Tuesday, March 18, 2025

The Fight Over ECN Fees

A full-blown dispute has emerged between traders and electronic communications networks (ECNs). At issue is the transaction or access fee, charged each time a market maker hits the bid or takes the offer on a stock an ECN is publicly quoting on Nasdaq.

Many market makers complain that these fees should not be charged, in part because ECN orders are similar in one respect to the quotes posted on Nasdaq by market makers. They are all part of the Nasdaq price-quote montage.

Consequently, many market makers, from the largest to the smallest, are refusing to pay access fees on orders executed as a result of ECN price quotes on Nasdaq. ECNs, in turn, are now refusing to accept orders preferenced by some of the brokers withholding access payments.

Compete Publicly

Market maker quotes and ECN customer orders compete publicly each day on Nasdaq. Some of the best known ECNs are Reuters Holding's Instinet and Bloomberg Tradebook. ECNs frequently stand alone at the inside price. In some securities, in fact, ECN orders outnumber market-maker quotes. That is likely to become more common as firms reduce their market-making commitments and new ECNs enter the market.

In addition to the access fees charged at up to one and a half cents per share as well as the ECN's posted stock prices, traders incur Nasdaq's one-cent fee whenever their trades with ECNs are transmitted over SelectNet. ECN customers on the other side of the trade are often charged a similar ECN fee, but are not charged a Nasdaq fee.

Market makers, on the other hand, do not charge an access fee. Nor do they pass along the ECN fees, which can add up quickly, to their customers. As market makers see it, the ECNs should be collecting fees only from their customers, who are getting the benefit of executions on their anonymous orders. Without regulatory guidelines, many market makers, as mentioned earlier, are withholding payments to ECNs. These tactics have resulted in several legal and regulatory issues noted herewith:

*Breach of agreement lawsuits.

ECNs are allowed by the Securities and Exchange Commission to charge a reasonable fee to non-subscribers for accessing an ECN. An ECN, which is responsible for communicating its fee structure, may require that non-customers enter contractual agreements on the payment of access fees. Furthermore, the SEC has informally told ECNs that they may refuse to trade with any entity that does not pay its fees.

The first of probably many lawsuits was recently filed by Montvale, N.J.-based All-Tech Investment Group, operator of the ECN ATTN, against a large Jersey City-based Nasdaq wholesaler.

*Heightened NASD scrutiny for unnecessarily locking or crossing markets.

A locked or crossed market occurs when the publicly-displayed inside bid and offer prices are identical or inverted (e.g., an inside bid priced at 10 1/2, and an inside offer priced at 10 1/2 or 10 3/8). A market maker is more likely to enter a locking or crossing quote when it is denied access to an ECN's inside market in order to attract trading interest. While failure to pay an ECN its fees may not be a regulatory issue, the increased incidence of locked or crossed markets is a market-integrity issue.

*Best-execution violations.

This could occur if traders are unable to obtain the best Nasdaq price available.

Interestingly, the National Association of Securities Dealers does not seem concerned that ECNs, which are registered broker dealers, may be failing to provide best execution when they do not fill their customer orders.

*Disruption of trading operations.

Instead of several seconds to execute an order, a trader who is denied access to an ECN may take the time to either call around to get execution at the inside price or enter a locking or crossing order.

ECNs were approved by the SEC under the terms of the order handling rules to operate trade-matching systems through a SelectNet linkage to Nasdaq. When the two-tiered market ended in January 1997 with implementation of the SEC's order handling rules, there were four SEC-approved ECNs. Now there are eight. A ninth ECN is awaiting final regulatory approval.

ECNs transmit their best customer and subscriber orders to Nasdaq and accept preferenced SelectNet orders from third parties. ECN orders can also be accessed by telephone, while subscribers have direct access to ECNs via dedicated terminals and PC-based modems.

The SEC and the NASD are aware of the current controversy between market makers and ECNs, and are considering rule proposals that may resolve the situation.

One rule proposal, a copy of which was obtained by Traders Magazine, would prohibit ECNs from refusing "to deal with any person who attempts to access the quote of the [ECN] when one or more [ECN] is responsible for the inside quote, on the basis that such person has not paid or will not pay any charge or fee that is in addition to the publicly-quoted price of the [ECN]."

Meanwhile, regulators are keeping a noticeably low profile. It is too early to draw conclusions about their ultimate decision. Nevertheless, Richard Lindsey of the SEC's Division of Market Regulation, informed attendees at a recent Securities Industry Association conference that the SEC looks favorably on the NASD proposal.

An NASD spokesman, however, declined to comment, noting the sensitive nature of the issue.

Times Change

Less than two years ago, many of these same Nasdaq market makers wholeheartedly subscribed to Instinet and paid its transaction fees. Instinet provided anonymity and participation in a two-tiered Nasdaq market: the public quote montage and the better-priced Instinet subscribers' market. Market makers were allowed to attract trading interest at prices inside the Nasdaq public market spread without adjusting their quotes. For Instinet and Nasdaq market makers, it was a "win-win" situation.

Currently, however, the combination of dramatically reduced spreads, significant NASD fines and ECN fees may be just too much for Nasdaq market makers and traders to countenance. And the burden of ECN fees can only worsen as more ECNs enter the market.

Firms may continue to pay the ECNs' fees for accessing their price quotes on Nasdaq. If so, these market makers will have uninterrupted access to all inside markets.

Firms that withhold payments, however, can expect to be denied access to ECN orders. When this occurs, the best advice I can offer is this: market makers must be able to demonstrate that they attempted to access the ECNs prior to entering a quote that effectively locks or crosses the market.

Howard L. Haykin, CPA, is president of Compliance Solutions, a New York-based specialist in regulatory compliance for NASD broker dealers and SEC investment advisers.

Are Commission Rates Finally Slowing Down? Report Notes Levelling in Institutional Equity-Trade

An uninterrupted and staggering 20-year decline in the average equity commissions paid to broker dealers by U.S. institutions is slowing unceremoniously, a new report by Greenwich Associates reveals.

"The point of resistance has been reached," said Wayne Wagner, president of the Plexus Group, a Santa Monica, Calif.-based firm that studies institutional-trading costs. "Brokers are simply saying, Let's have no more declines in commissions.'"

Across a range of 400 institutions that responded to the study, Greenwich notes that weighted average commissions in aggregate remained unchanged at 5.6 cents per share for the 12 months ended January 1998, the same average rate of a year earlier.

