The new exchange will bring IEX’s suite of order protection innovations to better meet the demands of market makers.

“We are focused on understanding the challenges of our members and having discussions with market participants to guide our entry into the options market,” said Bryan Harkins, president at IEX.

“IEX’s experience and expertise in understanding the needs of liquidity providers provides a great foundation as we begin to offer options market makers a set of tools designed to drive performance.”

The proposed options exchange will be an electronic venue, offering access to the full multi-listed options market while relying on a pro-rata model.

The development will be the first time that IEX’s proprietary solutions for risk management and markout optimisation will be available for US options trading, building on top of its equities offering.

“IEX spent the last decade innovating to build technology that is designed to protect liquidity providers, and we have now added a team of leaders with deep multi-asset expertise that can help guide IEX through our next stage of growth,” said Brad Katsuyama, founder and chief executive at IEX. 

“We have been encouraged by the conversations this team has had with market makers about moving into the options market which underscores the opportunity for us to deepen our relationships with clients and to further improve execution quality in US markets by expanding into options.”

The launch follows IEX’s announcement of several key leadership appointments earlier this year, including the addition of Harkins as president and John Palmer to lead the firm’s efforts in building out its offerings and technology to serve new markets.

Palmer will serve as head of options and lead the new exchange. He will continue reporting to Harkins, who will oversee both IEX’s equities exchange and the new options exchange.

IEX has also appointed Ivan Brown, who will play a key role in the firm’s plans to bring a highly differentiated trading venue to the options market. Brown will lead business development and product design for the new options exchange. 

He joins IEX after 15 years in financial markets leadership positions at the New York Stock Exchange (NYSE), most recently having served as head of options and business development.

“Bryan, John, and Ivan are proven operators who have built successful trading platforms across asset classes,” asserted Ronan Ryan, co-founder and chief operating officer at IEX. 

“We are committed to bringing together the best people in the trading industry to disrupt the status quo in options trading with a unique market architecture, highly differentiated products, and deep commitment to client relationships.”

IEX stated that it plans to work closely with options industry participants to address the unique risk management-related challenges that currently exist in the options market, adding that it will require minimal effort for current members of its equities exchange to be onboarded to this new venue.

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According to the exchange, The Signal is designed to predict imminent changes to the National Best Bid/Offer (NBBO) and allow order types including D-Peg and P-Peg to react positively to unstable market conditions.

IEX and co-founder Brad Katsuyama have claimed to champion better protection for investors from adverse price selection since the inception of the exchange in 2013. This included the introduction of a discretionary limit order (D-Limit order), acting as a speed bump mechanism, allowing investors to buy or sell a security at a specified price or better.

The latest version of The Signal brings a new level of performance for pegged orders on IEX Exchange.

Enhancements to the model include looking at both size and number of venues, as opposed to just venues; the addition of three new venues (MEMX, MIAX, Nasdaq PSX); and the shift from a logistic regression to a rules-based model.

In previous updates, the latest version of The Signal was pushed by IEX to all members at once. However, with this latest version, members are invited to opt in and make the change at their preferred pace. The existing version will remain the default.

From 18 April, clients will be able to elect through a port request form to use the new Signal formula for all of their D-Peg, P-Peg, and C-Peg orders or can designate via a FIX tag to opt-in on a per-order basis.

The roll out of the new Signal version in this manner will enable members to transition from the current model to the new model for their pegged order types at their own pace, or stick to their current experience if preferred.

This will allow for live A/B testing of comparable models to occur in a way that was not possible in previous Signal updates.

“With market conditions changing rapidly, protection against adverse selection is more important than ever,” said IEX.  

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Best Challenger Exchange is a new category for Leaders in Trading this year, in which we recognise not only the ever-changing facets of the marketplace but also the plethora of new venues springing up to accommodate them.

Unsurprisingly, given the themes of 2022, digital assets did a lot of the heavy lifting in this year’s shortlist – but it’s not all about crypto, with US-based players such as MEMX driving themes of equality and investor power, while IEX is of course well-known for its stance on high frequency trading. Our shortlist this year includes Archax, FTX, Investors Exchange (IEX), Members Exchange (MEMX) and Miami International Securities Exchange (MIAX).

