<s> A TRADING DESK’S VIEW OFMARKET QUALITY
A TRADING DESK’S VIEWOF MARKET QUALITY
edited by
Robert A. SchwartzZicklin School of Business, Baruch College, CUNY
John Aidan ByrneAntoinette ColaninnoZicklin School of Business, Baruch College, CUNY
KLUWER ACADEMIC PUBLISHERSNEW YORK, BOSTON, DORDRECHT, LONDON, MOSCOW
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In memory of my father, Fred J. Schwartz.
Contents
List of Participants
ix
Conference Sponsors
xiii
Preface
xv
Chapter 1: Recent Evidence on Market Quality
1
Chapter 2: Intra-Day Volatility: Friend or Foe?
35
Chapter 3: View from the Trading Desks
51
Chapter 4: View from an ECN
81
Chapter 5: Perspective of the Market Architects
89
Chapter 6: Does Best Execution Make Sense?
117
Chapter 7: Thoughts from a Former Regulator
139
Chapter 8: Volatility in U.S. and European Equity Markets: An AssessmentOf Market Quality151Participant Biographies
177
List of Participants
Theodore AronsonPaul BennettGeorge BodineAndrew Brooks
Managing PrincipalSenior Vice Presidentand Chief EconomistDirector of Trading
Aronson+Johnson+OrtizNew York Stock ExchangeGeneral Motors InvestmentManagement CorporationT. Rowe Price Associates
Vice President andHead of Equity TradingThomas CardelloMorgan StanleyManaging DirectorGlobal Head of EquityBarclays Global InvestorsMinder Chengand Currency TradingPresidentArchipelago Holdings LLCMichael CormackViktoria DalkoPresidentRICE InstituteTIAA-CREF InvestmentSenior ManagingPaul DavisDirectorManagement LLCNutmeg SecuritiesThomas DoyleInstitutionalSales/TraderChief Executive Officer Pipeline Trading SystemsFred Federspiel**At the time of the conference, Mr. Federspiel was Chief Executive Officer ofe-Xchange Advantage Corporation.Borsa ItalianaDirector of ResearchLuca Filippaand DevelopmentLubin School of Business,William FreundDirector, William C.Pace UniversityFreund Center for theStudy of EquityMarkets
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A Trading Desk’s View of Market Quality
Marc Gresack*Chief Executive Officer Glen Eagle Securities*At the time of the conference, Mr. Gresack was a strategic consultant at BrutLLC.Bloomberg Tradebook LLCDirector of ResearchSanjiv Guptaand StrategyJote & AssociatesNari JoteManagementConsultant and GlobalBusiness CoordinatorTIAA-CREF InvestmentSenior TraderChristopher KilleenManagementDavid KrellPresident and ChiefInternational SecuritiesExchangeExecutive OfficerAnanth Madhavan*Barclays Global InvestorsGlobal Head ofTrading Research* At the time of the conference, Ananth Madhavan was Managing Director ofResearch at ITG, Inc.Bernard L. MadoffMark MadoffDirector of ListedTradingInvestment SecuritiesJohn Malitzis*Citigroup Global MarketsSenior Vice Presidentand Associate GeneralCounsel*At the time of the conference, Mr. Malitzis was Vice President in theTransaction Services Department at the Nasdaq Stock Market.Seth MerrinLiquidnetChief ExecutiveOfficerRussell MonahanAmerican Stock ExchangeDirector of StrategicResearchAnthony NeubergerLondon Business SchoolAssociate Dean, Fulltime Masters inFinance ProgrammeAssistant Professor ofMontclair State UniversityDeniz OzenbasFinanceAmerican Stock ExchangeBrett RedfearnSenior Vice PresidentRichard Repetto*Associate DirectorSandler O’Neill & Partners,LP*At the time of the conference, Mr. Repetto was a Managing Director atPutnam Lovell.Michael RichterChief ExecutiveLime Brokerage LLCOfficerSharon Salamon*Director ofThomson FinancialInstitutional Equitiesfor Product
