5.1 Annex A contains our detailed cost-benefit analysis of the imposition of the
Standards.
5.2 The main benefits we foresee from implementing the Standards are:
• greater use of ATSs generally, arising from increased confidence among
potential users that operators comply with good practice;
• increased competition between ATSs and between ATSs and other
execution venues (such as recognised investment exchanges or regulated
markets);
• greater competition between intermediaries on quoted spreads and on
method and timeliness of execution;
• an increase in informational efficiency, which will result in a lessening of
trading in transparent markets on the basis of information about trades
only known to direct users of opaque ATSs;
• an expanded market for order, quote and trade information and the
consolidation of this information with similar information from other
execution venues; and
• a reduction in the risk of clients mis-buying ATS services and securities
generally.
5.3 We think the main potential costs of implementing the Standards would be as
follows:
• costs to ATSs, in particular:
a) implementation costs; and
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b) potentially, costs associated with loss of business, as users who seek to
continue to trade in secrecy move their business from ATSs to other
trading venues including voice brokers and trading platforms in
offshore jurisdictions;
• user costs, particularly:
a) trading costs to firms (whether direct or indirect users of ATSs) arising
from potential ‘leakage’ of information about large positions to the
market generally via transparency requirements and consequent
market movements; and
b) possibly, higher trading costs arising from a reduction in liquidity on
ATSs, if there is significant diversion of order flow away from ATSs
and towards more costly execution platforms;
• potential market impacts, specifically:
a) a lesser number of trades conducted overall if trading costs (including
costs arising from market movements) increase appreciably; and
b) diminished variety of services on offer as similar transparency and
other standards lower service differentiation between ATSs and
between ATSs and exchanges; and
• FSA costs including supervisory and policy costs.
5.4 For implementation costs to firms, we estimate the cost of the Standards for
each firm as within the ranges £35,400–£187,000 one-off costs, and
£15,040–£63,840 per annum. We consider the likely costs for commodities
firms, service companies and other kinds of firms operating ATSs to be
similar.
5.5 On balance, we believe that the benefits of imposing the Standards would
outweigh the costs.
Q 5.1 Do you have any comment on the cost-benefit analysis contained
in Annex A?