vice president, risk solutions, SunGard's capital markets business

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Risk Management: Conferences, Convergence and Catastrophe

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This blog post was originally published on TabbFORUM.

Late October 2012 saw an RMA conference on risk management in Dallas, the annual FIA conference in Chicago, and a catastrophic natural disaster in and around New York. While these were separate events with very different impact levels, all three were connected by the complexity of modern risk management, what it means, and how its outputs can be understood and used.


Conversation at the Risk Management Association event in Dallas was focused largely on developing, implementing and managing a risk appetite within a financial institution. This tackled from multiple angles, including liquidity risk, market risk and credit risk. The recurring theme of the discussions was the difficulty in developing a framework that works both top-down from an enterprise-wide risk tolerance perspective, and bottom-up from an individual risk contributor’s perspective.

Risk appetite definitions ranged across benchmarked “active” risk budgeting (VaR against benchmarks), economic capital, collateral and funding costs, VaR and VaR shortfall. As has been noted before, it is interesting that in the aftermath of a financial crisis which saw VaR receive critical attention, its use is expanding into bilateral calculation of collateral and central clearing margins.


It was those same central clearing margins that took center stage at Chicago’s Futures Industry Association conference. As a business more used to exact calculations built on lot sizes and observable prices, the relative complexity, convexity and simulation-based margining of interest rate swaps are causing many to strengthen their technical architecture and approach. As the single largest OTC derivative class heads to the margin model, FCMs and their clients are becoming familiar with historic simulation, decay factors and look-back periods. At the same time, the margin posted is looking more and more like an alternative for economic capital, even using the same techniques to generate the number.

The VaR number itself, of course, is essentially predicting the minimum loss that would be expected to happen at the specified percentile. For example, a 99th percent VaR predicts the minimum loss that should be expected to happen once in every hundred days.

New York, New Jersey, and Neighboring Areas

As the conferences in Dallas and Chicago were happening, the tri-state area of New York, New Jersey and Connecticut were actually experiencing a devastating weather event.

The parallels between a VaR calculation and this “perfect storm” are as inescapable as they are shocking. Defined variously as a tail event or a 2.33 standard deviation event, the VaR cases are typically characterized by multiple loss-causing events occurring within the same simulation. This is a low percentile by definition, but has an extremely large impact. In terms of what faced the northeast U.S., a high tide and a hurricane create the worst possible outcome for the shoreline areas. Here, risk management hits closer to home.

Risk management is a control function that mitigates, to a degree, the impact of the extremes. It is also a fact that events deep in the tail are often uncontrollable.  It was with shock that reports of Hurricane Sandy’s effects were viewed, and with a sense of humility that the aftermath restorations are being tackled.

Risk can often be seen as a dry academic subject, as more theory than reality, and the discussions in Dallas and Chicago could lend weight to that opinion. However, the events in the tri-state area graphically and violently demonstrated that tail events do happen, and enormous damage can be caused when extremes collide.

While you’re here…

head of product management, Front Arena, SunGard's capital markets business

Success in Middle East Trading: Keeping it Simple

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At the recent SunGard Dubai City Day, panelists at the session entitled “Leading from the Front: the Ever-changing Capital Markets Arena” had a very interesting discussion about how institutions, particularly those in the Middle East, can compete in times of rapid global regulatory and technological change.

New regulations, such as Dodd-Frank in the U.S. and MiFID II Europe, are focused on systemic risk and transparency. However, in the Middle East, systemic risks are typically well-contained and transparency almost entirely refers to OTC instruments which are not prevalent in the region. Consequently, the new regulations in other regions will have minimal impact in the Middle East.

It was noted that there are differences between regional consumption models: the U.S. has largely financed consumption with debt, European consumption has been mostly savings-financed and China appears to be growth-financed.

In contrast, the Middle East, rich in both natural resources and cash, has financed little of its consumption with debt. There has been discussion of the idea that the region should combine different consumption models, financing with a mixture of debt, savings and growth. There was a belief that the choice of the correct model will ensure a lower level of regulation compared to other countries.

There is a broad, ongoing discussion about regulation in the Middle East markets. The panelists emphasized the importance of balance and pointed to a concern over “regulatory inconsistency across the region.” But there are also more upbeat perspectives on the regulatory landscape: unlike more developed regions where participants from all sectors are seeing increased regulation as a potential business impediment, the Middle East is seeing its markets opening up.