That's the first yearly measurement taken since 1977 by the Greenwich-based research firm, that average commissions did not decline by roughly one-tenth of one cent each year. (Average commissions are the total commissions reported, divided by the shares executed, irrespective of institutions' weight or size.)

Back in 1977, the average "unweighted" commission was 13.6 cents, compared with 6.4 cents in 1997. Adjusted for inflation, the effective 20-year decline is even more stunning than the more than 50-percent decline.

An official at Greenwich said in an interview that the results in the report, compiled for U.S. institutional equity investors, confirmed what the firm had been anticipating as far back as 1994 that commissions would eventually hold relatively steady. Of course, the closer to zero commission, the smaller the room becomes for rate shrinkage.

Nevertheless, taking the four years starting in 1993, commission rates per share on agency trades, as measured by the reporting institutions' weight, fell until 1995 from 6.3 cents to 6.1 cents to 5.9 cents, and held steady in 1996 and 1997 at 5.6 cents per share.

While some U.S. institutions from mutual funds and pension plans to money managers and other buy-side firms expect downward movement in commissions in the coming year, only the very largest envision slight declines in rates, according to Greenwich.

Increasing Profitability?

But does the study, as the Plexus' Wagner and other experts suggest, really convey that broker dealers are headed for a new period of increasing profitability on the tail of a rip-roaring stock market?

The answer is not that simple. At best, the picture is clouded. For one thing, a breakdown of the unweighted average commissions per share on agency trades shows a divergence in rates paid by the very largest institutions on the one hand, and some of the smallest institutions on the other.

While institutions with total commissions of over $20 million annually saw average commissions dip from 5.7 cents to 5.6 cents, institutions generating commissions of $5 million to $9.9 million reported that their average jumped from 6 cents to 6.2 cents.

On the Nasdaq side, that pattern was only evident between the very small institutions and all the other reporting institutions. Imputed commissions for these smaller buy-side firms rose significantly, while the commissions actually declined for all the rest. (Imputed commission, classified by traders as net-trading costs paid as Nasdaq credits to market makers, are implied by factoring the stock value plus the spread divided by the number of shares executed.)

To be sure, the rate increases noted among the smaller institutions clearly contributed to the reversal in overall commission rates in 1997. Even so, on an unweighted basis, commissions on agency trades fell from 6.7 cents in 1995 to 6.5 cents in 1996, and to 6.4 cents in 1997. On the Nasdaq side, imputed commissions dropped from 7.3 cents in 1995 to 7.2 cents in 1996, and to 6.6 cents in 1997.

Explicit Commissions

The continuing decline in imputed commissions raises the prospect that Nasdaq institutional desk's will eventually charge explicit, or actual, commissions for handling block orders.

That's even more likely if the Securities and Exchange Commission approves a proposal by the National Association of Securities Dealers to eliminate double counting on riskless principal and other trades.

Altering the way trades are counted would result in single prints instead of two-sided prints. "That would make it easier to charge institutions a straight commission," said George Jennison, head of Nasdaq trading at Richmond, Va.-based Wheat First Union.

"At the moment, there is significant margin pressure on Nasdaq institutional business," Jennison added. "We're probably going to see some repricing on orders."

Some institutional traders suggest that institutions themselves are really holding up commission rates. In their view, institutions are loathe to push rates down much further because that would hurt the level of soft-dollar research services they receive.

Greenwich noted that the soft-dollar conversion ratio now hovers at 1.55. In a soft-dollar arrangement, a specified proportion of an institution's total agency-commission business is rebated or softed to institutions in the form of research and other services.

Thus, with a conversion ratio of 1.55, an institution receiving a total of $100,000 in soft-dollar services would be required to transact $155,000 in commission business.

"If commission rates drop much further, institutions would be hurt," said Raymond Murray, director of trading at Minneapolis-based Investment Advisers.

On the other hand, Wall Street firms, such as New York-based Lynch, Jones & Ryan, that specialize in soft-dollar services to institutional accounts, may be holding a lid on commission rates, according to other experts.

"Soft-dollar brokers may be providing a level of competition to executing brokers in general," said Lee Pickard, a Washington-based attorney specializing in soft dollars. "If these soft-dollar firms were not around, rates might now be even higher."

Electronic Brokerages

Finding a clear sign of where commissions are headed, therefore, is not easy.

The popular use of electronic brokerages, such as Reuters Holdings' Instinet, somewhat clouds the landscape. Greenwich's study notes that institutions paid 3.8 cents per share on electronic brokerages, dubbed as "non-traditional" trading systems by Greenwich.

At least 96 percent of institutions generating more than $20 million a year in commissions using non-traditional systems for Nasdaq business. Greenwich further noted that among institutions generating more than $5 million a year in commission volume, 82 percent use non-traditional systems, up from roughly 75 percent in 1995 and 1996.

"Even if use is not so widespread among institutions that are not quite so giant," said Greenwich consultant Bjorn Forfang in a foreword to the study, "it is extremely widespread and rising."

The message now is that there is less homogenization of commission rates than ever before, according to another expert. "Some institutions will pay six cents to a broker for block positioning or capital commitment, and use an electronic broker for plain-vanilla agency execution," the expert said.

By Greenwich's calculations, average commissions on agency trades as distinct from all other business are expected to decline to 5.5 cents in 1998 from 5.6 cents in 1997. But even that may not change the current steady trend in rates. "If the commission rates stay flat and then begin to rise, that could be significant for sure," said an official at Greenwich.

But the official pointed out that the consolidation trend among institutions is likely to put a further squeeze on commissions. "Commissions could go down further in the coming year," the official added.

All told, total commissions generated in the U.S. institutional equity business increased modestly for the 12 months ended January 1998, gaining just two percent over the prior year, according to Greenwich.

Broken down, listed commissions, accounting for more than half of all institutional equity order flow up three percent since 1996 increased by seven percent. Imputed commissions rose by ten percent and now comprise 25 percent of all commissions.

Significantly, commissions generated from new issues or initial public offerings fell dramatically, nearly 25 percent in 1997 from the previous year's record high. At the 75 largest reporting institutions that each generate more than $20 million in aggregate business, commissions dropped from 33 percent to 24 percent of total commissions.

Retail

While Greenwich's study might hint that institutional broker dealers may be headed to higher levels of profitability, that conclusion must be juxtaposed beside the impact of narrowing spreads on Nasdaq (most obviously on the retail side).