Archax 

A new institutional-grade exchange for trading crypto/digital assets founded in 2018, Archax is the first crypto firm to be regulated by the FCA. With a majority stake acquired by abrdn in August 2022, the trading venue is clawing its way into institutional inner circles, most recently through its new partnership with METACO to deploy its digital asset custody and orchestration technology on IBM Cloud, in order to leverage the confidential computing capabilities of IBM’s digital asset infrastructure.  

A digital asset exchange, brokerage and custodian based in London, Archax has big ambitions. “We see the digital asset market as a long-term investment opportunity, and at Archax we make investments in technology and processes to reflect that vision,” says CEO and co-founder Graham Rodford.  

But it is also expanding outwards from pure crypto trading into the wider world of what blockchain can offer. In September, the firm partnered with BondEvalue to deliver solutions for the trading of fractional fixed income products. The partnership will enable their clients to access investment opportunities on BondEvalue’s regulated platform, the BondbloX Bond Exchange (BBX), a blockchain-based bond exchange which allows investors to conduct electronic trading of fractional bonds. 

As a bridge between the traditional and DLT space, Archax is proving a worthy contender.  

FTX  

A cryptocurrency exchange built “by traders, for traders,” FTX Trading offers products including derivatives, options, volatility products and leveraged tokens. With a senior team comprising alumnis from Jane Street, Optiver, Susquehanna, Facebook and Google, among others, the exchange seeks to service everyone from both professional firms to first-time investors, with a platform that is both simple and sophisticated.  

At the start of 2022, FTX Trading won a further $400 million in Series C funding, taking its total valuation to $32 billion – not bad for a firm only founded in May 2019, with investors including Singapore’s Temasek and Paradigm. In March of this year, the exchange expanded its presence into Europe and the Middle East with the establishment of FTX Europe, marking the next phase of its global expansion. Headquartered in Switzerland with an additional regional headquarter in Cyprus, the new company offers its products and services to European clients via a licensed investment firm with passportable licenses across the European economic area. 

In the same month, the firm partnered with US-based crypto platform West Realm Shires Services to launch a new unit targeted at institutional investors – marking its commitment towards developing and supporting institutional involvement in crypto trading. FTX Access will initially provide institutional investors interested in gaining exposure to digital assets with trade execution, analytics, index products, advisory services  and capital introductions, with plans to expand into custody, derivatives, structured products and other asset management products later down the line. 

“Our goal is to provide services that make it easier for traders at all levels to invest in cryptocurrencies, while also meeting compliance and regulatory standards found in traditional finance,” said FTX CEO and co-founder Sam Bankman-Fried, speaking at the time.  

FTX also this year made a strategic investment into IEX Group, the operator of the US-based Investors’ Exchange, in order to develop a transparent market structure for the buying, selling and trading of digital asset securities.  The question of crypto regulation has long been a tricky one, and FTX US has been clear about its ambitions to become a regulated exchange, working with regulators to create a platform that enables both retail and institutional engagement with digital assets.   

Investor’s Exchange (IEX) 

A controversial name on the exchange landscape, IEX has created some waves in recent years, but there is no question of its influence. Founded in 2012 with the intention of mitigating the impact of high frequency trading, and listing in 2017, the exchange is familiar to many as the brainchild of ex-RBC traders Brad Katsuyama and Ronan Ryan, who came to believe that that traditional stock exchanges were enabling certain trading strategies that could harm long-term investors such as mutual funds and pension funds. Debuting as a dark pool in 2013 and the subject of Michael Lewis’ notorious book Flash Boys, the exchange has since built a name for itself through its mission to give all market participants a fair and efficient trading experience.  

It has developed a number of innovations including the IEX Speed Bump, designed to ensure that the exchange executes trades at the most up-to-date price, and the IEX Signal (i.e., Crumbling Quote Indicator or CQI), a machine learning-based signal that aims to protect investors from trading while prices are unstable. Since its inception, more than $8.5 trillion in shares traded on IEX Exchange have benefited from the IEX Signal. 