List of ParticipantsManagement*At the time of the conference, Ms. Salamon was the Senior Sales andMarketing Executive at NeoNet Securities.Richard Schenkman* Managing PartnerElm Tree Group LLC*At the time of the conference, Mr. Schenkman was Chief Executive Officer ofBrut LLC.Zicklin School ofSpeiser Professor ofRobert SchwartzBusiness, Baruch College,FinanceCUNYChief Executive OfficerWeeden & CompanyBarry SmallGeorge SofianosVice PresidentGoldman Sachs, Inc.Principal and Director ofKern Capital ManagementHolly StarkTradingJoel Steinmetz** At the time of the conference, Mr. Steinmetz was Senior Vice President forEquities, Instinet Corporation.Senior Vice PresidentInstinet CorporationNatan TiefenbrunManaging Director andCIBCBruce TurnerHead of U.S. EquityTradingIndependent Director andLaura Unger*Consultant*Ms. Unger is a former Commissioner of the U.S. Securities & ExchangeCommission.Plexus GroupWayne WagnerChairmanChairman, Department of Zicklin School ofAvner WolfBusiness, Baruch College,Economics and FinanceCUNYThe University ofRobert WoodDistinguished ProfessorMemphisof FinanceExchange LabPartnerSteven Wunsch
xi
Conference Sponsors
The American Stock ExchangeArchipelago, Inc.Brut, LLCInstinet CorporationInternational Securities ExchangeLiquidnet, Inc.Bernard L. Madoff Investment SecuritiesThe Nasdaq Stock Market, Inc.New York Stock ExchangePlexus GroupSecurity Traders AssociationWeeden & Company
Preface
This book is based on A Trading Desk’s View of Market Quality, aconference hosted by the Zicklin School of Business on April 30, 2002. Thetext includes the edited transcripts of each panel as well as separatepresentations by two distinguished industry officials, Joel Steinmetz, who atthe time was Senior Vice President, Equities, Instinet Corporation, andLaura Unger, formerly Acting Chairperson and Commissioner of the U.S.Securities and Exchange Commission.This book is not simply a historical record of the conference. It isalso an exposition of the complex issues raised by the industry experts andspeakers in attendance. Therefore, we introduced new material from followup interviews with many of the panelists so that the final result would be amore valuable document. Our intention was to examine the discussions witha critical eye, then modify or expand various sections to reflectcontemporary conditions. In addition, we have included a paper byOzenbas, Schwartz and Wood (see Chapter 8, page 151) that providesfurther analysis on the connection between market quality and intra-dayvolatility that was noted several times during the conference.1During the production process, we worked with the panelists, andtook pains not to put words in their mouths. They have all approved the finaldraft of the manuscript, and we thank them for their assistance and patience.We also express our heartfelt thanks to the sponsors who made this1
Chapter 8 was reprinted, with permission, from D. Ozenbas, R. Schwartz, and R. Wood,“Volatility in U.S. and European Equity Markets: An Assessment of Market Quality,”International Finance, Blackwell Publishers, Volume 5 Number 3, Winter 2002, pp. 437461.
