI IBM BA TMO CI LO EIX AMGN WAG CL BRK.B AAPL MA GILD UPS TD HD CVS F SLB DIS C CVX XOM BAC PG JNJ $100,000M Market Cap ($) Source: KCG Data KCG | MARKET MICROSTRUCTURE 6 Who Gets the Short End of the ‘Tick? Pilot 3 will force investors to pay exchanges more exhibit 5: Most “dark” trades are executed at the NBBO or the mid already. With the exception of retail and VWAP orders, Pilots 2 and 3 require trades to be executed at discrete price points—either mid or touch. 25% Exchange TRF We analyzed executions that occurred inside the NBBO for all stocks. The results are revealing: 20% Percent of Trades The dark isn’t as scary as you think There are two misconceptions about dark trading. First is that it’s all done in dark ATSs. Second is that it mostly happens at the touch. Data shows that both beliefs appear to be wrong (Exhibit 5). In fact, we find that, by value traded: 15% 10% 5% Ask 80 - 90% of spread 70 - 80% of spread 60 - 70% of spread Mid 50 - 60% of spread 90 - 100% of spread Trade Reporting Facility (TRF) at the touch. 40 - 50% of spread • Only one-third of all “dark prints” are shown to have executed on the 30 - 40% of spread • But only one-third of those occur at the mid; 20 - 30% of spread • Two-thirds of all “dark prints1” occur inside the NBBO; 10 - 20% of spread 0 Bid • Around half of these are on exchange; 0 - 10% of spread • On average, stocks see around 42% of trades inside the spread; Source: KCG Data Good news: Wider spreads should increase depth Wider spreads should increase the depth of the NBBO, but by exactly how much is difficult to estimate. Consolidation of multiple price levels would triple depth. At a minimum, we should expect that the all the volume currently quoted inside the 5-cent spreads should consolidate at the new (wider) NBBO. Based on current book depth (see Exhibit 6) this should almost triple the depth of book in impacted names. However, if this is all that happens, investors will be worse off. Traders who sweep the book now get the same liquidity at cheaper prices thanks to stock that is displayed inside the 5-cent spread. Latent liquidity may now be posted There is a lot of “hidden” volume in today’s market. As each offer is lifted, volume backfills, often at the same price. 1 Here we define “dark prints” as all exchange prints inside the NBBO plus all prints on the Trade Reporting Facility. Note that this excludes reserve and hidden order types on exchange at the NBBO, which are also on-exchange dark executions. KCG | MARKET MICROSTRUCTURE 7 Who Gets the Short End of the ‘Tick? As spread capture is more important to performance, posting at the near-touch may become more common. exhibit 6: Wider spreads should at least consolidate the lit book out five levels. Longer queues could draw out liquidity 500 As more volume posts at the touch, queue priority becomes more important—as the time between posting and executing an order increases. Smarter algorithms and low-latency infrastructure will 400 be needed to accelerate order submission in order to keep up Average Shares with target participation rates. This should add even more liquidity to the NBBO. Market makers should be tempted to size up Market makers try to capture the spread by trading at both the bid 300 200 and the offer. But when a stock gaps up (or down) it causes a loss, which can trigger stop-loss trading. For example, in Exhibit 7 the NBBO for the 1-cent spread (orange) gaps 100 outside its range much more frequently than a 5-cent spread (blue). the market maker to get to the top of the queue. This may reduce the ASK 5 ASK 4 ASK 3 ASK 2 BID 1 BID 2 ASK 1 However, deeper NBBO has the perverse effect of making it harder for BID 3 0 BID 5 spread capture to stop-loss trades. BID 4 The wider spreads make the NBBO less volatile, improving the ratio of Source: KCG Data number of trades they get to do if they only post small size. This could then tempt them to increase their own size. exhibit 7: Wider spreads should mean more consecutive trades happen at each NBBO level. $100.15 $100.10 $100.05 $100.00 1-cent spread $99.95 5-cent spread $99.90 Fair price 10:00:35 AM 10:00:30 AM 10:00:25 AM 10:00:20 AM 10:00:15 AM 10:00:10 AM 10:00:05 AM 10:01:00 AM 10:00:55 AM 