The Securities Industry and Financial Market Association (SIFMA) published its recommendations for changes to the US cash equities market structure that promises enough pain for broker-dealers as well as exchanges and alternative trading system operators.
Since reporting on it earlier this week, I am still trying to wrap my brain around the impact SIFMA’s proposed changes would have if the market adopts them.
Besides implementing kill switches, expanding the reporting requirements to the Financial Industry Reporting Authority and reducing/eliminating maker-taker fees, SIFMA recommends that the securities information processors (SIPs), the organizations that gathers all of the market data for NYSE- and Nasdaq-listed stocks from each exchange and reporting facility and aggregates it into consolidated feeds, should first update their data processing infrastructures “so that the SIPs provide the fastest commercially available services for data aggregation and distribution.”
After the SIPs make the necessary upgrades, SIFMA suggest throwing all of it out- baby, bathwater and all- in favor of having it replaced by competitive vendors, which would replace the SIPs with their own aggregated offerings. It would be similar to how the US Securities and Exchange Commission (SEC) retired the out-date Intermarket Trading System (ITS) in favor of private direct links between exchanges as part of its 2005 Regulation NMS market reforms.
Besides being an industry owned and operated market utility, that is where the similarities between the roles of the ITS and SIPs end. The ITS was a network, whose function easily could be replaced with another network provider. The SIPs are not just making an aggregated market data feed. They are making THE aggregated market data feed. You know, the one to which the regulators always refer.
Take that away then what will take its place?
Aggregating market data is not a clean business. It needs to be scrubbed and have any data outliers addressed. It is not possible for two market data aggregators to deliver feeds that are completely consistent tick by tick, much less half a dozen of them.
This is not to say that the SIPs have implemented the perfect method to aggregate market data feeds. They have not, but at least they are industry owned and not operated as for-profit businesses, which makes them perfect as the objective record for the market.
Any other arrangement would open up a regulatory can of worms.