The Year of the Snake…and Trade Break

I’m not big on New Year resolutions or on predictions.  But in the case of Dodd-Frank and EMIR in Europe it’s hard to resist.  The die has been cast and SDRs are a real thing now.

Here Come the Trade Breaks

Here Come the Trade Breaks

Setting aside for the moment the master strokes about what DF and EMIR are supposed to be about, let’s talk for a moment about the hands on, down in the trenches  effect of what these rules are actually causing.

A trade clean up of epic proportion.

It sounds like a great and practical idea.  Perhaps an idea that many firms agree have been put off too long.  But there is a problem.  A big one actually…this is the commodities business.

In the commodities business we have legacy systems.  No I don’t mean just in-house built systems.  I mean vendor systems that were architected in the 80′s and 90s.   Lots of them out there, sold as new, patina upon patina, with the same fundamental architecture they started with.  I was working with a vendor system at a client.  One of our younger developers was pulling his hair out asking why, why did they do this?!   The answer unfortunately is the same as the reasoning for popped collars and hair gel in the 80s.  “It was the thing at the time.”

Immediately on everyone’s plate is how to get trades out of these old architectures and get them properly into the SDRs.  This turns out to be, at best, like data gymnastics.  At worst mad contortion.  If the data is a spaghetti-works to begin with the probability of a trade break goes through the roof.  Surveying the dozen or so systems we have connected to the SDRs better than 3/4 of those have a significant amount of transactions that have been “shoehorned” into the system.  This is a recipe for a trade break downstream with ICE/DTCC/CME or whatever SDR has been chosen.  These systems are somewhat unforgiving, and as a result unless they come across perfect they bounce.

Forget the Year of the Snake.  This is the year of the Trade Break.

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Dodd Frank | CFTC – Black Swan No Action

The CFTC issued some breaks by laying out a series of Dodd Frank “No-Action” letters. The biggies:

CFTC issued a No-Action letter to prevent firms from crossing into Swaps Dealer status.  The rule states that any firm doing more than $25 Million in business with “Special Entities” such as a Federal, State or Local utility is classified as a Swaps Dealer.   The CFTC raised this level by 3200% to $800 Million.  Yep. Black Swan.  They really do exist.

We’ve already seen the problems that this rule had created.  Liquidity for public utilities has evaporated because private utility XYZ and Merchant ABC don’t want to do business with them any more to prevent becoming a Swaps Dealer.

Transition from swaps to futures No-Action.  As everyone is aware ICE rolled its swaps over to futures last weekend.  Exactly when everyone (not a bank) is in the midst of sorting out whether they are Swaps Dealers or not.  And, just when you think you have come up with your final number…poof… all your ICE trades are now futures and excluded from the calculation.  Now under the No-Action letter everyone has until end of year to figure it out.

Yet to get No-Action status: Physical Transport and Storage.  This is kind of a curve ball in my opinion.  For example, is a natural gas transport contract a physical

What Am I !????

deal?  Is it a physical deal with embedded optionality?  Or is it just a financial deal?  If it’s a physical deal then where are the molecules?  If it’s a physical deal with embedded optionality, then what part is physical and what part is option?  If it is a financial deal…well, I hate to be the bearer of bad news, but lots of companies represent the value of their transport as spreads or spread options.

I would argue this:  It could be any of the above and a No-Action is appropriate to give the CFTC the time to figure it all out.

Here’s a link to the CFTC No-Action letters:

http://www.cftc.gov/LawRegulation/CFTCStaffLetters/No-ActionLetters/index.htm

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Disaster at Knight: Only One Thing Could Have Gone Wrong

They botched the Software Quality Assurance (QA)…stating the obvious…Res Ipsa Loquitur…(It speaks for itself).  But the $400 million dollar question is HOW they botched the application QA.

This is not the first time in my career I have seen this.  It is the third.

The first time was a UK company in the newly formed UK power market.  Big vendor developers had botched the (manual) bidding code such that it posted bids as asks and vice versa.  $80 million down the drain before they found the error. 

The second was a hedge fund that had botched the automated booking process in their ETRM system causing the portfolio to be mis-hedged.

First some background on QA steps.