Members Exchange (MEMX) 

Claiming to be the fastest-growing US equities exchange, MEMX was founded by its own members to serve as a co-operative, collective exchange acting in the interests of its founders and their client base. Its founding members include many of the largest US retail broker-dealers, global banks, financial services firms and global market makers, such as Bank of America Merrill Lynch, Charles Schwab, Citadel Securities, E*TRADE, Fidelity Investments, Morgan Stanley, TD Ameritrade, UBS and Virtu Financial. The exchange’s mission is to “increase competition, improve operational transparency, reduce fixed costs, and simplify the execution of equity trading,” and it has grown rapidly since its launch in 2020, currently accounting for around 5% of equity market share.  

Its big development this year was the launch of its US options exchange, and in August the SEC issued approval for it to trade listed options. “MEMX Options will use technological advancements to increase determinism, reduce costs and drive competitive improvements for our options members, just as we did in equities,” said Jonathan Kellner, chief executive of MEMX.  

“As the only exchange founded to represent the needs of market participants, expanding into a new asset class allows us to provide meaningful benefits to an even broader range of investors.” 

Miami International Securities Exchange (MIAX) 

MIAX operates regulated financial marketplaces across multiple asset classes and geographies. The MIAX Exchange marketplaces are enabled by in-house built, proprietary technology that was originally built to meet the high-performance quoting demands of the US options trading industry. 

The group operates markets across a number of asset classes including options, futures and cash equities: including options through MIAX Options, MIAX Pearl, and MIAX Emerald; US equities through MIAX Pearl Equities; US futures and options on futures through the Minneapolis Grain Exchange; and international listings through The Bermuda Stock Exchange. Through MGEX Clearing, it also offers clearing services for US futures and options on futures. The group recently acquired Dorman Trading, a full-service Futures Commission Merchant registered with the Commodity Futures Trading Commission.

Its total US multi-listed options market share reached a record 14.3% in 2021, a 21% increase from its 11.8% market share in 2020. Total US multi-listed options market share for the MIAX Exchange Group reached 11.63% in the first nine months of 2022, representing a 19.8% year-over-year decrease. A total of 97.3 million multi-listed options contracts were executed on the MIAX Exchange Group, representing an average daily volume of 4,635,039 contracts. Total year-to-date (YTD) volume reached 961.2 million contracts, a decrease of 2.8% from the same period in 2021.

In US equities, MIAX Pearl Equities reported volume of 2.8 billion shares in September 2022, representing a 101.8% increase YoY and a record monthly market share of 1.16%. Total YTD volume reached a record 22.4 billion shares, a 268.1% increase from the same period in 2021. Since launching its first options exchange in 2012, MIAX has grown to be the 15th largest global derivatives exchange operator as of 30 June 2022, as measured by the total number of futures and options contracts traded on exchanges as reported by the Futures Industry Association.

Since 2017, MIAX has been involved in ongoing litigation with Nasdaq, surrounding six claims of patent infringement. As of June 2022, these claims were invalidated by the US District Court and and Nasdaq waived its right to appeal, thus closing the case. 

The winner of Best Challenger Exchange will be announced at the Leaders in Trading 2022 gala awards dinner at The Savoy Hotel on 3 November. For table enquiries, please contact Nathan Anacleto.  

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IEX was founded by former RBC electronic traders Brad Katsuyama and Ronan Ryan, notorious for their portrayal in 2014 Michael Lewis’ book ‘Flash Boys’. In 2020 the group applied for approval for the D-limit order, which it claimed would combat adverse selection, levelling the playing field between HFTs and slower market participants.  

A D-limit allows traders and investors to submit a discretionary limit order that can adjust its pricing if the stock price is about to change for the worse, using predictive technology called IEX Signal.  

“We deny the petition challenging the SEC’s decision,” stated three federal court judges.

“D-Limit… is an innovative, yet simple, solution designed to enhance on-exchange liquidity,” IEX group president Ronan Ryan said at the launch. “D-Limit has gained the support of a broad coalition of asset managers, pension funds, brokers and market makers, and represents a continuation of our efforts to partner with the broker-dealer community to provide new solutions for best execution designed to help all market participants achieve better performance in displayed trading.” 

The order gained market support from players including Virtu Financial and Goldman Sachs. However, others were strenuously opposed: including Citadel Securities, which wrote to the SEC on 14 August, 2020 expressing its concern that the IEX proposal would discriminate against liquidity takers. 