10:00:05 AM 10:00:45 AM 10:00:40 AM 10:00:35 AM 10:00:30 AM 10:00:25 AM 10:00:20 AM 10:00:15 AM 10:00:10 AM 10:00:05 AM 10:00:00 AM $99.85 Source: KCG Estimates KCG | MARKET MICROSTRUCTURE 8 Who Gets the Short End of the ‘Tick? Bad news: Market impact may also increase Although depth of book is likely to increase, there will be side effects exhibit 8: Costs are higher for wider spread stocks. that need to be weighed against the benefits of a deeper NBBO. Based on our comparisons of narrow- and wide-spread stocks in today’s Transaction costs will increase When we look at “similar” stock trades (Exhibit 8), we find that average shortfall is typically higher for stocks with wider spreads. $0.02 Average Shortfall market, we expect: $0.01 $0.00 This should be no surprise as a specific objective of increasing Narrow spreads is to increase profits for market makers. That will reduce returns for other participants. Wide Spreads Source: KCG Data Signaling and execution risk will increase Basket is normalized for market cap ($500m and $750m) trade size (consistent %ADV range), and volatility (extreme volatility excluded). As investors try to mitigate the increased costs of trading, their first Narrow spreads are below 30 bps. reaction will likely be to capture spread themselves. The problem with adverse selection longer. The extra wait at near-touch, or cost to cross 10 6 4 2 inside the spread (Exhibit 9). Ironically, an increase in dark trading is likely to lead some (including exchanges) to decry the detrimental impact this has on price discovery and market efficiency. 80% 1 70% current market. As spreads get wider (in bps), more trades happen 16 60% simultaneously is to trade in dark pools. This naturally occurs in our 26 50% The best way to reduce impact, signaling cost and execution risk 42 10% Dark trading will increase 68 Spread (bps) the spread, will also make it harder to match VWAP. 100 40% Longer queues also add to execution risk as orders are exposed to exhibit 9: Stocks with wider spreads trade much more often inside the spread (in both dark pools and exchange dark order types). 30% it signals your trade. 20% loading up the bid in order to get priority to capture the spread is that % Fills Inside Spread Source: KCG Data Dark trading percent (x-axis) represents the sum of all trades printed to the tape at prices inside the NBBO at the time. This includes exchange and TRF trades. No doubt this influenced the design of Pilots 2 and 3, both of which should impede this natural optimization of trade strategy. KCG | MARKET MICROSTRUCTURE 9 Who Gets the Short End of the ‘Tick? Speed will be even more important As the NBBO gets deeper, capturing spread will take longer, as new exhibit 10: Book duration increases as spread increases. orders join the back of a bigger line (Exhibit 10). This will make speed some of the spread costs. Complexity will increase Different tick sizes for qualifying stocks will make the market more (not less) complex. The inclusion of three separate pilots with different routing and limit pricing rules exaggerates this in the short term. This seems contrary to one of the overarching concerns about market structure—that it has become too complex. Liquidity may decrease Because the spread is more expensive to cross and book duration is 200k Quote Turnover (seconds) even more important for market makers and for investors trying to save 50k 5k 500 50 10 2 1 1 3 5 10 25 50 100 200 400 1000 Spread (bps) Source: KCG Data Book duration measures the time (in seconds) for the average NBBO depth to clear, based on the ADV of the stock. Color represents market cap—small-cap (blue) stocks typically have wider spreads and slower quote turnover. likely to be longer, we think total volume traded is most likely to go down. Wider spreads may make block market making more profitable, but it’s likely to reduce the ability of electronic market makers to plug transitory differences in supply and demand for these stocks. For questions or further information on this report, please contact Phil Mackintosh at [email protected] or 201.963.2724. KCG | MARKET MICROSTRUCTURE 10 Who Gets the Short End of the ‘Tick? 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