Indeed, Greenwich notes that imputed commissions on Nasdaq from handling block orders executed with a spread continued to decline from 6.8 cents per share in 1995 to 7.3 cents in 1996, and to 5.9 cents in 1997.

And the 1998 Traders Magazine Nasdaq Market-Maker Survey revealed profitability, across a range of small to large firms, declined among roughly 60 percent of the desks.

Although that data could not be independently verified, the reported decline was attributed by head traders to the ongoing impact of the order handling rules and the widespread quoting of Nasdaq stocks in sixteenths.

For its part, Nasdaq said spreads declined by up to 33 percent soon after the implementation of the order handling rules in January 1996.

"Over-the-counter profitability is way down," lamented Wheat First Union's Jennison.

Skeptics

Some experts, however, are now questioning if the narrower spreads can be equated with declining profitability.

"During the trading day, I suspect some market makers are simultaneously moving their bid and asked prices up and down on a Nasdaq stock, before committing to handling a large block of shares behind a smaller order," said one expert, who declined to be named.

"On a buy order, institutions are paying more, and on a sell order they are getting less," added the expert. "Spreads have narrowed, but not the effective profitability."

Are market makers engaging in this practice?

"Oh, that's plain silly," snapped a New York-based market maker.

Commission Rates in Cents Per Share (Agency Trades) Commission Volume 93 94 95 96 97 98*

Over $20 million 6.2 5.9 5.8 5.5 5.4 5.4

$10 million to $20 million 6.4 6.2 6 5.8 5.8 5.7

$5 million to $9.9 million 6.1 6.2 6.1 6.1 6.3 5.9

$2.6 million to $4.9 million 6.2 6.5 6.2 5.8 6.3 6

$2 million to $2.5 million 6.8 6.5 6.6 6.5 6.2 5.9

$1 million to $1.9 million 7.3 7.2 6.5 7 6.7 6.5

Under $1 million 8.3 9.1 9.2 7.7 7.7 7.3

Total Institutions 6.3 6.1 5.9 5.6 5.6 5.5

*estimated

Note: Average weighted by Commission and based on matched volume

Source: Greenwich Associates

For Your Eyes Only: In Undercover World of Intelligence Agency Desks Utilize New Technology

On Wall Street, firms guard intelligence secrets with a passion rivaled perhaps only in international espionage.

But the programmers and scientists guarding the secrets of so-called intelligent trading systems more closely resemble James Bond's pal Q the brainy inventor of 007's electronic gadgets than they do the British secret agent.

Since their introduction into Wall Street in the late 1980s, intelligence systems have made significant inroads into proprietary trading. Employing mathematicians and physicists, certain firms have used the systems based on mathematical models, or algorithms, that help process information and recognize patterns to locate mispriced securities and project future stock movements.

But recently, a number of trading firms have used intelligence software to trade stocks on an agency basis.

"Agency trading will have to go this way," said Dr. Mark Gimple, managing director of quantitative methodologies at New York-based Reynders, Gray & Co., an institutional agency-trading firm. "Investors are looking worldwide for liquidity, and they will need that technology to find it."

Gimple a Stanford University Ph.D. and former aerospace and biomedical scientist developed his firm's distinct intelligence system. With initial start-up costs of more than $400,000 for equipment and software, it took Gimple six months to get the trading system running.

Aimed at lessening market impact, the quantitative trading system is programmed to follow the daily volume in New York Stock Exchange-listed stocks. The system equipped to trade up to 6,000 client orders each day will trade for orders when a particular stock's volume is peaking during the day.

The system does not handle Nasdaq orders. "Because of the nature of the dealer market," Gimple said, "Nasdaq orders require a little more human attention."

Affectionately nicknamed "the walking algorithm" by his co-workers, Gimple said the system keeps track of multiple liquidity sources and accurately projects when volume in certain stocks will rise.

When the desk receives an order from a client at a pension fund, trust fund, institution or from a broker, Gimple or a Reynders Gray trader will give the client a first assessment of the market, hoping to get a sense of how the client wants the order to trade. Some orders may need to trade quickly, others can be stretched out over days. Based on the client's instructions, the desk will enter the order for execution within a certain time frame.

The desk then enters the order into the system, providing the system with a designated price range and time frame for execution. The system will execute an order within the designated parameters when it predicts volume will peak.

"We call it trading in the shadows,'" Gimple added. "We try to be present in the market, but we don't want our orders impacting the marketplace."

When the system determines an order should be filled, it will be sent to the NYSE's DOT system if it is a market order, or to SuperDOT if it is a limit order. The Big Board's electronic systems, in turn, route the orders directly to the specialist for execution.

Reynders Gray has eight equity traders in New York and Boston. Of the 1.5 million shares the desks average each day, almost half are executed by the trading system.

Across town from Reynders Gray's midtown Manhattan offices, New York-based Investment Technology Group (ITG) also utilizes a distinct quantitative algorithm to trade securities on an agency basis.

QuantEx ITG's quantitative trading system monitors market conditions and is programmed to make trading decisions based on weighted factors. Like the system at Reynders Gray, QuantEx will route orders directly to liquidity sources when market conditions are most favorable.

"It is almost like the system has a series of questions it asks thousands of times a day," said Suzanne Christensen, ITG's director of product marketing for QuantEx. "If all of the market conditions click, the system will trade the order."

In 1990, ITG acquired a small technology company, Integrated Analytics Company, that had developed a successful quantitative system. Hoping to transform it into a transaction system, ITG spent almost three years reprogramming the quantitative software.

Orders are entered into QuantEx during the day, and are routed to DOT, over-the-counter market makers, electronic communications networks (ECNs), crossing networks and brokers when market conditions fulfill the system parameters.

Aside from handling orders on its own agency desk, ITG has licensed 115 QuantEx links to 60 clients. The ITG clients with QuantEx links route orders directly to liquidity sources through ITG's routing server.

David Cushing, ITG's director of research, provides all coverage and strategy writing for QuantEx clients. Aside from its research responsibilites, Cushing's staff works with clients to help integrate QuantEx into the client's trading operations.

"Working so closely with clients, we can help identify what clients want on their end," Cushing said. "That lets us know what enhancements will keep our system up to date."

QuantEx clients route more than ten million shares a day, and ITG routes up to seven million shares daily on the intelligence system.