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conference possible (see page xiii). Their funding and, more importantly,endorsement of our mission, are deeply appreciated. In addition, a numberof people have been helpful in preparing this manuscript. In particular, wethank Dror Parnes and Faisal Aslam for their help, and Avner Wolf,chairman of Baruch’s Economics and Finance Department, for his constantsupport and encouragement.The Baruch conference focused on market quality, right from the firingline, at the desks where trades are made and the costs of trading are incurred.After we turned to ‘market quality’ for the focus of the conference, asurprising number of people asked, ‘What is market quality?’ as if we hadcoined a new term. This was surprising, in part because ‘market quality’ isthe name of a major Nasdaq committee. That is where we got the term. It isan excellent term, but what does it mean?‘Market quality’ is a broad concept. How efficient are our markets?How tight, or narrow, are spreads? Is liquidity deep? How low are tradingcosts? Is there connectivity between liquidity pools? How accurate is pricediscovery? These are only some of the important questions. Another thoughtthat I have been focusing on – and I hear that others are focusing on – isquantity discovery: getting orders out of traders’ pockets, onto the table, andmaking the trades.‘Market quality’ also relates to the magnitude of price volatility thatwe see in the course of a trading day. I have said at some of our previousconferences that I think too much attention is paid to the size of bid-askspreads, and that not enough attention is paid to the level of intra-day pricevolatility. I would like to suggest that the accentuation of intra-day volatilityis a comprehensive, inverse indication of market quality. Whether the termhas been used widely or not, we have been debating issues about marketquality since at least the 1975 Securities Act amendments. What is theobjective of the debate? What are we trying to accomplish? We have talkedabout tight spreads, acceptable transparency, consolidation, connectivity andcompetition. Market quality encompasses all of these issues and more. Atthe heart of these discussions are questions about market structure and theability of participants to obtain best execution. Best execution has typicallybeen viewed as a responsibility placed on individual traders who handleorders in an agency capacity. Market centers share a best executionobligation. If we want participants as a group to get better executions, wemust offer them better market structure.Our hope with the conference and this volume is to shed new lighton some old issues. The issues do not change, but the light that we see themin does. Perhaps a fresh perspective will help us to obtain more answersand, ultimately, to achieve a more efficient market structure.
Robert A. Schwartz
CHAPTER 1: RECENT EVIDENCE ON MARKETQUALITYModerator – Paul Bennett, Senior Vice President and Chief Economist,New York Stock ExchangeAnthony Neuberger, Associate Dean, Full-time Masters in Finance Programme,London Business SchoolDeniz Ozenbas, Assistant Professor of Finance, Montclair State UniversityRobert Schwartz, Speiser Professor of Finance, Zicklin School of Business, BaruchCollege, CUNYRobert Wood, Distinguished Professor of Finance, The University of Memphis
PAUL BENNETT: Like many of you, I have been wrestling with theconcept of market quality. It is a complicated and difficult topic. Even ifyou narrow the perspective to just the trader’s viewpoint, it is hard to assessmarket quality. Part of the difficulty is that various markets offer differentqualities. Some trading systems offer blinding speed. Others offer tradersthe ability to negotiate anonymously. Some offer face-to-face trading. Fordifferent types of transactions and strategies, each of these features can be animportant characteristic.You have to figure out what you want. My daughters used to love a kindof toothpaste that tastes like bubble gum. That is quality for them. Now I amtrying to figure out whether or not to get the kind that makes your teethreally white - does it have sand in it? The bottom line is, quality is in the eyeof the beholder. You have to figure out what your objective is.If you do settle on a quality measure, you must make sure that you aretruly measuring what you think you are measuring. I have cooked up a littleexample of this. Suppose you have two markets, A and B. Market A offersspeed, and basically what you see in the quotes is what you get. Market B isa little more complicated; it has some reserve orders. With reserve ordersallowed for, you do not know what orders might be in the market but notdisplayed. If you hit market A with a relatively large order, or if somebodyelse gets there first, you will walk up the book. In market B, you might get
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A Trading Desk’s View of Market Quality