In the last two years alone, Qatar, for example, has received approval for a DvP (delivery vs. payment) mechanism, stock lending, market-making, DMA (direct market access), ETFs (exchange-traded funds), bills, new indices, new order types, and closing auctions.

That said, technology must keep pace with so much rapid change, and it seems clear today that dedicated systems for market-making and securities lending are imperative. Further, the increasing breadth of products, models and regulations requires consolidation of systems and data sources to provide clear insight into risks.

Indeed, with an expectation of a take-off in DMA, some foresee a time when a minority of flow will go through broker order management systems: technology vendors must “supply tools to calculate and assess the risk that comes along with these new trades.”

The core message we heard in Dubai was the importance of “going back to basics.” Simplified and standardized regulation and processes coupled with “accurate, reliable and comparable data” is fundamental to the path forward for trading in the Middle East.

global head of connectivity, SunGard’s global trading business

Trading in the Middle East: Turning a Corner?

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At SunGard’s Dubai City Day, a panel looked at trading opportunities and challenges in the Middle East. Panel members started with the bad news first: due to regulatory constraints, the region’s exchanges remain largely domestic monopolies, with very little competition for listings, no high-frequency trading and no CCP. Add to this the constraint of settlement caps, the large retail focus of most exchanges, different working weeks and settlement models – all deterrents to the generation of regional liquidity abound, probably explaining the minimal foreign participation in the markets until very recently.

Trading in the region will eventually become more attractive and accessible to overseas investors, but the panelists in Dubai implied that regulators were understandably quite cautious at present. Of more concern was the diversity of regulatory regimes throughout the region.

It was suggested that the lack of drive to unify some of the basic rules could in part be due to a desire to preserve each exchange’s local dominance, but a lack of competition for flow and listings constrains liquidity movement and foreign participation throughout the region. As case in point, Saudi Arabia for example simply bars foreign ownership; currently, foreigners can only trade Saudi stocks through funds or swap structures.

Panelists indicated that in Saudi Arabia, the market has experienced a doubling of volumes over the first half of 2012, driven by local investors with a strong domestic focus in an economy growing at more than 5 percent per year.* The domesticity and retail-oriented focus of the Saudi market – an amazing 93 percent of trading volumes are said to be retail-generated – gives it a different character from international markets, where retail volumes can be more erratic. Conversely, the Egyptian market was said to be dominated by institutional volumes. In Qatar, the focus is on attracting both domestic flows – particularly from the expat client base that may not have been aware that participation was possible – and increased participation from GCC institutions rather than directly reaching international investors.

The difference in settlement structures and models is also naturally becoming a point of concern, especially for investors looking across different regional exchanges. For example, while Saudi is at T+0, other GCC countries operate in a T+2 environment.

Turning to connectivity, the panel looked at the GCC exchanges’ capacity to absorb a sudden influx of high-frequency external order flow. The panel’s answer was a qualified yes for the future, but not anytime soon. The implementation of new trading engines and the adoption of industry-standard trading protocols probably explain that enthusiasm. Attention was also given to the technical connectivity methods themselves: with more fiber-optic cables being laid and a greater belief in Internet security, panelists proposed that direct market access over VPN (virtual private network) could become a viable method in the region.

On the panel, there was a clear view that the Middle East needs new products to drive liquidity to its capital markets, besides the requirement to improve infrastructure and the need to provide market participants an experience similar to “Western” standards, through changes to the markets’ structure, such as market-making, full delivery vs. payment, etc.

There is no doubt that the region’s regulators and market operators are, in a carefully considered way, adopting policies conducive to market expansion, the narrowing of spreads, and the provision of liquidity. We may be getting closer to the day when Middle East equity markets become venues for international investment.

*Sources AMF & WFE

vice president, risk solutions, SunGard's capital markets business

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A Different Kind of Wall Street Board Meeting

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Friday August 17, 2012 sees a most unusual board meeting in downtown New York. Representatives from the largest banks on Wall Street, private equity firms, and Main Street gathered at Pier 40 for what may be the most cordial coming together of year. I am lucky enough to be at the event.