"What QuantEx does would be impossible to do on a human level," said Scott Mason, ITG's president. "It would take a large team of traders to trade the way it does. I can't see how agency desks will be able to continue to trade without some kind of intelligence system."

Algorithms, Quants and Expert Systems

An algorithm is a mathematical program that surveys inputted data and charts predictions based on that data.

Applied to trading, algorithm programmers believe that market behavior, although appearing very chaotic and random, follows a pattern. By analyzing various data sources and weighting those sources based on importance programmers hope a system can find a pattern and make predictions based on that pattern.

A genetic algorithm programmed to mimic the human thought process runs whole sets of algorithms together, constantly updating and modifying predictions based on changing inputs. A genetic algorithm attempts to solve problems through constant trial-and-error processes.

"Genetic algorithms are built with more parameters than simple algorithms," said Richard Bauer Jr., a finance professor at San Antonio's St. Mary's University, and author of "Genetic Algorithms and Investment Strategies," a book on the application of algorithm models on Wall Street.

Bauer said that genetic algorithms distinct from the most basic algorithms are more dependent on human programmers to produce forecasts.

"An algorithm can be generic and just react to information," Bauer added. "But because it has a memory, a genetic algorithm reacts the way humans would react if they could analyze data that quickly and efficiently."

A neural network as described by Dr. J. Doyne Farmer, a senior scientist at Santa Fe algorithm investment firm Prediction Company is a series of algorithms working together for more detailed predictions.

"You set up a neural network with algorithms connected in layers," Farmer said. "They work like nerves do, with the firing of one triggering processes in subsequent nerves."

Neural networks, according to Farmer, mimic the human brain's repetitive processes of measuring data, making adjustments and remeasuring data until predictions run smoothly. Once a certain algorithm makes a projection, it spurs the firing of a subsequent algorithm.

At Prediction Company, Farmer helped develop the detailed neural network that manages a portfolio of investments for international banking giant Swiss Bank Corp. Farmer started the company in 1991 with Dr. Norman H. Packard, his former University of California at Santa Cruz physics classmate.

But according to Lawrence Tabb, a group director at Newton, Mass.-based research company The Tower Group, many Wall Street firms have turned away from neural-network technology because of the complexity of the forecasting processes.

"Because the processes are so layered, I think people on Wall Street have backed away because they can't understand how the systems reach conclusions," Tabb said. "Data goes in, but a lot of people don't trust the answers that come out."

Tabb added that more Wall Street firms have turned to expert systems and quantitative models in recent years.

An expert system is a series of algorithms based on expert analytics. With rules derived from professionals in the designated industry, an expert system will process data based on those rules.

In trading, an expert system could be programmed with algorithms based on rules followed by certain traders. The system would rapidly process data and make predictions based on the preprogrammed trading rules.

A quantitative system or quant in trading uses complex algorithms programmed into the system as rules. Based on market conditions, like current prices and order flow, for example, the rules would ensure a desk's orders are handled within certain bounds.

"Often, a firm setting up for quantitative analysis knows what kind of results it wants, but it doesn't know how to program the system to achieve those results," Gimple said. "Quantitative systems may not actually trade, some just make sure a desk stays within its limits."

Intelligence Systems in Trading

Intelligence systems are used all over Wall Street, from exchange order books to money-management software and trading systems.

D.E. Shaw & Co. is the most well-publicized Wall Street firm using intelligence systems in proprietary trading.

Launched in 1988, D.E. Shaw utilizes algorithm models to exploit securities-pricing inefficiencies. The investment bank, founded by former Columbia University computer-science professor David Shaw, is reported to have spent over $100 million to research, construct and maintain its systems.

D.E. Shaw's mathematical models and risk-management systems try to identify pricing anomalies in over 100 worldwide markets. In recent years, the investment bank has expanded, creating a broker-dealer subsidiary for third-market trading and an international derivatives business.

Like most Wall Street firms using intelligence software, D.E. Shaw works to maintain a level of secrecy surrounding its trading systems. Few firms are open about their specific technology, and most keep volume figures hidden.

But according to Reynders Gray's Gimple, the growth in volume on the DOT and SuperDOT systems may in some ways mirror the development of intelligence trading over the last ten years.

In 1988, according to NYSE-published figures, the Big Board averaged more than 82 million shares each day over the DOT systems. That same year, more than 238 million shares were traded each day on the NYSE floor off of the DOT systems.

In 1993, DOT volumes jumped to 192 million shares a day, while almost 330 million shares traded off of the systems. Last year, volume on the DOT systems boomed, handling more than 475 million shares each day, close to the daily NYSE floor volume of almost 550 million shares for 1997.

Santa Fe's Prediction Company was one of the firm's that contributed to the growth in DOT and SuperDOT trading in recent years.

The firm's neural network makes all of the firm's investment decisions, and routes limit orders directly to SuperDOT. Prediction Company is bound by their contract with Swiss Bank Corp. from discussing its trading volume, but Farmer said since 1991, the firm has grown from just seven employees to more than 20 today.

Farmer added that Prediction Company has invested more than $10 million since 1991 in updating its neural network.

David Whitcomb, a Rutgers University finance professor, started an algorithm trading firm in 1988 that used to route limit orders to SuperDOT.

"I think we were the first firm to use an expert system to trade limit orders on the NYSE," Whitcomb said.

His Charleston-based Automated Trading Desk began trading limit orders on an agency basis for an investment bank. Although business remained profitable, the investment bank broke its relationship with Automated Trading Desk in 1995.

Today, Whitcomb's firm trades three million shares a day through its system for the 18 high net-worth customers of its brokerage subsidiary. Having spent millions to update its technology, the firm's expert system analyzes market information based on its clients' portfolios, makes trading decisions and routes orders to liquidity sources. The system now trades only Nasdaq securities, sending orders to SelecNet, SOES and licensed ECNs.

"Firms will have to do some of their trading this way," Whitcomb said. "Small trades should be done by expert systems because they can handle hundreds of orders at once. And human traders generally don't handle small retail orders with the same kind of attention they give to big blocks."

While still trading for its brokerage subsidiary, Whitcomb would like Automated Trading Desk to get back into trading on an agency basis as well. "It's our roots, and it kept us in business our first seven years," he added.

Agency Intelligence Systems

Although a number of agency desks are trading for clients with intelligence systems, it is by no means a standard practice among firms.