COMPILE

After code is written, it is compiled.  In a way compiling code is a form of testing.  If the code compiles, it means there are no obvious errors in the code that prevent it from running.  But running is different than working as intended.  The dirty secret of software development is a testing manifesto of, “if it compiles it ships.”  Do software updates come to you where the application starts and runs fine, but then interacting with it throws errors?  You’ve got a team adhering to, “if it compiles it ships.”

There are many types of testing, but without getting into semantic games, here’s a simple breakdown.

UNIT TESTING

Unit testing is the lowest level of code testing.  It is written by programmers and focuses on independently testing the smallest units of code.  Once unit tests are fully in-place, they can be run anytime code is added or modified to ensure that existing functionality has not been affected.  This allows complex systems to be dynamic and still stable.  What unit testing does not do it test how various units function together.

FUNCTIONAL TESTING

Once each individual unit of code works as intended, the full code base need to be tested together.  In other words, does the whole application function as intended.  The scope of such testing is captured in ‘Test Scripts’ which describe a set of discrete system actions with data inputs that produce a set of expected results.  In other words, I type my ID and password and click ‘Login’ with an expected result of logging in successfully.  These can be run manually or even automated with software tools since they are the same actions/results each time.

This phase of testing is really only as good as the testers or the person who automated the scripts.  I had a buddy running development and the testing consultants (who seemed to come out of a yellow bus with backpacks) said the testing had failed.   The test script said “Enter a pipeline company” in XYZ field.   They failed it because there was no company called “A Pipeline Company” in the drop down.  I wish I was kidding.

UAT

Finally, the last step is User Acceptance Testing or UAT.  This is where the users, those who use the application on a day to day basis, actually test the application for themselves.  In addition to testing their day-to-day activities (which may be just running through test scripts) they should also conduct what I like to call ‘monkey testing’.  In other words, beat on the system like a monkey and try and break the darn thing.  This is an important catch-all phase however it’s always tough because getting time from the actual users is a challenge.  But at the end of the day they have to put their name on it.

Where’d Knight Go Wrong?

If you have to point a finger, UAT is the place where blame is assigned.  As a publicly traded company there are some Sarbanes-Oxley implications to not running through test scripts.  One project we were on for a large enterprise application, the test scripts had to be put in paper form for SOX and they literally filled a 10×12 room.

I don’t know if offshore resources were involved.  In recent years there has been a large push to do testing offshore.  But my experience is that coordinating testing in a remote location adds another level of complexity to the mix.  For running test scripts in a far-away land, you are literally banking that a remote person whom you’ve never met knows the difference between a bid and ask, a put and a call, a long call versus a short put.  My experience is that this distance can foster a lack of accountability.  But most of all, do you know what it is like to get a trader to talk to the testing team at 9PM?  Brutal.

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POW! ICE Goes to the Future(s)

Last week   ICE announced that it is registering its products as Futures.

ICE has always traded “look alike” swaps that acted and behaved just like futures.  As look-alike contracts, ICE was able to stay out of the Commodity Exchange Act and the CFTC.   Dodd Frank changed all of that.  So ICE seems to have adopted a “join ‘em” attitude and decided to go head to head with CME.

Back to Futures!

It’s worth pointing out that there is still a HUGE incentive to trade bilaterally OTC.   If you are Exxon, the amount of collateral you have to put up for an OTC trade is minimal if not zero.  So why would you clear and post margin? Uncleared OTC is going to remain alive and kicking.  Sure, some trades will be mandated for clearing.  But for now those contracts are few and as new products come into scope they will be battled over furiously.

In this sense, ICE really has an edge.  ICE has a great OTC platform that will stay live;  an SDR that appears functional; and, a wide futures product mix.  CME may tout Clearport as the ultimate OTC clearing destination, but as many know, it’s just far, far harder to use than clearing on ICE.  I was talking to a broker who told me that ICE calls him every week to make sure everything is running smooth as silk.  CME?  No comment.

While I am pretty bullish on ICE with this move, it is not without some anticipated growing pains.  I think the worst pain is going to be in their pricing and margin groups.  Pricing was a revenue center for ICE.  So if you are anyone but a high volume trader, getting prices and margin cooperation has historically been a bit like a trip to the dentist (you pay for pain).  I think this is changing.  After all, its a federal requirement that futures settlement prices get published daily.