It is, of course, the start of the 2012 SEAPaddleNYC, a 26½ mile stand up paddle board race around the island of Manhattan, taking in the Hudson, Harlem and East Rivers, ending at the foot of the historic Brooklyn Bridge. Board shorts and bikinis replace the suits and dresses that each racer would normally be wearing on a weekday morning, allowing the investment bankers, traders, risk managers and others to mingle and chat as they await the 8:00 a.m. start.

Especially interesting is the intersection of professional and private life, and specifically how well the risk advice we give out to financial firms is applied in this most practical of situations.

To begin, we can look at the top-down view of the event and consider what risks we should be concerned with, their potential outcomes and how to mitigate them.

This would start with fitness. This is far and away the highest risk category considering that the race entails:

  • Standing in the mid-summer New York heat for up to eight hours (the time it took me last year!)
  • Paddling consistently for the entire duration of the circumnavigation of the island
  • Being in three reasonably fast-flowing rivers throughout the event

The concept of not being able to complete the race introduces the possibility of the worst case outcome, drowning.

The only answer here is to never underestimate the risk and the undertaking, and to train for several months beforehand. This is very similar to marathon training, and effectively requires that the total training miles covered is a multiple of the miles in the actual event. That in turn means putting in “on water” miles in the summer midday sun for many weekends prior on top of daily gym sessions. The easy-to-overlook piece is the “in exercise monitoring” of your own physical state and the recognition of the onset of exhaustion before it prevents your ability to at least make the river bank.

However, fitness will get you so far. Proper equipment is the second essential risk mitigation. The boards themselves come in two flavors; those designed for surfing/ leisure and those designed for racing. For shorter races of six or seven miles, the surf boards will suffice, but for distances of ten miles or more, a racing board that is flat, wedged-shaped (to cut through swell), and light is essential. I participated in the same event last year using a surf board, and this was the main reason for my eight-hour finish time.

The third risk consideration, in terms of the intangibles, is understanding the environment. This relates to understanding the tidal gates between rivers, and knowing when certain milestones have to be reached before the flow against the paddler will result in furiously “standing still” at maximum, muscle-sapping effort. A race strategy has to be built around those flows, and success can only be achieved by working within them, not against them. Rivers around New York all have different ebb and flow times, but these can be worked out mathematically from the Battery Park high tide. Paddling without this knowledge is akin to investing in a product with no idea of the risk factors inherent in that product.

In the paddle board race, there are things that can be controlled, but there are also risks that are completely outside of our control, which include water state and weather.

While a river has reasonably predictable flows, the quality and state of that water is highly dependent on upstream factors such as sewage spillage (an example of which occurred just nine days before this race). The key is to understand what has happened to the water recently, and what the consequences are for contact with and drinking of the affected water. If the risk is a direct contact risk, then the only prudent thing is not to compete, , but if the risk is in the drinking, then carrying your own water supply (with a one way valve!) and being disciplined not to allow any river intake on the inevitable spills will mitigate this effectively.

Weather also poses some interesting questions to the risk-aware racer. What weather is dangerous, and what weather makes the event untenable? Heat is dangerous, but carriage of water and sunscreen should prevent it being a deal-breaker. Thunder and lightning are something else. Actual lightning versus possible lightning becomes a paddler’s choice (and a test of faith in forecasters probabilities), while sheet lightning versus streak lightning becomes the on-water difference between an interesting light display in the clouds and a terrifying odyssey.

In the end, as with all risk analysis, the object is not to remove all risk, but to understand the risks involved and to proceed or not, with those risks in mind. Part of the fun is taking the risk, just as investment banking can be seen as a collection of monetized risks, but the key is to minimize the risks that can be minimized, and to take on the others in the most calculated way possible.

Now, bring me that horizon!

trading and client connectivity, SunGard’s global trading business


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This blog post also appears on ATMonitor.

The regulatory push towards real-time trading risk management was addressed in a panel session at the 2012 SunGard Industry Seminar in London. The discussion pulled together of a lot of useful information for participants, but ultimately didn’t generate too much controversy. It seems that the regulators are for the most part pushing at an open door with their demands for tighter pre-trade risk controls. Stories abound, we’re told, of risk management teams now able to pursue projects they had long thought important or even necessary, but had historically lost out to other competing priorities.

During the panel discussion, Simmy Grewal of Aite Group presented a round-up of the major regulatory initiatives that touch on this area. It’s a considerable list.