"That type of technology is used for proprietary trading, not agency trading," said Jim Hanrahan, head trader at New York-based Lynch, Jones & Ryan, a leading agency-trading firm. "Quants. Algorithms. That's business for a D.E. Shaw. What we do is follow customer orders."

Junius Peake, a University of Northern Colorado finance professor and Nasdaq market-structure expert, was unaware of any agency firm using intelligence software, but felt it was a logical and necessary development.

"I can't say I'm shocked agency desks are using that technology. It can do calculations that traders just can't," Peake added.

At ITG, Mason believes that although software and programming may differ greatly, intelligence systems will become the standard on Wall Street trading desks.

"There will always be agency trades that have to be handled the old-fashioned way, but intelligence trading will just continue to grow" Mason added.

Gimple agrees. "Investors are looking worldwide for liquidity, and they increasingly need technology to find it," he said. "A trader can't keep track of all the market information out there. You need the smartest technology to stay ahead."

The Mixed Blessing of Technology Spending:Desks Must Spend on Technology to Remain Competitive

Huge mainframes. Fiber-optic networks. State-of-the-art telecommunication systems. Worldwide market news delivered real-time.

Sound familiar? It should. These and more are at the very heart of a Nasdaq trading room.

Back in the pioneer days, much of what is today's Nasdaq trading-room technology did not exist. By contrast, some of today's technology has a pedestrian aura.

The consequences of that might be viewed as a mixed blessing desks have no choice but to collectively spend billions of dollars to remain competitive, but in return they transact business at an exponential rate.

Now Nasdaq, an electronic marketplace, is grappling with technology changes as never before.

Electronic communications networks (ECNs), such as Reuters Holding's Instinet, New York-based Investment Technology Group's POSIT equity matching system and an upstart crossing network, MatchPoint, developed by The AutEx Group and State Street in Boston, are helping to raise the stakes.

Never known for avoiding a challenge, the Street is embracing all this technology and more.

Three Areas

According to the latest institutional-equity study by Connecticut research firm Greenwich Associates, spending on technology is going to explode in the coming year.

Much will primarily be spent in three areas of Nasdaq trading: simplifying trading desks, deploying the Internet and client services.

"More and more firms are looking to deploy technology because the market has become extremely competitive, and recent regulations have cut into the spreads," said Lawrence Tabb, group director at The Tower Group, a Newton, Mass.-based consulting firm, referring to the order handling rules.

Tabb says that firms will use technology to make their operations more efficient and profitable.

To begin with, Tabb feels that desktop enhancements will be a priority for market makers, "because traders have to keep a grip on the various places they are trading in."

"When we started, there was the Nasdaq trading terminal and the Quotron," said Tom Norby, head Nasdaq trader at Portland, Ore.-based Black & Company. "Now there are so many platforms that you need to be a wizard to stay on top of every single one."

For one thing, the number of ECNs is on the rise. Besides Instinet, other ECNs include Bloomberg TradeBook. (Greenwich noted that 57 percent of all traders now report using Bloomberg terminals.)

Coming down the pike is BRUT, or the Brass Utility, developed by Automated Securities Clearance Corp., a Weehawken, N.J.-based company, and STRIKE, a Bear, Stearns & Co.-backed ECN.

Usage

According to Greenwich, among institutions generating more than $5 million a year in commissions, 82 percent now make use of non-traditional systems for Nasdaq business, up from 75 percent in 1995 and 1996.

The study notes that these same firms are expected to do 22 percent of their business in 1998 on non-traditional systems, up from 20 percent in 1997.

"Ten years ago, if you were an institution, you had to go to a Nasdaq trader to buy a stock," Tabb said. "Times have changed. Traders have to keep clients happy."

It is no surprise that technology budgets are being earmarked for running Nasdaq and ECN software as well as data feeds on one screen, instead of several standalone terminals.

"Traders won't have to deal with so many boxes anymore," Tabb said. Norby's Black & Co. is planning to run ECNs on one computer, allowing traders to view data in several windows on a single screen. Clearly, the plan would help cut operating costs.

As always, costs are uppermost on traders' minds. According to Greenwich, institutions paid an average 6.4 cents per share on listed agency trades, 6.6 cents per share on Nasdaq trades, and only 3.8 cents a share on ECN-based transactions for the year ended January 1998.

While the numbers appear to give ECNs a competitive edge, there are factors worth noting that make listed and Nasdaq commissions higher than ECN commissions.

For one thing, institutions use some brokers on listed agency business chiefly for soft-dollar services.

Nevertheless, the lower commission costs on ECNs have clearly helped them to gain market share.

Internet

The Internet is another hotbed of technology spending. And it is helping desks achieve another goal improving client services.

Buysiders see the Internet as an important source of after-hours research, according to the Greenwich study.

The same study finds an increasing number of institutions want their broker dealers to supply them research via the Internet.

What's more, broker dealers are bowing to the demands of their clients even as spreads shrink.

WorldStreet Inc. of Cambridge, Mass. provides sell-side trading desks a product that helps them share information more easily with buy-side clients, giving them around-the-clock service, seven-days-a-week sell-side access via the Internet.

The Internet is expected to be deployed for the National Association of Securities Dealers' Order Audit Trail System, or OATS.

OATS is a real-time electronic system, which gathers and reports up to 25 trade details from order-entry to order execution. OATS will replace current trade reporting that requires certain data to be sent to the NASD within 90 seconds of execution.

OATS will be implemented in phases. As part of the first phase, by March 1, 1999 electronic orders received by ECNs or at the trading departments of market makers will be subject to OATS reporting.(Electronic orders are defined as orders that are captured in an electronic order-routing or execution systems.)

FIX

Meanwhile, speed is becoming a buzz word.

"Brokerages are using FIX more extensively to become more responsive to their clients' need for faster delivery of research and other data," Tabb said.

FIX, or the Financial Information Exchange, is a communications protocol that enables securities firms and institutional investors to interact electronically.

This set of data structures and rules is radically changing the way financial counterparts communicate, enabling efficient distribution of information and transactions among a larger selection of trading partners.

FIX protocol was rolled out in 1992 after mutual-fund giant Fidelity Investments requested its broker-dealer trading partners to more fully automate the interaction among broker dealers and buy-side trading desks.

In 1993, several firms banded together to create FIX's comprehensive open standard, allowing firms to communicate indications, orders, confirmations and trade-allocation information, virtually without charge.

FIX is currently being adopted by the majority of U.S.-based equity buy-side and sell-side trading-platform vendors, and is gaining global acceptance as well.