more of your order filled at a better price than you expected. So, what dopeople do?Some will avoid market A, especially those participants with largeorders. Consequently, posted spreads, a common measure of market quality,might be small on market A, but market A may not offer much depth. Onmarket B, on the other hand, posted spreads may be wider, but market Bmay offer more depth and liquidity. This is an identification problem. Youare not really looking at the difference in market quality; you are looking atthe difference in the types of orders that each market attracts. This is part ofwhy it is so hard to assess market quality.The Securities and Exchange Commission has weighed in on this topic.The Commission is having various dealers and stock exchanges publishsomething called, in Washingtonese, 11 Ac 1-5.2 This is a huge data set that Iam sure a lot of people will try to do research on. It measures things likeeffective spreads, and price improvement in different market centers. It is anexcellent initiative that the New York Stock Exchange has always been verysupportive of. With it, we should be able to compare market quality.Most of us can tell if our own market is getting better. But this does notmean that we are able to contrast one market with another. The problem Isee with any comparison is making sure that it is an apples-to-applescontrast. For example, in the research department of the New York StockExchange, we compute data on behalf of all the specialist firms. It is a bigjob. There are a lot of uncertainties. You want to make sure that you aredoing it right. Sometimes we hire an outside data processor to do thenumbers. They always come up with different results, and sometimes thedifference is sizable.So, when I look at the various market websites that are out there, Iwonder if the markets are really comparable. That is something the SEC isgoing to have to reconcile. All of those market quality measures should beaudited, or something should be done, to make sure that they really arecomparable. The moral is that, even under the best of circumstances,effectively assessing market quality requires a lot of sustained effort, andsome critical thinking.With that, let me turn the floor over to Anthony Neuberger who is goingto discuss his new study.
2
The Securities and Exchange Commission Final Rule: Disclosure of Order Execution andRouting Practices, 17 C.F.R. pt. 240, Release No. 34-43590; File No. S7-16-00. UnderRule 11Ac1-5, market centers that trade national market system securities will be requiredto make available to the public monthly electronic reports that include uniform statisticalmeasures of execution quality.
Chapter 1: Recent Evidence on Market Quality
3
ANTHONY NEUBERGER: I want to talk about the precursors tomarket quality, the economic forces that drive market quality. The quality ofa market is driven to a large extent by the economic pressures on traders tominimize transaction costs. To understand market quality, we need tounderstand the incentives and structures that encourage the trading desk tominimize costs. Are these effective, or are they defective in some way?The incentives on fund managers have been fiercely debated in the U.K.following the publication of the Myners Report.3 But this is not aspecifically British preoccupation, and the debate in the U.K. may usefullyilluminate some issues here in the U.S. Indeed, this would not be the firsttime that discussion on one side of the Atlantic illumined debate on the otherside.First, some background on the U.K. debate. In 2000 the U.K.Government launched an inquiry to investigate the factors impedingfinancial institutions from investing more heavily in venture capital. It wasessentially a one-man inquiry carried out by Paul Myners, with some supportfrom civil servants. Paul Myners is the chairman of one of the major U.K.fund management firms. He was asked in particular whether the U.K. couldlearn from the much more successful U.S. experience.The report was wide-ranging, and many of its conclusions were generallyaccepted. But Myners came up with one recommendation that caused greatcontroversy. That recommendation was unexpected, given the terms ofreference of the study. He said that the traditional fund managementcontract did not give managers adequate incentives to control and minimizetransaction costs. He recommended that broking commissions and othercharges should be borne not by the plan sponsor, as is standard practice inthe U.K. and elsewhere, but by the fund manager.This recommendation sparked a huge controversy. The Government,while accepting the report in full on publication, put it out for consultation.The fund management industry commissioned a study by myself and mycolleague Professor Dick Brealey,4 on the impact of the Mynersrecommendation.3
In 2000 Gordon Brown, the Chancellor of the Exchequer of the United Kingdom, askedPaul Myners, Chairman of Gartmore Investment Management, to investigate possibledistortions in institutional investment decision-making. Mr. Myners published his reporttitled “Myners Review of Institutional Investment: Final Report,” on March 6, 2001(www.hmtreasury.gov.uk/mediastore/otherfiles/31.pdf).
4
See Richard A. Brealey and Anthony Neuberger, “The Treatment of InvestmentManagement Fees and Commission Payments: An Examination of the RecommendationsContained in the Myners Report,” available athttp://www.investmentfunds.org.uk/investmentuk/about_ima/reports/brealey.pdf.
