I heard Francis Gross of the ECB speak at one of the panel events at the XTrakter Conference last week, and found that I couldn't avoid asking him whether the aims of the "Data Utility" initiative by the ECB could be better separated from the means by which the ECB proposes to solve them. At the moment, reference data issues for the industry and the data utility seem to be presented as a single "package". I can't say that the response to my question was a clear one to my understanding; however I would say that Francis was helpful after the panel had finished and provided a recent presentation of their ideas, of which you can find a copy here.

Looking through the presentation, the motivations put forward for why the industry needs a data utility seem to include:

• Data processing must be done in an automated manner, since data volumes have moved beyond the capabilities of manual processing.
  - can't see anyone arguing with this
• Data is a major bottleneck, with multiple providers/sources each with the own "data dialect"
  - agreed and to some extent what keeps data/data management vendors in business, but sounds sensible to standardise if possible as there are plenty of other problems to address
• These data dialects lead to increased cost, operational risk and reduced responsiveness
  - agreed, mainly a cost aspect I would suggest
• The recent crisis was not helped by weak data management in the industry
  - but nor was it the cause, so not a great premise for a data utility
• • lack of transparency of data
    - "transparency" is an over-used word at the moment, but certainly clarity and quality were/are needed
  • systematic risk could not be assessed due to the availability of data
    - using terms like "systematic risk" seems to imply the regulators could calculate something, whereas this discipline is new so I guess we are really talking about simply knowing who is exposed to who and how.
• We need the capability to run large scale computing analysis on a vast pool of micro data, sometimes on an ad-hoc basis when a crisis begins
  - fundamentally agreed but also good to qualify with what you propose to be calculated - having a set of "numbers" doesn't seem to have helped much recently...

I started the above bullet point list by saying it contains the motivations for "why the industry needs a data utility" but I guess looking at the above list they really point to the more general aim of "why we need better industry-level data management". In the presentation the above points are then used to state:

"We all need the same good basic reference data. Why build more than one infrastructure?"

Maybe "Why build more than one infrastructure?" should really be changed to say "Why maintain more than one infrastructure?" given that Bloomberg, Thomson Reuters, Six Telekurs, Interactive, Markit and all the other vendors already infrastructure to do this. Not sure if I should read anything into the wording but more logical leaps of faith are to follow.

The presentation then moves on to state that shared reference data standards are a must, to which I cannot see many consumers of data disagreeing with that statement. Not sure I agree though with the overly simplistic statement that "Data will be good for all users or good for none". Trying telling that to the accountancy and risk departments for example but I suppose what we are talking about here is basic reference data not the more subjective price and valuation data. Reference data on instruments and entities is either right or wrong, and the presentation makes the good point that no amount of "data cleaning" can help this i.e. if wrong, the data needs to be re-captured from an accurate source.

The call for the establishment and use of reference data standards in the presentation then seems to be used to "slide "into a call for a standard reference data infrastructure. Unless I am very much mistaken, these two things are not necessarily the same thing and so it seems a logical leap has been taken here. The presentation talks about the possible necessity of "top down" legal compulsion for the industry, again something that I could agree and see the need for, but both the issues and legal compulsion do not automatically drive us to a "data utility" as the only option? Why couldn't legal compulsion be applied to the existing data vendors to standardise on common IDs for instance? ISIN is proposed as a standard in the presentation, but I can only assume that this is due to the ECB being mainly focussed on the bond world where to a large degree ISIN's work (i.e. are unique), whereas in the world of equities ISIN needs a lot of qualification (currency, exchange, share class...) before it uniquely identifies a quoted equity.

In summary, the presentation starts with showing how great the ECB's Centralised Security DataBase is (7 million securities, 3 million record updates/day etc...) and it does look good. The data issues for the industry seem clear, although I think the "crisis" is a bit of a red herring to the aim of data cost reduction, however the logical jump from industry need to effectively "we must have a data utility" is an interesting one, one where I would prefer that more options were discussed. It seems ironic that in these days of "transparency" it is not at all that transparent to me why more alternative solutions are not being discussed and a choice justified. Talking of choice and as a final thought, I am also not sure why the data vendors are not up in arms about this initiative - are they frantically lobbying behind the scenes? - do they simply think the utility won't go ahead? - or are they afraid of upsetting the EU? Any insight is very welcome, and maybe more of update from me when I get chance to speak with Francis in more detail.