The protocol is also being embraced by U.S. equity exchanges, trade-matching facilities and order-routing systems, and is quickly becoming the default standard for communicating all equity-trading information in the U.S.

According to Greenwich, the FIX protocol is now used by 21 percent of investors generating more than $20 million in commissions, up from 12 percent. On the growth side, Greenwich noted that 40 percent of the largest funds plan to use FIX protocol, and 35 percent all of investors generating more than $5 million are likely to be users.

The FIX protocol, combined with the Internet backbone, has enabled firms to create a global financial infrastructure, linking firms and branches seamlessly, Tabb says.

As more firms gain confidence in electronic trading technologies, and more platforms provide FIX-enabled order routing, Tabb believes that the number of trades and allocations routed will increase to approximately ten percent of total FIX traffic by the new millennium.

Priorities

When Greenwich asked institutions what changes they would most like Wall Street to make, many of their answers referred to technology-based services, said Greenwich consultant Phil Kemp in a foreword to his firm's report.

A striking number of institutions say they would like brokers to convert to electronic trading, said another Greenwich consultant, Bjorn Forfang, noting that many institutions are looking for new types of research services.

A sampling of other comments noted that some institutions wanted better electronic delivery of research and the ability to download spreadsheets.

"Targeted delivery of research [with] more active use of the Internet [is needed]," said one institution. "More efficient formats for electronic transfer of data," added another.

But all these technological enhancements do not mean anything to sell-side traders such as Norby.

"Ultimately, I need a reliable system which brings some value-added to my business and does not break down on me," he quipped.

Living the Island Life

It's a popular misconception that island life is always lazy and carefree. David Lunn head of equity and fixed-income trading at Bermuda International Securities in Bermuda argues that because of its exotic location, his desk is forced to work harder than its onshore competitors.

"We have to naturally price our services higher because we're an offshore firm," Lunn said. "But to do that, we have to make sure we provide better services."

About 600 miles off the coast of Virginia in Hamilton Bermuda's capital Bermuda International Securities is the trading subsidiary of the Bank of Bermuda. With 17 international offices, the Bank of Bermuda manages more than $6 billion in assets through its family of mutual funds.

Lunn and his team of four traders provide execution services for the Bank of Bermuda's portfolio managers. The desk also trades for the bank's clients pension funds, insurance companies, corporations and high net-worth individuals.

Because the desk executes orders for all types of international investments from equities and bonds to currencies and commodities Lunn's team of native Bermudans must be disciplined in markets all over the world.

"We spend a lot of time cross training on the desk," he said. "It's not a simple process. It takes a veteran trader about two years to learn this business."

Even after completing the initial cross training, Lunn expects his traders to spend up to two hours every day reading about international market developments. Aside from executing orders, the desk has to understand how different settlement processes work.

"The task here is a lot more involved than your average Wall Street firm," Lunn said. "Our traders are so sharp because they have to learn so many markets inside and out. That adds such a higher level of service to the firm."

Settlement procedures are typically straightforward in countries with developed markets, like the U.S., Japan or the U.K., Lunn said. But when dealing with smaller markets, in countries like Malaysia or Indonesia, settlement issues can get decidedly more complex.

"Because we have to know so much about the markets around the world," Lunn added, "we become a storefront of knowledge at the bank. People direct a lot of questions to us that we have to be able to answer."

Averaging about 100 trades each day, Lunn estimates that 40 percent of his desk's transactions are in equities. The desk structures its workday around the U.S. markets, because a majority of its equity transactions are in U.S. securities. (Bermuda is one hour and thus one time zone ahead of Eastern Standard Time.)

"Our customers are more familiar with the U.S.," Lunn said. "The U.S. has the world's largest and most sophisticated markets, and it's closest to us geographically."

When a client wants to execute an order in a market open at an odd hour, Lunn said his traders have a responsibility to be on the desk to provide that service.

But usually, the desk will send a limit order to a market open during the night. The limit order ensures a customer an execution at a specified price, and it keeps a trader from having to sit on the desk during the night.

Aside from his trading responsibilities, Lunn's extensive background in the international fixed-income markets helps him manage his own bond portfolio.

Lunn was born in Bermuda, the son of an Irish-born policeman and an English nurse. He left the island in the early 1980s and settled in London, getting his start in the financial-services industry as a fixed-income salesman, first at a small firm and then at Bankers Trust.

He moved from London to Hong Kong in the late 1980s to join Kidder Peabody, where he was responsible for the fixed-income business in the firm's Asia Pacific division.

He worked in Hong Kong for more than six years, where he met and married his wife Dolores, an Irish citizen working for cosmetic company Estee Lauder. When she was pregnant with their first child four years ago, they quit their jobs and moved back to Bermuda.

"I wanted to go back to bring up my children" Lunn said. "I loved growing up in Bermuda, and I couldn't think of a better place to raise our family."

The couple now has two children son David and daughter Olivia and Lunn is again a devoted Bermudan rugby player, a sport he was forced to abandon in Hong Kong.

"Bermuda is a beautiful place to live, and I never feel I'm out of the loop at work," he said. "I still work for a firm that is globally sophisticated."

At Deadline

31(a) Breakthrough

The National Association of Securities Dealers has filed a proposal with the Securities and Exchange Commission seeking relief on Nasdaq 31(a) transaction fees, according to reliable sources in Washington. The proposal, approved by the NASD's board of governors, seeks a reduction of up to $16 million, based on current trade volume. The reductions would be triggered by counting a typical riskless principal trade, involving two transactions, simply as a single trade. In addition, the rule seeks to create a step-out function which would result in single prints, instead of multiple prints, on limit-order business.

Frank Zarb, chairman and chief executive of the NASD, hinted that 31(a) relief is in the air. "I wouldn't be surprised if you see a rule that begins to fix it," Zarb told Traders Magazine's Washington editor Jeffrey L. Winograd. For its part, the SEC was more forthcoming. Richard Lindsey, the SEC's director of market regulation, told our man: "I believe that the [NASD] board voted, and I expect a rule-filing soon."

Meanwhile, on Capitol Hill, lobbyists fighting for relief on 31(a) transaction fees are pounding the pavement. Sen. Judd Gregg (R-N.H.), chairman of the Senate Appropriations Commerce, Justice, State and Judiciary Subcommittee, recently complained about legislative attempts to reduce fees.