“This proposal represents a significant departure from the current market structure, unfairly favouring IEX liquidity providers without any corresponding obligation, compelling market participants to preference IEX over other exchanges, and adversely impacting tens of millions of orders submitted by retail investors annually,” said Stephen Berger, global head of government and regulatory policy at Citadel Securities, in the letter.  

The regulator nevertheless decided in favour of IEX and the order type was approved on 26 August, 2020, noting that there was no evidence that the D-limit would require “material changes” to brokers’ routing strategies. Widely seen as a victory for IEX, the D-limit was launched in October 2020. Citadel Securities subsequently petitioned for review, arguing that the SEC lacked substantial evidence for one of its findings and that three of the SEC’s decisions were (as referred to in the court statement) “arbitrary and capricious”. 

“No one in this case has alleged that latency arbitrage is unlawful. The issue, instead, is whether the SEC may allow IEX to innovate.”

The case was heard in October 2021 and on 29 July, 2022 the US Court of Appeals ruled conclusively in IEX’s favour. “We deny the petition challenging the SEC’s decision,” stated three federal court judges. “The SEC’s determination that the D-Limit order does not violate the Exchange Act by unfairly discriminating or unduly burdening competition was reasonable and supported by substantial evidence.” 

IEX, which promotes itself as a champion of fair investing, has vocally opposed latency arbitrage since it received regulatory approval to become a licensed trading venue back in 2016 – another controversial SEC decision that split the market, with detractors including Citadel Securities, the New York Stock Exchange and Nasdaq expressing vehement opposition, while players such as T Rowe Price and Franklin Templeton voiced public support.  

Last week’s decision saw the court expressing neutrality on the subject. “At issue is not whether companies like Citadel may seek advantages in the market by using advanced technology and ingenious trading strategies,” said the judges. “No one in this case has alleged that latency arbitrage is unlawful. The issue, instead, is whether the SEC may allow IEX to innovate, with the D-Limit order, in a way that offers new opportunities to long-term investors.”  

IEX called the ruling “a huge win for all investors and traders.” 

In a statement reported by Bloomberg, Citadel Securities spokesperson David Millar said: “We look forward to continuing to engage with the SEC to ensure that the best interests of both retail and institutional investors are protected.” 

Read more about IEX Exchange in our interview with Brad Katsuyama and Ronan Ryan following its licensing in 2016.  

Learn more about the consequences of the ‘Flash Boys’ case and the ripple effect from Lewis’ book in our latest feature for the Q2 magazine.  

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US-based Investors’ Exchange (IEX) has selected former Brooks Brothers general counsel, Rachel Barnett, as its new chief legal officer.

Barnett joins IEX Group as chief legal officer from the US clothing retailer where she has been general counsel and secretary for the last two years. 

In her new role, IEX said she will be responsible for overseeing all legal and compliance matters for the exchange group. 

“IEX is extremely excited to bring on Rachel Barnett as chief legal officer at a pivotal time for the growth of our exchange and technology businesses,” said IEX co-founder and CEO, Brad Katsuyama, whom Barnett will report directly to.

“Rachel’s impressive background covers numerous aspects of the legal profession. She has experience as a board member and general counsel of a publicly-traded technology company, and as a skilled litigator of complex financial securities cases.”

Barnett brings an extensive legal career to the role, starting out in 2006 as a securities litigator at private practice Skadden, Arps, Slate, Meagher, and Flom, where she spent seven years.

She later went on to spend five years as general counsel and corporate secretary at Travelzoo, where she advised executives on corporate governance, strategic planning, international acquisitions, and Security and Exchanges Commission compliance. 

The appointment follows a recent strategic investment in IEX made by Québec institutional investor Caisse de dépôt et placement du Québec (CDPQ) in December as the exchange operator looked to continue expanding.

Elsewhere in June, IEX hired the former global head of equities electronic trading at JP Morgan, Daniel Ciment, as its new chief operating officer. Ciment had spent 10 years with JP Morgan also as global head of agency program trading. He took up the new role at IEX in July 2020.

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In his new role at BMO, Stockland will be responsible for product development and developing new client relationships, particularly with his institutional asset manager connections.