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In the face of industry opposition, the Government did retreat somewhatfrom the Myners proposal, and asked the industry to come up withalternative proposals to meet Paul Myners’ criticisms. In response, the fundmanagement industry has drawn up a code of conduct on transparency.I want to draw on the work that Dick Brealey and I did to look at thepressures on fund managers to manage transaction costs in the best interestsof their client. I will start by showing evidence on the size of transactioncosts in the U.K. before examining the way that fund managers are rewardedfor managing funds.In our study, we surveyed fund managers about the way they managefunds, the costs and other areas. Figures vary hugely from fund manager tofund manager. To give some idea of what is typical, I will quote mediannumbers (see Exhibit 1).
Exhibit 1. How Large Are the Costs?
We focused our survey on U.K. actively managed equity portfolios sothat we could standardize across fund managers. The median fund size is$300m. The median level of total transaction costs is 1.3% per year (130basis points). Of this, the broking commissions that had so exercisedMyners amount to 12 basis points (about 10% of the total). Management
Chapter 1: Recent Evidence on Market Quality
5
fees are 30 basis points. The government itself accounts for a further 25basis points, largely in the form of stamp duty, which is a tax on turnover.The remainder, half the total cost, is market impact cost. The figures onmarket impact come from a survey by the consultants Plexus Group. I amgoing to talk some more about the measurement of market impact costs atthe end of this presentation but, for the moment, I want to note that directcosts are only one component of total transaction costs. I want to emphasizethat measures to cut explicit costs will not be useful if they are offset by anincrease in implicit costs.
Exhibit 2. There Are Substantial Variations
As I said, these are median figures, and the range across portfoliomanagers is wide (see Exhibit 2). Management fees in our sample rangefrom 17 basis points to 50 basis points. This is not the result of just one ortwo outliers. The inter-quartile range is also wide, being 25-35 basis points.Commission rates for active management vary widely too, with the interquartile range being 13-20 basis points. I had assumed that competitionwould lead to them being reasonably standardized, but I presume that thisreflects the different levels of service being expected by different managers– it does not reflect the size of funds.
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For commission costs per dollar of assets under management per year(rather than per dollar transacted), the inter-quartile range is even wider at 417 basis points. This reflects the enormous variations in turnover acrossmanagers. We can conclude that transaction costs, both explicit andimplicit, are large compared with fund management fees, and they also varywidely across broadly similar funds.The size of transaction costs and their variation are interesting, but theydo not in themselves clearly indicate that there are any problems in therelationship between fund managers and their clients. Indeed, on the face ofit, this seems to be an industry where competition would be expected to do apretty effective job at arriving at an optimal contract. Clients are not privateindividuals who may be easily misled, but trustees with some degree ofsophistication. In many cases they are advised by consultants. Fundmanagement itself is not a particularly arcane or difficult subject. All clientsare ultimately interested in one thing – the return on the fund – and returnsare easy to measure. The fund management industry is fragmented, andentry costs are low, so there does not seem to be an issue of monopolypower. Switching costs between fund managers are pretty low.However, there are some indications that have led Myners (and otherobservers) to worry that there might be real problems. While softcommissions, which are referred to as soft dollars in the U.S., do not seem tobe particularly large in the U.K. – we estimate them in our report as equatingto around 1% of management fees – they do give an incentive to fundmanagers to incur commission charges on behalf of the fund, and then to usethe soft commissions to pay for services they would otherwise fund out oftheir own pockets. Regulations that force the manager to use softcommissions only on services of direct benefit to the client do not mitigatethis problem. Soft commissions do not appear to be in the best interests ofthe ultimate clients.The existence of commission recapture arrangements is another cause forconcern. It is hard to see how the practice of paying a commission and thenrebating it or channeling it to some other party is consistent with there beingan open, transparent market for fund management, brokerage and executionservices.It was also clear to Myners, and my investigations with Dick Brealeyconfirmed this, that plan sponsors have very little awareness of the level oftransaction costs incurred by their funds. The sponsors were very muchaware of what they paid in management fees, but not of the costs ofcommission or the costs of market impact, which were incurred on theirbehalf. They lack crucial information to judge these costs. Very fewsponsors, for example, get any consolidated information about thecommission charges which are paid on their trades.