Education

Two of the most noted finance academics are forming a new learning institute for buy-side and sell-side traders. Robert Schwartz and Robert Wood, finance professors at Baruch College and the University of Memphis respectively, are collaborating with communications expert Douglas Parrillo on the newly-formed Security Traders Institute (STI). Parrillo is a former senior vice president of corporate communications at the National Association of Securities Dealers.

The primary goal of STI is to provide rookies and veterans of the trading trenches instruction on how to develop and perfect their professional skills.

Courses will cover the rules and regulations of equity trading. STI said it will announce a schedule for its planned courses in the U.S. later this year. STI said it will also be active in the new Series 55 equity-trader examinations.

OptiMark Hoopla

The Bank of New York's BNY ESI & Co. has signed an agreement with OptiMark Technologies to be a designated broker of the OptiMark Trading System, making it the first consent agreement announced by OptiMark, which is now based in Jersey City, N.J.

While OptiMark's implementation is still pending, the agreement with BNY ESI does give OptiMark some bragging rights. BNY ESI, a separate brokerage affiliate of The Bank of New York, and the successor of ESI Securities Company, has been an agency broker for more than two decades.

OptiMark is designed to allow buyers and sellers to represent anonymously, and in a non-disclosed manner, their willingness to trade over a continuous range of prices and sizes based on a mutual-satisfaction profile. Some 140 institutional customers, handling more than $2 trillion in annual equity-trading volume, have made arrangements for direct links with OptiMark.

Year 2000

Richard Ketchum, the National Association of Securities Dealers president, told Wall Street firms that Year-2000 horror stories are not fiction. In fact, the horrible truth is that the possibility of firms missing their deadlines for their Year-2000 compliance is looming large.

"There is a long and venerated tradition of missing information technology (IT) deadlines, not just in our industry but across the board," Ketchum said in prepared remarks for NASD Regulation's annual spring conference. Missing deadlines for Year-2000 compliance could spell major problems, such as botched trade reporting.

Further compounding his fears, Ketchum said that an NASD survey on Year-2000 compliance showed that only 40 percent of NASD member firms are more than half through their Year-2000 projects. Firms are spending heavily on Year 2000. Ketchum said IT managers have indicated that Year-2000 compliance will consume about 60 percent of their budgets.

NASD’s Battle on Primary Market-Making Rules Complex New Standards Raising Concern Among Nasdaq T

Citing convoluted language, the use of difficult formulae and a need for more testing, several Nasdaq trading firms have slammed the National Association of Securities Dealers' proposed new standards for primary market makers.

With the advent of the order handling rules, the original standards were shelved because old market-maker evaluations were unreliable. One standard, for instance, required market-maker spreads to be no greater than 102 percent of the average spread.

But it was practically impossible to measure when a market makers' quote change was driven by a customer order, entered and later canceled without an execution, making it difficult for desks to meet the 102 percent parameter, according to one major trading desk.

Since the order handling rules, all market makers have been designated primary market makers. The NASD's effort to impose new standards, however, is facing stiff opposition from some firms. Firms have complained about insufficient time to conduct independent analyses, and have expressed trouble understanding the NASD's primary market-making criteria for net-liquidity ratios, proportionate volume and proportionate trades.

Extended Comment Period

The NASD extended the public-comment deadline for the standards from May 1 to the end of May. In comment letters filed with the Securities and Exchange Commission before May 1, several firms blasted the NASD.

Wall Street investment-banking giant Morgan Stanley, Dean Witter, Discover & Co. urged the NASD to withhold approval of its pilot program for the new standards until the NASD submitted "clarifying language to assist firms in making an independent evaluation of its [primary market-making] status, and provide member firms with an initial analysis of its [primary market-making] status on a stock-by-stock basis."

"Until we have a better understanding of the impact of the proposed amendments, we are unable to provide more substantive comment," the letter noted.

Morgan Stanley said the new standards, as drafted, were onerous and difficult to calculate. In addition, the limited comment period and the immediate effectiveness of the technical proposal did not afford members sufficient time to comprehend the consequences of the amendments.

Favors Small Minority

Jersey City-based M.H. Meyerson & Co. stated in a comment letter that the NASD proposal was "blatantly slanted in favor of a small minority of market makers."

In a follow-up letter, the firm linked the proposed standards to another NASD proposal for an integrated order-delivery and execution system.

"The feature of sponsored access [to the limit-order book] by non-members in itself is a terrific concept, provided it is not tied to primary market status," the Meyerson letter noted. "We implore you to use this recommendation without any status modifiers."

"In essence, the NASD has asked that the SEC approve a major restructuring of Nasdaq without affording the public sufficient time to understand, comment or test the proposed changes," stated a CS First Boston letter. More time was needed for industry participants most affected by the changes to "review and reflect" the proposed amendments, the letter added.

Plain English

New York-based CS First Boston was upset with the convoluted language of the NASD's proposal, and urged the association to consider an SEC initiative requiring brokerages to disclose invesment information to investors in understandable English. The investment-banking giant noted that the NASD's proposal requires "multiple footnotes to explain essential, yet perplexing phrases."

"While we understand the concerns raised by the SEC and the NASD regarding the need for more meaningful criteria for the designation of [primary market-making standards] and the concomitant exemption from the short-sale rule, we are very uncertain whether the proposal is the proper way to achieve this goal," noted a letter from Wall Street investment-banking giant J. P. Morgan & Co.

J. P. Morgan worried that the relatively complex formulae appear to require primary market makers to accept significant risks in times of severe market conditions.

"While it does not seem particularly improper to expect a market maker to satisfy its proportional share of trading in an up or down market to be deemed a primary market maker, requiring a minimum arbitrary level of trading against the trend of buying or selling may prove especially harsh in certain circumstances, potentially imposing significant risk on market makers," the J.P. Morgan letter added.

The new standards would also require a market maker to "engage in significant levels of such putative liquidity-building transactions while being limited in its ability to sell short in a down market," J. P. Morgan noted.

Consequently, a market maker trying to buy in a down market would be unable to first sell short to position itself to buy that stock. Thus, the market maker would have to buy first, hoping to sell before the market fell further, potentially making qualification as a primary market maker quite risky.

An NASD spokesman told Traders Magazine that the comment period was extended so industry participants could read and comment on the materials published.

New Home for the NASD in Ohio or N.Y.? Two Congressmen Speak Out!

