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Bottom line is that the regulatory changes were implemented by bureaucrats who are lacking real world experience of sitting on a trading desk and understanding how the engine works from the bottom up. And in my opinion were implemented to punish Wall ST first, THEN try to protect the system but instead is now hampering the broad economy and increasing tail risk for all.

Regardless of how good the intentions were of Dodd Frank, Volker, Basel III etc, the result is that all market makers in all asset classes now have less capital to deploy, and the profitability no longer warrants the normal trading risks, which will intensify sell offs during spikes in volatility and greatly increases the risk of shocks worse than 2008. It also explains why Ben Bernanke says he was rejected for his personal mortgage refinance a few weeks ago. Lending simply isn't worth the risk in this regulatory environment as banks are being forced to hoard capital.

We spent 20mins during the Marquette / Seer meeting on this subject with both sides agreeing that hedge funds and PE firms are the only ones who can fill that void now, and they're going to clean up as a result why the economy limps along. Meanwhile the too big to fail banks have the largest market share of all time so the system is riskier than ever.


> On Nov 19, 2014, at 5:23 PM, Chuck Harple <chuck@mmathisgroup.com> wrote:
>
> Dan
>
> Thank you for the heads up.
>
> Also, Capitol Hill has talked about this in a number of committees. I know of this because of work on pension legislation and the "health of the PBGC!"
>
> Honestly, because the strength was in the senate for the Democrats, they missed an opportunity to address this or for that matter anything on issues of such magnitude.
>
> I truly believe that this will be addressed in the new congress. I just hope other stuff is not attached to it that will cause the administration to veto such legislation. I would like to talk to you more about this. But in my opinion the next two years will be a boom for Wall Street, which is good for us. No one standing in their way. I am attending a meeting with Schumer and will address.
>
> Be well.
>
> Chuck Harple
> The Mathis Harple Group
> 923 15th Street, NW
> Washington, DC 20005
> 202-662-9700 office
> 202-957-0042 cell
> chuck@mmathisgroup.com
>
>
> Please pardon any typos. Sent by iPhone.
>
>> On Nov 19, 2014, at 3:54 PM, Daniel McHale <dmchale01@gmail.com> wrote:
>>
>> …This is a very interesting read from Bloomberg that came out yesterday that highlights how electronic trading, coupled with unintended consequences of new banking regulations and capital requirements, are causing shockwaves to the Treasury market. I have a close friend who works on the US Treasuries sales deck at Deutsch Bank, and he has been talking about this canary in the coal mine for a while. Considering every consumer and commercial loan is tied to Treasuries and/or Libor, it's worth the quick read.
>>
>> Flash Boys Invade Treasury Bond Market In New Era Of Volatility
>> Nov 18 2014 | 6:50am ET
>> By Susanne Walker and Lisa Abramowicz (Bloomberg) -- In a flash, the bond market went wild.
>> What began on Oct. 15 as another sleepy day in the U.S. Treasury market suddenly turned into the biggest jump in volatility in a quarter century, leaving investors worrying there will be turbulence ahead.
>> The episode exposed a collision of powerful forces -- the rise of high-frequency trading and the decline of Wall Street dealers -- that are reshaping the world’s biggest and most important bond market. Money managers say the $12.4 trillion Treasury market is becoming less liquid, meaning securities can no longer be traded as quickly and easily as they used to be, thanks in part to the Federal Reserve’s bond-buying program.
>> “The way the market is set up right now, we’ll see instances like we did on that day,” said Michael Lorizio, senior trader at Boston-based Manulife Asset Management US LLC, which oversees $281 billion. “There’s going to be a learning curve as to how to handle that.”
>> The development reflects unintended consequences of new financial regulation, as well as steps the Fed has taken to breath life into the U.S. economy. The implications, however, extend far beyond Wall Street, because the Treasury market determines borrowing costs for governments, companies and consumers around the world.
>> When the day began on Oct. 15, an unprecedented number of investors were betting that interest rates would rise and U.S. government debt would lose value. The news that morning seemed ominous. Ebola was spreading. So was war in the Middle East. At 8:30 a.m. in Washington, the Commerce Department announced a decline in retail sales.
>> Buy Quickly
>> The shift came all at once. The sentiment that the Fed would raise rates reversed. Traders who’d bet against, or shorted, Treasury bonds had to buy as many as they could as quickly as they could to limit their losses. By 9:38 a.m., 10- year Treasury yields plunged 0.34 percentage point, the most in five years.
>> Analysts such as Jim Bianco, president of Bianco Research LLC in Chicago, blame the herd mentality of electronic traders.
>> “A lot of these guys are focused on speed,” Bianco said. “They’re all uncreative and write the same program. When the stimulus comes in a certain way, every one of them comes to the same conclusion at exactly the same moment.”
>> The influence of high-frequency traders in the Treasury market is growing. About 60 percent of Treasury securities trades are expected to be transacted on electronic platforms by the end of next year, an increase from 40 percent in 2013, according to Tabb Group LLC, a New York-based research firm. Of those trades, 10 percent were executed by robots in 2010, a share that will probably grow to 20 percent next year, according to Tabb.
>> More Volatile
>> “As the markets become more electronic, they become more volatile,” said Larry Tabb, Tabb’s chief executive officer. “It’s the new normal.”
>> At least one electronic trader, Charles Comiskey, the head Treasury dealer at Bank of Nova Scotia, said he unplugged his computer for half an hour during the height of the frenzy. That may help explain why yields plummeted so fast without sellers to stem the fall.