  • The U.S. SEC Market Access Rule (15c3-5) is designed to eliminate “naked access” to equity execution venues and requires brokers to establish pre-trade risk controls in all cases.
  • The U.S. CFTC’s proposal for position limits on commodity derivatives (part of the Dodd-Frank legislation) still faces legal challenges, and requires more work on establishment of futures/swaps equivalents, but if enforced later this year, will effectively require global controls of pre-trade risk.
  • In the EU, the MiFID II proposals include text that implies ESMA will develop commodity derivative position limit standards similar to those of the CFTC.
  • Also in the EU, ESMA’s Guidelines on pre-trade risk management for automated trading engines are currently being incorporated into national regulations.
  • The real-time application of credit valuation adjustment (CVA) techniques to provide accurate measures of counterparty and liquidity risk exposures in OTC markets is required under the Basel III rules.

Stuart Adams of FIX Protocol Limited brought an interesting perspective to the discussion: FPL has been very active in the pre-trade risk field, and is due shortly to publish an update to its 2011 Risk Controls guidelines, extending their scope to cover listed derivatives as well as equities.

Throughout the discussion, the panel addressed questions around three different areas.

How real-time can risk management be?

You don’t get more real-time than pre-trade – which is now being required in a range of cases. The major difficulty with being fully real-time is that in most trading firms of any size there will be multiple trading architectures in use, and also there will be trading on multiple exchanges. Limits and margin then have to be allocated and shared across them, and it’s hard to do this optimally. This is a particular challenge in derivatives trading, given the complexities of managing margin. Risk also has to be managed across related asset classes – typically futures, options and swaps.

The push for better risk management comes at the same time as an urgent priority on lower latency. This places tight limits on how much checking you can do pre-trade and creates a challenge for software builders – how fast can they make the checks run? As a result, we see firms making necessary practical compromises: for example, pattern risk controls (recommended in the FPL Guidelines) are generally placed post-trade.

Where do buy- and sell-side firms need to place emphasis in their compliance efforts?

There are difficult decisions here, given that many other issues are live at the same time, particularly in Europe, with the rest of MiFID and the MAD review. But getting pre-trade risk management right, across the industry, has to be a major priority. There will be no excuses for anyone breaking a limit.

Firms need to ensure that comprehensive software controls are in place for all electronic trading, whether from screens or automated trading engines. Where these already exist, the systems in place and how they are configured need to be reviewed. Not all systems will be capable of handling all checks in 15c3-5 or the ESMA Guidelines. Firms also need to ensure that the controls are well documented.

The challenges multiply where different markets and diverse trading architectures are involved, but technology solutions exist that can help optimize the management of such environments.

Can some real business benefits be gained at the same time?

Arguably, given the scale of what can happen in an electronic trading environment, every trading firm should be on the same side as the regulators. We’ve certainly seen examples of both brokers and buy-side firms using the regulations as a lever to make risk management or technology improvements that did not previously get budget or resource focus. This shouldn’t come as a surprise. We are, after all, talking about the avoidance of what could in the worst case be catastrophic risks.

This panel session amounted to a general agreement that there is little point in fighting the regulatory direction on pre-trade risk management and that in many ways it will benefit business. The big issues include assuring the quality of systems for each trading architecture and asset class, and deciding how far to go with the more complex controls in order to optimize the use of available capital and margin.

While you’re here…

vice president, risk solutions, SunGard's capital markets business

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This month saw the Professional Risk Managers International Association (PRMIA) celebrate its tenth birthday in style at the Marriott Marquis in New York’s Times Square at its inaugural risk conference, sponsored in part by SunGard.

Even with the credit crisis behind us, ongoing issues with euro zone sovereignty risk, Basel III, the Volcker rule, the failure of MF Global, and the move to central clearing proved that there was plenty to talk about at the event. And if 2012 had not been eventful enough so far, J.P. Morgan’s announcement of a $2 billion loss on the eve of the conference both highlighted the profile of risk management and guaranteed a buzz at the party.

With the JPM news so fresh, speculation was high as to the root of the issue, with plenty of debate over whether risk management had failed, been ignored or experienced a miscalculation. The same three possibilities were equally discussed during the MF Global case earlier in the year. Conferences focused on risk management often delve into the status of risk management within larger financial firms, but rarely have such stark examples acting as fuel to the fire.