If the National Association of Securities Dealers finally decides to move its headquarters from Washington, can we expect a bidding war that makes a plan for the New York Yankees to move to Manhattan pale in comparison?

NASD President Frank Zarb makes no secret of his dream to move part of the NASD to

New York's Times Square to heighten the association's public profile. But one of Washington's top legislators thinks Zarb should consider another location.

How about quiet Findlay, outside Columbus, Ohio, in his congressional district? wisecracked Rep. Michael Oxley (R-Ohio), chairman of the House Commerce Subcommittee on Finance and Hazardous Materials.

"It's in the northwest of Ohio, a very nice spot, with several golf courses, clean air, no traffic, no crime. And Toledo, just 30 miles away, has an international airport," he told Traders Magazine.

Rep. Thomas Manton (D-N.Y.), the ranking member on Oxley's panel and a quintessential New Yorker, thinks the Big Apple is still the perfect fit.

"I don't think there is any great advantage to being in the nation's

capital," he said, exchanging glances with Oxley. "But there is an advantage to being in New York where the markets are made."

"New York Mayor Rudolph W. Giuliani doesn't like raiding when it comes to athletic teams, but this is one where there would be a real natural fit," Manton added.

Oxley put in another pitch for humble Findlay. "The [NASD staffers] could actually just commute from New York," he joked.

Bleak Capitol Hill Outlook on 31(a) Fees

Lobbyists for U.S. exchanges are still pounding the pavement in the Senate, fighting for a reduction in Section 31(a) fees on Nasdaq transactions that could save dealers up to $20 million annually.

But prospects for a cut look bleak in the House, according to several sources who spoke to Traders Magazine. "Nothing is new here," said a Republican source who has closely followed the issue.

"I haven't heard of any additional activity," said a spokesman for Rep. Edward Markey (D-Mass.). "There doesn't seem to be any general sentiment for it."

"It's fairly difficult to make it happen," added the Markey aide, explaining that the legislation necessary to reduce the fees would follow too closely on the heels of the 1996 legislation which authorized Nasdaq transaction fees in the first instance. Section 31(a) fees fund the annual Securities and Exchange Commission budget.

The Senate

Meanwhile, the situation remains confusing in the Senate.

In late April, Nasdaq President Alfred R. Berkeley III fired off a strong letter to Senate Banking Committee Chairman, Sen. Alfonse D'Amato (R-N.Y.), in support of the Security Traders Association's proposal to slash fees on dealer-to-dealer trades.

Despite some speculation to the contrary, D'Amato maintained that he had not read Berkeley's letter.

Speculation that D'Amato may jump on the issue was fueled by a story in a weekly trade publication saying he was preparing to sponsor legislation. "That report was erroneous," a D'Amato aide told Traders Magazine.

The only official mention D'Amato has made on 31(a) fees appeared in a pro forma letter he sent several months ago to Sen. Peter Domenici (R-N.M.), chairman of the Senate Budget Committee. The letter outlined a number of issues the Senate Banking Committee examined for budgetary implications.

"He hasn't said anything else," said a banking-comASD proposal was "blatantly slanted in favor of a small minority of market makers."

Adminstration Officials

The issue may reemerge when Senate and House budget negotiators huddle with administration officials. If that happens, the president's Office of Management and Budget (OMB) is expected to add its voice. "I expect the OMB will vigorously oppose it," said a House source. "You know, technically it's a violation of the [balanced] budget agreement."

The major Senate stumbling block, as previously reported, remains Sen. Judd Gregg (R-N.H.), who heads the Senate Appropriations Subcommittee, with jurisdiction over the SEC. He is opposed to a fee cut.

Congressmen Claim a Victory In U.S. Decimal Stock Switch

A decimal-based U.S. stock system has moved one step closer to becoming a reality perhaps in the summer of 2000 thanks in part to the unrelenting efforts of Rep. Michael Oxley (R-Ohio) and Rep. Edward Markey (D-Mass.).

Holding a new General Accounting Office (GAO) report in one hand and a ream of letters from four exchanges, the National Association of Securities Dealers and the Securities and Exchange Commission in the other a triumphant Oxley announced at a Capitol Hill hearing that opponents of decimalization have been brought to their knees.

"With this, we will have completed our goal of bringing competition to stock pricing, modernizing the markets to the benefit of all investors," said Oxley, chairman of the House Commerce Subcommittee on Finance and Hazardous Materials.

Experts Agree

Many industry experts now agree that U.S. stock exchanges will switch from fractions to quoting stock prices in decimals sometime in 2000. The SEC is hoping for a July 2000 switch. September 2000 was the target date agreed upon during a private Feb. 27 meeting by a working group of equity and derivative market representatives in Washington.

The New York Stock Exchange said it is on target to quote in decimals by year's end. The Cincinnati Stock Exchange is planning to be ready by April 1999. And the Pacific Exchange said it will have all necessary systems finished by the end of September 1999.

The NASD and the American Stock Exchange appear to be dragging their heels. The NASD said it is committed to being ready in early 2000, while the AMEX is committed to a conversion in September 2000.

Technology Adjustments

The GAO report noted that the technology adjustments necessary to support a decimal-based pricing system are straightforward and relatively inexpensive. A study by the Newton, Mass.-based Tower Group, commissioned by the Securities Industry Association, estimated the systems changes at almost $170 million.

However, the report concedes that the technology concerns about Year-2000 computer remediation and the 1999 conversion to a single currency in much of Europe pose substantial barriers to decimal trading before 2000.

SEC Chairman Arthur Levitt, in a May 8 letter, stressed that the move to decimals is essential for keeping U.S. markets competitive with foreign markets.

But Levitt warned that a move in advance, or simultaneously, with Year-2000 testing would be imprudent. In addition, firms are working to comply with the NASD's Order Audit Trail System and the European currency switch.

The SIA is coordinating industry-wide conversion efforts, and legislators plan to study the SEC oversight of the massive project.

Common Cents

Oxley and Markey, with House Commerce Committee Chairman Rep. Thomas Bliley (R-Va.), began a legislative drive to mandate decimalization when they introduced the Common Cents Stock-Pricing Act last year. Passage of the bill would be moot if the industry itself moves voluntarily to a decimal system.

The Security Traders Association said it is pleased with the current developments. "I think all market participants are committed to producing the most competitive prices for investors, and we are convinced that competitive forces will ultimately produce the most competitively-priced markets, which is Oxley's objective," John N. Tognino, president of the STA, told Traders Magazine.

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