Stockland joins the BMO Capital Markets electronic trading division with nearly 20 years of industry experience, most recently serving as chief strategy officer at IEX Group for over four years. 

Previously in his career, Stockland has also worked at US-based market maker KCG Holdings, now part of Virtu Financial, as an execution consultant for almost nine years.

“Eric’s appointment is a testament to BMO’s commitment to invest and develop innovative electronic trading solutions,” said BMO in a statement. “The addition to the growing electronic trading team comes on the heels of BMO Capital Markets acquisition of Clearpool Group. Eric is a respected practitioner and thought leader in the industry who will help transform BMO’s institutional offering.”

Stockland’s appointment follows the acquisition of US-based agency broker and algorithmic trading specialist Clearpool by BMO, which was completed in April and first announced at the beginning of 2020.

BMO said at the time that Clearpool would deliver ‘powerful’ new capabilities to its electronic trading platform and added that electronic trading was a rapidly growing portion of the global equity secondary commission pool.

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Daniel Ciment joins IEX after ten years at JP Morgan where he served as head of global equities electronic trading and global agency program trading. He will begin his role as COO of IEX Exchange next month, reporting to IEX president and co-founder Ronan Ryan.

During his time at JP Morgan, Ciment’s team established various execution products for the bank’s institutional, hedge fund, broker-dealer and corporate clients. He has also previously held similar roles in electronic trading at Barclays, Lehman Brothers and ITG.  

“Over the years, we have built a great and trusted relationship with Daniel in his role leading the JP Morgan Equities Electronic Trading business,” said IEX co-founder and CEO, Brad Katsuyama. “He is an industry leader and well regarded by our clients, both on the buy-side and sell-side. Bringing Daniel onboard as the COO of the Exchange gives us a senior leader who can help drive IEX to the next level as we look at a number of significant opportunities on the horizon.”

Ryan, IEX co-founder and president, added that Ciment’s experience in providing service and product innovation to market participants throughout his time at JP Morgan and broader career is invaluable to the exchange.

In August, IEX moved to implement market access charges on its most active trading members for the first time. The decision followed IEX’s disclosure of its costs to produce market data and connectivity amid widespread debate on allegedly overpriced exchange data and connectivity products.  

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The US Securities and Exchange Commission (SEC) has denied a proposal from Cboe Global Markets to introduce a four-millisecond delay on its equities exchange.

The controversial speed bump was opposed by some of the markets most active participants, including Citadel Securities, BlackRock, T.Rowe Price and industry lobby groups representing mutual funds, hedge funds and high frequency traders.

The SEC stated: “The commission concludes that the proposal is discriminatory and the exchange has not demonstrated that the proposal would not be unfair. The exchange has not demonstrated that the proposal is sufficiently tailored to its stated purpose, which is to improve displayed liquidity.”

Under the Cboe proposal, liquidity-taking orders sent to its EDGA exchange will have to wait four-milliseconds before trading with resting orders in the order book. It said this will provide market makers with sufficient time to re-price their rusting orders before ‘opportunistic’ or high frequency traders can trade with them at old prices.

“Cboe will remain committed to enhancing the US equity markets for all participants, and will continue to work closely with our regulators and industry to develop innovative products that benefit the marketplace,” Cboe said in a statement.

The proposal was set to be the third implemented by a major US exchange after IEX and NYSE American deployed their own speed bumps. However, Cboe said at the time of the plan that these mechanisms do not provide protection to market makers and participants that post two-sided markets, whereas its Liquidity Provider Protection feature would promote price forming displayed liquidity.

NYSE American also scrapped its speed bump in November last year, and instead implement a floor-based designated market maker scheme. 

However, opponents to the Cboe plan argued the speed bump would create unfair advantages for the fastest players, while at the same time, leaving mutual funds to be hit by orders.

The Investment Company Institute, a trade group that represents mutual funds managing more than $25 trillion in assets, wrote in a letter to the SEC that the speed bump would establish a “harmful precedent” by penalising slower market participants.

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The Securities and Exchange Commission (SEC) has published a proposal in a bid to modernise the governance of National Market System (NMS) plans, which produce the public consolidated tape and disseminate trade and data from trading venues.

