May 26, 2013

How HFT Provide Liquidity to the Market

How HFT provide liquidity to the market or not.

R T Leuchtkafer’s letter to the SEC 
Imagine a stock under stress from sellers such was the case in the fall of 2008. There is a sell imbalance unfolding over some period of time. Any HFT market making firm is being hit repeatedly and ends up long the stock and wants to readjust its position. The firm times its entrance into the market as an aggressive seller and then cancels its bid and starts selling its inventory, exacerbating the stock's decline. Unrestrained by affirmative responsibilities, the firm adjusts its risk model to rebalance as often as it wants and can easily dump its inventory into an already declining market. A HFT market making firm can easily demand as much or more liquidity throughout the day than it supplies. Crucially, its liquidity supply is generally spread over time during the trading day but its liquidity demands are highly concentrated to when its risk models tell it to rebalance. Unfortunately regulators do not know what these risk models are. So in exchange for the short-term liquidity HFT firms provide, and provide only when they are in equilibrium (however they define it), the public pays the price of the volatility they create and the illiquidity they cause while they rebalance. For these firms to say they add liquidity and beg to be left alone because of the good they do is chutzpah.

The SEC should define both "momentum ignition" and "order anticipation" strategies as manipulation since they are both manipulative under any plain meaning of the Exchange Act. These strategies identify and take advantage of natural interest for a trader's own profit or stimulate artificial professional interest, also for the trader's own profit. They do so by bidding in front of (raising the price) or offering in front of (depressing the price) slower participants they believe are already in the market or that they can induce into the market. They both depend on causing short term price volatility either to prey on lagging natural interest or on induced professional interest. Any reasonable definition of "manipulation" in the equity markets should explicitly ban them by name.

Tags: high frequency traders and market liquidity