Of course, there were also more forward-looking discussions around dealing with regulatory reform and any unintended consequences thereof. A key area of discussion for the PRMIA audience was central clearing. Among the potential issues that could arise were concentration and liquidity risks within specific clearing exchanges, and the dramatic rise in the amount of collateral/margin required to conduct derivatives trades. The role of FCMs and their attendant business models also tail-ended those same debates.

The ongoing conversation about whether VaR or Expected Shortfall is the more effective risk metric was high on the agenda, as delegates pondered the usefulness of the two. In general, participants agreed that VaR/stressed VaR works for the capital calculations but that both measures should be looked at internally for prudent risk management, along with other tail-orientated risk measures and stress tests.

The plight of the euro zone was next on the hot topic list, as risk managers from across the U.S. and beyond discussed the theoretical and practical implications of sovereign risk in the developed European markets, the impact these have on credit spreads and default correlations, and how best to reflect political risk in underlying risk calculations and estimates.

The PRMIA audience also discussed the Volcker rule, both in terms of absolute compliance and monitoring of hedging and market making activities, as well as the equally worrisome effect on liquidity in the absence of prop trading. Interestingly, potential Volcker-led liquidity issues led back to the question of which risk measure (VaR/ES) can be best adjusted to reflect lower liquidity environments, the need for liquid central clearing, and the associated cost of margin/collateral.

There were also presentations on risk culture, model validity and enterprise-wide liquidity, operational, market and credit risk. Of course, these are all topics that in less stressed times could be top-of-mind at a risk conference, but were here relegated to bit players on a larger stage.

At the PRMIA conference the conversations were all different, yet connected. After 10 years of challenging risk management, it was a great way to celebrate. There has never been a stronger need for forums like this where risk professionals from across the industry can discuss, argue, share and move forward with peer-agreed best practice in a financial world that seems intent on challenging the resolve and commitment of risk departments everywhere.

While you’re here…

senior product specialist, SunGard's capital markets business


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This blog post also appears on ATMonitor.

The overarching objective of increasing market resilience and stability during periods of turmoil is shared by most, if not all, market actors. But that is where the agreements seem to end. How to achieve this, and how successful the regulators can hope to be is something that could be debated and discussed endlessly. We certainly had a good go at it during a recent panel discussion at SunGard’s London Industry Seminar, and I made the following observations from the event.

Regulation is here to stay, and its reach and coverage will continue to change rapidly. It is a challenge to even grasp the breadth of change happening in the various regulatory streams, such as EMIR, MAD, MiFID, and ESMA. What is the full regulatory picture created when these different rulebooks are overlaid? No one seems to be able to concisely formulate this yet.

That leads on to the question: are we creating something efficient? It is, in insulation for individual behaviors such as stemming layering or quote stuffing, but where do the various rules and guidelines get us when looking at the big picture? There is great uncertainty here, which is cause for concern.

Compliance desks are now scrambling to implement new guidelines, directives and regulations as they are published. At this point, information is often confusing, incomplete or still in draft form. When final versions are available, the publishing date is often only months from the go-live date, which is not enough time for firms to properly implement organizational and role changes and IT system improvements to fully comply. This waters down the effect and impact of changes, as regulators are essentially forced into a position where they have to show initial leniency towards implementation.

For any actor in financial markets, strong and well-functioning compliance is now becoming a marketing tool. Customers are increasingly asking how their orders are managed and how they can be assured they are being fairly treated. This is true for trading venues, banks and brokers alike. Regulation is here to stay, and its rate of change, reach and impact will continue to increase. So watch this space, and join us in our next panel debate, as I’m sure it will be another interesting discussion.

While you’re here…

solution specialist, SunGard’s capital markets business


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Over the past few decades, we’ve seen the global securities finance industry grow and evolve in many ways. When I started out in this business it was relatively small, and at the time we were seeing a dramatic expansion of the securities lending market. It always was, and still is, very much a people business, and the interesting thing is that many of the folks who were around 20+ years ago are still around somewhere in the industry today.