>> It may also explain why an unprecedented $946 billion of U.S. government debt ended up changing hands on ICAP’s BrokerTec trading platform on Oct. 15, breaking the record by 43 percent. Once sellers stepped in and the plunge was arrested, there was plenty of liquidity.
>> Bloomberg LP, the parent company of Bloomberg News, competes with BrokerTec and other bond-trading platforms.
>> Cash Reserve
>> New rules adopted after the 2008 credit crunch are also part of the new normal. Global guidelines called Basel III, instituted by the Bank for International Settlements in Basel, Switzerland, require banks to hold more cash in reserve for assets such as bonds they keep on their balance sheets.
>> Partly in compliance with the regulations, the 22 primary dealers authorized to trade directly with the Fed reduced their U.S. government debt holdings to $46.3 billion at the end of October from a record high $146 billion in October 2013, Fed data show. While they still hold inventory, they’re allocating less to opportunistically buying big clumps of bonds and then slowly selling them, a process known as market-making.
>> Hedge funds have filled the vacuum created by the retreat of the big banks. On the morning of Oct. 15, the turmoil in Treasuries echoed in the trading of junk bonds. As $8 billion was being wiped out in that global market, Toronto hedge-fund manager Philip Mesman fielded e-mails from U.S. bankers clamoring for him to buy their customers’ holdings.
>> Shock Absorber
>> Investors were unloading the debt of the riskiest companies, forcing exchange-traded funds and mutual funds to sell. Before Basel III and the Volcker Rule, which limits the ability of U.S. banks to trade on their own accounts, dealers would’ve bought the bonds themselves and held them until finding someone to take them. Instead they were forwarding the “sell” messages to firms they knew had quick access to cash.
>> “In the old days, the dealers could carry inventory and it acted like a shock absorber,” said David Breazzano, who manages $8.2 billion in high-yield bonds and loans as Waltham, Massachusetts-based DDJ Capital Management LLC’s chief investment officer. New regulations create “opportunities for other institutions to fill the gap,” he said.
>> One result is a narrowing of the market. Average daily turnover in the U.S. bond market shrank to $809 billion last year from $1.04 trillion in 2008, according to Securities Industry & Financial Markets Association data.
>> The Fed has bought so many bonds -- $3.5 trillion worth since 2008, including $1.86 trillion of Treasuries -- that big individual trades matter more now. The amount of U.S. debt available to trade at one time without moving prices as of October has plunged 48 percent to $150 million since April, according to JPMorgan Chase & Co.
>> Possible Drivers
>> That phenomenon hasn’t been confined to the U.S. The size of German bund futures that can go through the market at one time without moving the price has fallen 46 percent to 784 contracts as of Oct. 17, from this year’s peak of 1,450 contracts in April, according to JPMorgan. The average over the past four years was 920 contracts.
>> Regulators are searching for an explanation. The Federal Reserve Bank of New York’s Treasury Market Practices Group, a gathering of finance executives and New York Fed officials, met Oct. 16. It identified “possible drivers” of what happened as changes in the direction of trades by investors with a lot of borrowed money -- “repositioning by leveraged investors” is how they put it -- algorithm-driven robot traders and the regulatory restrictions that limit the participation of big banks, according to minutes of the meeting.
>> “Members concluded that more time would be needed to fully understand the day’s events,” the minutes said.
>> Liquidity Break
>> Timothy Massad, chairman of the Commodity Futures Trading Commission, which oversees the Treasury futures market, told reporters in Chicago Nov. 5 that his agency “took a look at” the price fluctuations of Oct. 15.
>> “Basically we didn’t see any break in liquidity,” Massad said. “I think it was just a high volume day. But let me just add that’s based on our preliminary look. New evidence might come to our attention that suggests otherwise.”
>> CME Group Inc., the Chicago-based derivatives exchange, saw record trading that day with 39.6 million contracts changing hands, including all-time highs for interest-rate futures and options at 25.1 million.
>> Terrence Duffy, CME’s executive chairman, said one of the most active days in the history of futures trading went off without a hitch.
>> Market Turbulence
>> “The systems were really rocking and rolling,” he said in a Nov. 6 interview in his office. “All of a sudden we saw a tremendous amount of volatility enter the marketplace at once.”
>> The U.S. Securities and Exchange Commission is pushing mutual funds to test whether they could satisfy customer redemptions during periods of financial stress, said people with knowledge of the plans.
>> The Treasury Department heard concerns about high-frequency firms in fixed-income at a November 2013 meeting of the Treasury Borrowing Advisory Committee, a group of executives who represent banks and investment funds.
>> Members “suggested that the liquidity provided in the market through electronic trading was small on a relative basis and unlikely to persist during periods of market turbulence,” according to the minutes of the meeting.
>> In certain markets, “there’s a facade of liquidity,” said Jon Duensing, a money manager at Amundi Smith Breeden, the U.S. unit of the French asset-manager Amundi that oversees about $1 trillion. “It’s possible that the mechanisms that investors thought were in place to facilitate capital flow may break down.”
>> --With assistance from Matthew Leising, Matthew Boesler and Alexandra Harris in New York, Cecile Gutscher and Ari Altstedter in Toronto, Anchalee Worrachate in London and Silla Brush and Dave Michaels in Washington.
>> Copyright 2014 Bloomberg. All rights reserved. This material may not be published, broadcast, rewritten, or redistributed.
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