The WFE’s response focuses on drivers of the shift in liquidity and the role of bilateral trading in hollowing out intraday liquidity, even in the most liquid capital markets. In the face of that challenge, closing auctions respond to customer need.

We reject the idea that more volume at a given point in the day equals more operational risk. We note that size of potential loss is not the same as probability of the loss being crystallised, given that exchanges a) plan ahead for volume capacity and b) apply fundamental hygiene and containment practices to all forms of operational risk.