From the beginning we always saw very different approaches to securities finance from the U.S. markets and international (non-North American) markets; the U.S. was a more highly regulated and standardized environment, resulting in more vanilla, but high-volume, trades. The international players were jumping in from the perspective of seeking high-value “specials” and leveraging cross-border arbitrage opportunities, such as the famous “dividend trade.” At that time, the international securities finance markets were growing rapidly.

In my experience helping customers to solve various problems over the years, I’ve been fortunate enough to see the industry mature firsthand. I have had a front row seat to watch the securities finance markets tackle new challenges, develop new approaches and adapt to changes in the global finance industry. From my own experience, and through asking a few of my esteemed colleagues, a few examples of how things have changed come to mind:

  • “The ‘Big Bang’ in 1986 opened up the UK market to banks and brokers from the U.S., Europe and Asia-Pacific, which ultimately led to an increased globalization of the whole securities financing market. The stock market crash in the following year resulted in many more consolidations within the established market and helped to facilitate the emergence of new markets, making this a very exciting time to be providing software for securities finance.”

  • “When many new players were jumping into the securities finance business, they needed to get up and running very quickly, with as much out-of-the box functionality as possible… I think our record for getting a new player live was two weeks. The server often used to literally sit under the desk; you would never find that now!”

  • “In the early days, decades ago, the desks were small, manned by dedicated specialists who needed to be multi-functional. These specialists also had to have a system to support the broad spectrum of needs around securities lending in different markets. Now there is a tendency to have specialist areas for each function in the securities finance lifecycle.”
  • “Over the years, the number of transaction types supported has increased, and stock lending desks (predominantly in the equities side of the business) expanded into doing some repo and buy/sell back business. In more recent years this also extended into more synthetic transactions, particularly in emerging markets.”

  • “It has been exciting to be involved as emerging markets have come (and gone) in the securities finance space. Countries such as Malaysia, Thailand, Taiwan, and India gained traction in the 1990s, but lost it again following currency exchange challenges and the introduction of tougher regulations. Today we are seeing increased activity in some of these countries as well as within new regions such as Brazil, Russia, China and the Middle East.”
  • “In time, operational standards have emerged, through the auspices of ISLA and its hard-working sub-committee members who have led the world in developing best practices for a number of the trade lifecycle activities. As a result, there is now more automation of some processes, but there is still a long way to go.”
  • “After the global financial crisis of 2008, there is now more focus on risk in the securities finance area than ever before.  Years ago, securities finance transactions were considered ‘risk-free.’ Nowadays you are actually likely to find a dedicated risk professional on the securities finance desk.”

Clearly, the securities finance space has changed and evolved quite a bit, but I believe that innovation is happening faster now than ever before. In the next few years, I expect to see:

  • More automation of trading and lifecycle processes; electronic marketplaces have struggled in our environment, however, cost pressures are likely to result in increased traction in this area.
  • Even greater consolidation of processes; in these times where “cost is king,” all ways of streamlining processes are being considered. For example, collateral management used to sit in silos but this is changing as firms are creating centralized groups to increase efficiency, improve transparencies and enable optimized collateral usage.
  • A move towards CCPs; without being mandated, uptake to date has been slow, however the beneficial capital treatment of trading versus a CCP is likely to mean that central counterparties will prevail over time.
  • Further automation of corporate actions processing; this area has always had the capability to make or break the profitability on a trade – the need for tighter controls in this area are now getting focus.

Across the globe, securities finance has come a long way in the past few decades, but we still see room to grow. It has always been an exciting, people-focused business, and I look forward to seeing what the coming years have in store. What key milestones in the securities finance industry stand out to you? Where do you see securities finance in five years? Leave us a comment to join the conversation.

Note: A special thanks to my colleagues, especially Carol Kemm, for adding your insight to this article.

managing director, Asia-Pacific, SunGard's capital markets business


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As sponsors of the recent Australia FIX conference, which gathered over 300 delegates from sell-side and buy-side firms in Sydney, we participated to some lively discussions around recent and upcoming changes in financial markets:

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global head of connectivity, SunGard’s global trading business


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By Philippe Carré, Global Head of Connectivity, SunGard’s Global Trading business

One of the major themes of this year’s London City Day was ‘Capitalizing on Change’ and there is nowhere that has seen more change in 2011 than the Middle East and Africa. So it was not surprising that the session ‘New investment opportunities: trading emerging markets in Egypt and the Pan Africa region’ attracted so much interest. Read more»