Under the current regime, incumbent exchanges, such as Nasdaq, the New York Stock Exchange (NYSE) and Cboe, have total control and voting power over how the consolidated tape is produced and disseminated. Although under the SEC’s proposal, broker-dealers and investment firms would gain voting rights, subsequently limiting the control of incumbent exchange operators.

“The Commission has received extensive public input on issues relating to equity market structure and access to market data, as well as suggestions for how that structure should be updated to ensure that our markets continue to best serve the interests of investors,” said Jay Clayton, chairman of the SEC. “Today’s proposed order is designed to address issues regarding the dissemination of market data that affect the efficiency and fairness of our markets.”

The proposal from the US watchdog is the culmination of intense debate among market participants, many of whom argue that exchanges have an unfair monopoly on the equity consolidated tape, which they suggest is grossly overpriced considering the supposed low-cost of production. 

Mehmet Kinak, a 19-year T. Rowe Price veteran who currently heads up global systematic trading and market structure for the asset manager, has long-been an advocate for sweeping changes across the industry, which he believes in some cases can favour exchange groups over investors. During a heated roundtable discussion at the SEC early last year, Kinak argued that brokers have no choice but to purchase more expensive equity market data products from exchange groups to meet regulatory requirements.

“What concerns me is an ecosystem that slants one direction over another, [the exchanges] set the rules and we have to follow them,” Kinak told the SEC. “That’s a tilted system which needs to be addressed. An ecosystem of a for-profit company that can self-regulate itself and police reform that allows it to get flow is a terrible cocktail that has been created, unfortunately, and it needs to be addressed.”

Similarly, challenger exchange group IEX, alongside the likes of firms such as Virtu Financial, strongly supported Kinak’s argument and slammed the incumbent exchanges for not revealing the true costs of producing the consolidated tape. Shortly after the roundtable at the SEC, IEX made the bold move of publicly disclosing its own costs of producing market data and connectivity, suggesting that incumbent exchanges could be marking up charges for such services by as much as 4,000%.

At the same time, and following the bitter dispute over transparency and costs, nine major Wall Street firms confirmed plans to establish a member-owned equities exchange to rival the incumbents. Known as Members Exchange (MEMX), those involved include Bank of America Merrill Lynch, Charles Schwab, Citadel Securities, E*TRADE, Fidelity Investments, Morgan Stanley, TD Ameritrade, UBS and Virtu Financial.

MEMX’s mission is to increase competition and transparency, while reducing fixed costs and simplifying execution of equity trading in the US, with the latest technology and a low-cost fee structure. Former Instinet CEO, Jonathan Kellner, leads MEMX as chief executive, and the exchange is moving forward with its plans after gaining a green light from the SEC to launch its operations at some stage in the middle of this year.

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The exchange group’s chief executive and co-founder, Brad Katsuyama, said in a statement on social media that a new fee structure will be implemented later this year for a small subset of highly active clients that use extra ‘logical ports’.

Logical ports, also known as trading sessions, are used by broker dealers to submit orders to exchanges. As of October, IEX will offer its members access to five ports for free, and then charge $100 per month for additional ports. Katsuyama said around 25% of IEX’s clients will incur the extra fee.

The move follows IEX’s decision to disclose its costs of producing market data and connectivity earlier this year, which stated that the costs associated with supporting logical ports is around $1.5 million per year, or roughly $83 per month, per port. IEX was the first US exchange operator to publicly disclose its market data and connectivity costs amid widespread debate about overpriced exchange data and connectivity products.

“After disclosing our costs to provide market data and connectivity, we actually had some members encourage us to at least cover our costs in providing these services,” Katsuyama said about the new fee structure.

“We were also focused on ensuring that our new fee filing aligns closely with the requirements of the Securities Exchange Act of 1934… which [requires] that exchanges provide the information necessary to show that fees are fair and reasonable and do not impose a burden on competition.”

Despite market data and connectivity fee filings traditionally effective immediately, IEX said it has decided to delay the adoption of the free structure to provide its members with time to assess the changes, and provide any feedback.

“We are hopeful that our rationale for this change makes sense and that the standard we are setting for exchange fee filings raises the bar for all exchanges going forward,” Katsuyama concluded.

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