Chapter 1: Recent Evidence on Market Quality
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Others have pointed to the large amount of research of questionablequality released by brokers, which does not seem to be greatly valued bytheir clients, as a sign that there is some form of market failure. Others havenoted that low cost transaction systems have failed to get a large marketshare despite substantial apparent cost advantage (particularly true inEurope, but also to some extent in the U.S.). This suggests, they argue, thatthe investment managers may not have strong incentives to minimize tradingcosts.There are some indications that managers are not transacting asefficiently as they could. What are the defects in the market for fundmanagement services that prevent clients from forcing managers to tradeefficiently?I believe the answer is that it is hard for the client to distinguish amanager who trades efficiently from his less efficient competitor. That maysound implausible. There are a number of consulting firms that analyzetransaction costs. They sell their services to both sponsors and fundmanagers. But the measurement of transaction costs, particularly of marketimpact costs, is not easy. It is even more difficult to interpret the measuresand to decide whether the costs are excessive.Faced with this problem, the client may well decide just to monitor thenumber that is of ultimate interest – the net return after all costs. It is easy tomeasure. The client may well reason that if incentives are in place toencourage the manager to maximize net returns, these same incentives willencourage the manager to trade efficiently.This argument suggests that we should look at the relationship betweenthe client and the manager to see what incentives it creates. If the incentivesare too weak, one could investigate whether alternative structures might leadto better results.We assume that managers are motivated entirely by their economic selfinterest. This is a simplification. Managers are constrained by regulation,and by their own ethical and professional standards, and these doubtless doencourage managers to trade efficiently whatever the formal contractualarrangements. But both sides in the argument on the Myners Reportimplicitly accepted that it would not be enough to rely on theprofessionalism and goodwill of the manager. The contract needs to bedesigned to encourage appropriate behavior.We can analyze the situation using the classical economic framework ofthe principal agent problem. The client has engaged the manager to managethe portfolio on his behalf. The client can readily monitor the outputs – netreturns – and can also monitor the inputs -- what the fund manager isactually doing. But it is hard for the client to tell whether the manager isexerting maximum effort and using all possible skill.
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A Trading Desk’s View of Market Quality
Let us start by looking at the incentives relating to output. These seemrather weak. The ideal contract would make the manager manage the fundwith as much care and effort as if it were his own money. The managerwould then be prepared to spend up to $1 in effort, or out of his own pocket,if it could increase the size of the fund by $1. Now, the median fee foractive fund management in our survey is 30 basis points. This does give thefund manager some incentive to make the fund grow because the managerreceives 30 basis points on any growth in the fund. But the incentive is veryweak. It would not be worth spending more than one dollar of one’s ownmoney as a fund manager unless it is likely to make the size of the fundgrow by at least $300.But the argument is incomplete. The main economic incentive on thefund manager to work hard is not the fee on the increased size of theportfolio, but the fact that he is liable to be fired if the fund under-performs.To quantify this incentive, we built a simple model. We assumed thatmanagers get sacked if they under-perform their peer group over a period ofseven years. They then lose the profit element of future fees on thatportfolio, which we estimate at 10 basis points per year. But performancedepends only partly on skill. Chance is also a factor. The manager thereforehas to decide whether to exert additional effort to improve the expected outturn, knowing that he may still be unlucky and lose the mandate.Putting in plausible parameters, we concluded that the threat of losing themandate does sharpen the incentive to exert effort. It is now worth themanager spending a dollar if the fund value increases by 17 dollars. This isa great improvement on the 1:300 ratio we estimated before, but a long wayfrom the 1:1 ratio that is optimal.Could changes to the management contract do more to improveincentives? One obvious improvement is to tie fees to performance. Thiscertainly