WFE response to IOSCO consultation on market structure

Author Name: 
WFE

Executive Summary

The World Federation of Exchanges (WFE) commends IOSCO for carefully analyzing the issues raised by the growing and disruptive fragmentation and loss of visibility (darkness) in equity markets.  The four sensible recommendations in this consultation progress efforts on the part of regulators and exchange operators worldwide to ensure that equity markets continue to serve investors by becoming ever more efficient, transparent and fair. 

The WFE supports competition and believes that regulators must promote market designs that foster order interaction in a free, transparent and fair competitive environment. Unfortunately, regulations intended to promote competition between and on-exchanges have in recent years been misused to enable the growth of venues designed to avoid competition.

The WFE is concerned about the integrity and efficiency of fragmented, complex and dark markets, particularly as it relates to price formation, surveillance, and market resiliency. Market participants are increasingly discouraged from posting competing prices in lit venues, and evidence indicates that spreads are wider than they could be otherwise. Similarly, diminishing transparency and fair access leads to market complexity that makes markets less capable of handling volatility. Finally, the WFE is concerned that a greater share of equities trading occurs away from full regulatory protection offered by regulated exchanges.

The WFE calls into question two common practices in fragmented markets. First, retail and institutional orders are systematically segmented toward venues designed to avoid quote competition, where conflicts of interest are unavoidable. Second, fragmented markets increasingly allow participants to step in front of displayed public limit orders on dark venues with little to no price improvement or block trading. The incentive to segment markets and reduce transparency jeopardizes the price discovery process and can adversely impact costs for all investors. .

The WFE calls attention to the problems that investors and security commissions face in receiving reliable data from over-the-counter (OTC) equity trading venues. While the WFE believes that the quality of data, and the costs associated with aggregating data should be weighed when changes to market structure are considered, consistent transparency regulations across venues is fundamental to efficient trading and market surveillance.

The WFE supports recent changes made by the security commissions of Canada and Australia in curbing the excesses of OTC equity trading. 

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