But these are trivialities.  For those trading on ICE, there is really not much impact.  Had ICE stayed with look-alikes, they would have had to send all these trades to Trade Vault as a DCO anyway.

 

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Architecture | Crouching Tiger, Hidden Trading System

I am not sure if this is a trend yet.  But it’s worth noting.  Over the past couple months I have talked with a total of three major energy trading entities that all have one thing in common: Projects to “hide” the ETRM system entirely from their traders.  Traders will not use, see, touch or smell the ETRM system of record.  Rather, they will see in-house developed, deal entry and position reporting that is fed by the ETRM system.

So there you go.  Why?  Well, the rationale is pretty straightforward.  ETRMs can be too noisy for Traders.  The trading systems are too hard to configure.  Too hard to get the information they really want.  It is as it always has been.

I’m going to chalk this up to a generalized “Ux” failure.   Ux is short for User Design and something that has been badly neglected in the ETRM space.  Remember that BlackBerry you used to have?  Or, that one you are suffering with now?  Ok, now think of the Apple iPhone.  The difference?  User Design, of course.  Steve Jobs was fanatical about Ux.   BlackBerry does one thing great….email.  That’s it.  Browse, App Store,App functionality…all garbage.  It is not that BlackBerry does not do these things.  It’s that it does these things with poor Ux.  And we hate them for it.

Some suggestions for Ux.

Never Let the Users Design User Design.  Remember that Simpsons where Homer designed a car called the Homer?  User driven, user design nearly always results in “a Homer,” and I don’t mean a home run.  But the users know exactly what they want, right?  Yes, but put those people with a Ux pro to drive out the requirements.  You will end up with something that is functional and easy to use, rather than functional and a pain in the neck.

Never Let Developers do User Design.  Writing code and designing GUIs is not the same thing.  A good developer will nearly always admit that they hate designing GUIs.  Just don’t let them do it.  Every time I see pop-up window after pop-up window, I know that a developer designed the GUI.

Watch For Developer vs. Ux Conflict. If you use a User Design pro there will inevitably be a conflict between the developer and the User Design Pro.  The User Design Pro should win.  The truth is that Ux Pro’s make the developer’s life harder.  Doing cool things with the GUI takes more development effort and one should expect the developers to push back.

So, what about these efforts to hide the ETRM system?  Well, unless the in-house development efforts really put their mind to Ux, there is a better than average chance that they will end up with a poor re-creation of what they had in the first place.

 

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Regulatory | Trick Bites Back!

One of our gripes with trading systems is that sometimes they just can’t properly book certain trade types.  Yes, there really are trading systems out there that can’t book Futures.  Yes, there really are systems out there that can’t book spread trades, options and an assortment of exchange products upon which traders have already pulled the trigger.
What do we do if our trading system can’t trade futures?  No problem, we just “trick” the system and book it as a swap. You know, the old “work around.”  Sometimes this turns out OK.  With a little push here and a rub there the P&L

Enjoying work arounds?

all turns out fine.  Fine that is, until someone needs to run a report specific to futures.

Like a Dodd Frank report?  Why yes!

To begin with, if you are in the know, then you know that not only is system tricking done…it’s done a lot.   Every trading company has some work around here or there.   So, remember those futures we couldn’t book as futures so we booked them as swaps?  Looks like Dodd Frank requires us to report our futures as …well …futures.  So now we are going to have to go through every one and figure out which swaps are actually futures and compile them into a report.

This got us thinking that clients will need all trades reported to the CFTC exactly as executed on the exchange.  But as we dug deeper we realized that there is not chance it would be so simple.

Turns out it looks like CFTC can’t book spread trades (as spread trades) either. So that trick we did on spread trades, booking them as swap legs.  Yep, the CFTC wants them that way too.  They don’t want the aggregated spread, just the underlying legs.  Those stellar ETRM systems that have gone the distance and actually book spreads as spreads?  You’re out of luck.  We have to decouple these into their respective swap legs.

Our only suggestion is that if you are holding out on how to do regulatory reporting, it’s a good time to get the ball rolling because there are going to be a lot of twists and turns in this plot.

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