适应贸易场馆管理标准的提高

© Oliver WymanREGULATORS ARE RAISING THE BAR ON TRADING VENUEMANAGEMENT AND SURVEILLANCE DATACONTROLSRegulators are increasing their scrutiny of firms to ensure that they are capturing all tradingvenues and trading activity in their surveillance programs. As with recent regulatory actionrelating to e-comms recordkeeping failures, regulators have shown that they are inclined toenforce substantial fines even in cases where immediate market or customer harm may notbeapparent.Trade data has always been critical for an effective trade surveillance program, but certainmarket abuse risks (for example, spoofing) can only be detected by analyzing order data asthe manipulation happens before the trade is executed. Surveillance teams mustgathercomplete details of orders placed, cancelled or amended, requests for quotes and indicationsof interest, which is usually not captured in the firm’s trading systems and often requires thatfirms receive the data from the trading venues directly. The rapid proliferation of alternativetrading venues, and the shift to electronic trading outside of equities has exacerbated thechallenge for firms to maintain a complete inventory of trading activity and ensure that thesurveillance program is operating with complete, accurate and timelydata.Regulatory focus on trading venues management and data management is not new. Manyfirms have already invested extensively in trading venue inventories and data governanceand controls. However, recent regulatory scrutiny should serve as a wake-up call forfirmsto urgently re-examine and, where necessary, enhance their programs given the particularchallenges describedabove.FIRMS SHOULD ASSESS THEIR SURVEILLANCE PROGRAMSTO ADDRESS INCREASEDSTANDARDSFirms should evaluate their surveillance programs to ensure they effectively manage tradingvenue inventories, maintain clear data lineage and automated controls, and review theirgovernance and roles and responsibilities between 1stLine of Defense (1LOD) and 2ndLine ofDefense (2LOD) to ensure adequate oversight and ownership. When assessing thestrengthof their surveillance program, firms should consider these keyareas: © Oliver WymanFIRMS SHOULD TAKE IMMEDIATE ACTIONS TO MITIGATESURVEILLANCEGAPSIt is important for firms to take immediate actions to stabilize the current state of the tradingactivity they are capturing in their surveillance program. These actions include confirmingthetrading venue inventory and implementing approval processes and governance to ensurethese inventories stay up-to-date. Additionally, firms should strengthen the controls arounddata in their program and clarify roles and responsibilities across 1LOD and 2LOD to ensurethere is proper governance of the venues goingforward.CONFIRM THERE IS A COMPREHENSIVE TRADING VENUE INVENTORY ANDSURVEILLANCECOVERAGEMany firms typically have a trading venue inventory, but it is important to ensure thisinventory is up-to-date and complete. Information required to build a full tradingvenueis often dispersed across both 1LOD (for example, trading desks, Operations) and 2LODteams (for example, Compliance, Third-Party Risk Management). When compiling yourinventory, make sureto:•Catalog a complete and comprehensive listthrough a questionnaire developed for eachtrading desk to confirm the products they are trading, type of trading activity, venuesbeing used and how they are accessing each venue. Supervisors of the tradingdeskswill need to attest to the accuracy of the information the traders areproviding.•Perform a surveillance risk assessment of each trading venuefor potential marketabuse, following the firm’s surveillance risk assessment procedures. Firms shoulddevelop plans to address any gaps in data or surveillance coverage throughmodelsor compensatingcontrols.•Identify and source data from trading venuesthat are required to address market abuserisks into the surveillance platform(s). Firms should verify that the data from thosevenuesis being sourced for surveillance. Firms are advised to establish a risk-based plan foracquiring trading venue data, as obtaining this data from vendors may requiretime.Where gaps are identified, a rapid assessment should take place to determine how long itwould take to capture the activity, and whether the traders need to cease using the venueuntil appropriate controls are put inplace. © Oliver WymanESTABLISH TRADING VENUE GOVERNANCE, OWNERSHIP AND APPROVALPROCESSESOnce firms have established a trading venue inventory, they should establish a cross-disciplinary and cross LOD governance structure to manage and approve anychangesto the inventory. A trading venue governance forum or committee should be establishedto oversee and approve changes to trading venues (for example, new venues, changes toaccess). These committees should include senior representatives from Compliance, 1LODtrading teams, Technology, Operations, Data Governance and Third-Party Risk Managementto ensure the appropriate level of Senior Management oversigh