What Seems Like More Red Tape Can Be a MARvelous Opportunity

头条新闻是扑扣和恐慌的。出版物和博客的故事是，如果您在欧洲交易，您应该害怕市场滥用监管。非常害怕。

The EU’s Market Abuse Regulation, “along with its sibling, the Market Abuse Directive, pose a对全球市场参与者的双重威胁,” claims one commentator.

市场虐待规则，设定为生效的星期天 - 包括在U.K.，包括在内Brexit投票尽管如此 - 超越市场滥用指令。它在欧洲证券交易所和市场操纵上监测的赌注，在多边贸易设施中的政府控制时代的欧洲证券交易所和迎来性。我们在Onemarketdata认为，参与者应该感觉不像发烧的头条新闻表达的那样令人惊慌失措，而是将其视为竞争机会。

MAR截止日期的即时性和规则的广度和规定性是兴奋的是，作为市场制造商之间的压力来源。欧洲市场透明度规例的并行浪潮 -mifid II，mifir，bcbs 239，埃米尔，汇款等 - 对于某些人来说是一种溺水的感觉。然而，对于那些可以回来看看大局的人来说，新的透明度和监测规则的筏子会产生超过成本的竞争机会。

First, let’s look at the imminent MAR deadline. As deadlines go, it’s a fuzzy one. Some bits of MAR won’t come into force until the Markets in Financial Instruments Directive II definitions on which they depend are finalized, in January 2017, and those may vary by jurisdiction. As the Financial Conduct Authority said on the heels of the Brexit vote, “Regulation [derived from EU legislation] will remain applicable until changes are made.”

Market participants are struggling with fundamental interpretation questions. The European Securities and Markets Authority had to release an updated Q&A in May to clarify that the rules do apply to buy-side firms. At recent conferences, firms debated provisions related to inside information, market soundings and the interpretation of Accepted Market Practices. A伦敦律师事务所的伦敦LinkLaters调查, released on June 21, concluded that fewer than 5 percent of firms are “completely ready.” All this means is that the July 3 deadline is the start of a chapter, not the end of the story.

So, don’t panic. Take a deep breath, and focus on the most essential steps, one at a time.

Step 1: Make sure you are collecting the data you’ll need.I was surprised to discover that many asset managers in Europe don’t collect their own trade data. For MAR, as for MiFID II, you’ll need a record of every transaction, order, cancel and correction. You’ll need to join all of that with market data — but it is always possible to obtain market data later. You’ll be able to add the tools to answer the regulatory questions later too.

第2步：避免熊陷阱。是的，买入 - 一切和调和陷阱. On a recent visit to London, the trading head of a small broker-dealer told me that he had purchased MAR-related software and now needed historical market data for it. He lamented that he would next have to buy similar products for best execution and trade reconstruction, as well as add resources to reconcile between the proprietary databases and symbologies they used. He did not care that the U.S. office of his firm already had strategies for best execution and compliance in place. “Different regime,” he said. Yet regulatory convergence, which crosses the Atlantic, means that the data you need and the questions to be asked of those data are almost the same.

他认为这是一种自上而下的方法。但他已经陷入了熊陷阱 - 看到每个监管的陷阱是需要一个独立解决方案的一次性问题，这在事实之后必须协调。

Some coolheaded firms have tackled the same problems bottom-up, by deploying a time-series database and a streaming-analytics engine capable of storing the transactions as they arrive on the wire, then joining the collected history to other data sources. They mutualize market data collection costs through a cloud-based on-demand market data vendor. With these in place, the requirements imposed by MAR and MiFID II’s best execution, as well as by algorithm performance metrics and trade reconstruction, can often be addressed by simple queries over the collected data, either historically or live. With a single gold copy of the data, there’s no reconciliation to do.

第3步：利用一个奇妙的机会。What at first looks like a series of unconnected regulatory problems actually gives way to a systematic, cost-effective strategy that kills several birds with one stone. It can do more than save money by avoiding the BEAR trap. The same transaction store and time-series database that complies with MAR can answer questions that save trading costs, enhance commission revenue and produce robust forecasting models. For those with cool heads, a coherent, data-first approach can create revenue opportunities and enhance return on investment in a way that is competitively meaningful.

Dermot Harriss是高级副总裁OneMarketData, a fintech firm headquartered in Hoboken, New Jersey.

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