sharpens the incentives, but also shifts risk from the client to themanager. The client is highly capitalized and has a high tolerance for risk.The fund manager has capital that is a small percentage of funds undermanagement and is highly risk averse. It becomes very inefficient to shiftmuch risk to the manager.An alternative is to base the manager’s fee much more heavily on thosecomponents of the return that are more directly under the manager’s control.For example, you could, as Paul Myners proposes, give the manager a higherfee, but require him to pay all commissions on the grounds that these aremore fully under the manager’s control. This removes the incentive thatcurrently exists to get research done by the broker rather than in-house. (In astandard contract the costs of broker research are met out of commission,and that is paid out of the fund rather than out of the manager’s pocket). Butit creates new perverse incentives. If the fund has to trade a large block of
Chapter 1: Recent Evidence on Market Quality
9
stock, then, under a traditional fund management contract, the agent’sincentives are to trade in such a way as to minimize the costs to the fund. Ifit is advantageous to the client to pay a broker commission to work the orderover a long period rather than to do it as a single block trade with a marketmaker, the agent will do so. If the agent has to pay the broker’s commissionhowever, the agent will have an incentive to trade in a way that minimizescommission payments.No contractual form is perfect. All contracts involve trade-offs. Weexamined the empirical evidence to see whether it provides a guide towardsa better contract structure, but it is not possible to draw any strongconclusions. The standard fund management contract – commissions borneby the fund, fee as a proportion of funds under management – is nearuniversal. This makes it difficult to compare the effects of differentcontractual regimes. It also suggests that the contract is unlikely to beseverely sub-optimal. Hedge funds, where managers tend to have muchstronger incentives to maximize net returns, spend more on commissions.Our survey provides weak statistical evidence that funds that are managedin-house spend more on commissions.We concluded that the traditional contractual form provides rather weakincentives to manage transaction costs efficiently, that alternative contractdesigns could remove some of the undesirable incentive effects of thecurrent system, but that they would do so only by creating new incentiveproblems. We found little evidence to suggest that one particular contractualform is preferable. Indeed it seems unlikely that there is a single form ofcontract that is optimal for all funds.The incentive problem cannot be solved purely by concentrating on theoutputs – the net returns. To mitigate the incentive problems, clients need tolook at the inputs. In particular, they must monitor the activities andperformance of their fund managers. Understanding the managers’ policiestowards commission payments is an essential part of this task. According toour survey, few plan sponsors receive information from their managers onthese payments. We argue that this is unsatisfactory.The U.K. fund management industry has now developed a code ofpractice on transparency. Clients will be regularly informed on managers’policies on commissions and other explicit charges, and will be told howmuch has been paid out of the fund. But monitoring the trading efficiency ofa manager goes beyond the measurement and comparison of explicit costs.As we have seen, implicit costs, notably market impact costs, aregenerally larger than direct costs, and they are hard to measure. To givesome idea of the problem, consider the following. Two well-respectedconsulting firms put out regular figures on transaction costs in differentmarkets using their own definitions of transaction costs.
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Exhibit 3. Execution Costs in Various Countries
As shown by Exhibit 3 above, there is reasonable agreement aboutcommission levels, but the two sets of figures on implicit costs differenormously both in their absolute level and in their ranking of countries.These differences are due to the way in which they define transaction costs.But even if there were a general agreement on the appropriate way ofdefining transaction costs, it is difficult to use it as a measure of themanager’s skill. A manager who is following a momentum strategy isbound to experience higher transaction costs than a value trader, whateverthe relative trading skill of the two managers.I conclude that market quality does depend, at least in part, on thepressures on fund managers to trade efficiently. The conventional fundmanagement contract does not give the manager very strong incentives to dothis. Changing the contract