I went along to the XTrakter Annual User Conference in London on Thursday - Good event with some great speakers. Angela Knight, CEO of the British Bankers Association, gave a talk to start off the day. Angela seemed a lot less on the defensive than when I have heard her on national radio here in the UK, usually being interrogated by some journalist who wants answers to difficult questions on the financial crisis and the banks role within it.

Angela said that we were in year 3 of the "crisis" with 2008 being about the banks, 2009 being about governments and politics and 2010 being the year of sovereign debt. I guess she enjoyed saying this but that everyone is blaming "Anglo Saxon Banking" for our problems and yet it was not the banks that contributed to the fundamental problems that Greece is facing.

One major theme of her talk was decidedly Euro-Sceptic in tone, which was that the UK idea of internationality and international trade was different from that of Europe. She perceived that in the UK one of our trading parties is Europe, whereas international trade in Europe was more about inter-European and not world-wide trade - I think that there are elements of truth in this but not sure that Germany industry for example would agree that it is not conscious of truly "global" trade? She said that she was concerned by the rules and regulation being put up by governments, particularly in respect of there being too much and in too short a time.

Angela was an engaging speaker and at the very least her opinions prompt reaction, however I have to end this quick post with the best quote of the morning from Anthony Belchambers, CEO of the Futures and Options Association. Anthony said that current frenzy around political and regulatory initiatives to control the financial markets remind him of:

"A bar room brawl, where the brawlers don't punch the person that started the fight, they punch the person they have always wanted to punch..."

I went along to a morning panel on counterparty data management on Tuesday, sponsored by GoldenSource, Avox and Interactive Data, and hosted by Virginie O'Shea of the A-Team. Counterparty data obviously has a very high profile currently in light of recent events, however the advice from the panel fundamentally seemed to be get the basics of data management right (ownership, control, consistency, quality, transparency), rather than anything radically new.

There was some debate about the possible extension of BIC (Bank Identifier Code) to be used more generally as a standard for a unique business entity identifier - this seemed to be received well but there were concerns that such an initiative would not solve the problem but rather become an addition to the already complex entity-mapping process.

The "Data Utility" from the ECB was also debated, and it was refreshing to here some negative (realistic?) things said about it, such as the concern raised by Interactive that this might involve huge public spend without necessarily understanding why a new government sponsored entity would be able to do better than existing data providers. Obviously a data provider would say that, but I have to agree, it seems there is too much focus on having a data utility and not looking at the different options for solving industry data issues (one option obviously being a data utility, but lets not pre-package the problem with a solution but more of that in later posts...).

For more detail on the event, then take a look at Virginie's blog post.

Given that I am English and can tend to start many personal introductions with a short conversation about the weather (generally either "awful" or "not bad for this time of year"...), then maybe I should be very receptive to the use of weather-related expressions in technology such as the "cloud". Maybe not however since the "cloud" and "cloud computing" have reached that zenith of marketing hype, when everyone is talking about a new technology regardless of if they are sure what it actually is (or might be, or could become...).

Anyway, I finally swallowed my cynicism and on Thursday morning went along to "Migrating Business to the Cloud", an event by Microsoft hosted at Bafta (small venue where the UK deals out its equivalent (?) of the Oscars). The master of ceremonies was Mark Taylor of Microsoft, who gave a general introduction to what Microsoft are doing in the "cloud", and of particular note he described the four types of computing scenarios where cloud computing can optimally be applied:

• Predictable Bursting - where computing needs come and go in predictable waves of usage/demand
• Growing Fast - where computing needs are rising exponentially like in a successful internet start-up
• Unpredictable Bursting - where computing demand comes in unpredictable bursts, such as that associated with say usage of a backup computer centre in disaster recovery
• On and Off - where you might run a process once a month or at an interval you decide

The above definitions seem ok to me but there is (probably understandably) some overlap in usage cases. The "Growing Fast" case for start-ups is interesting and more of that later.

Mark handed over to David Chappell who gave his perspective on cloud platforms as they are today in the market. David was a very entertaining and knowledgeable speaker, despite wearing a dodgy suit (what happened to those trousers?!) and having a peculiar wide foot stance when speaking. Anyway I digress, on to what he said. David started by saying what the "Cloud" is comprised of:

• Cloud Applications - basically this is Software as a Service (SaaS) and some current examples of this would be Salesforce.com CRM, Microsoft Exchange Online and Google Apps.
• Cloud Platforms - a platform for developing cloud applications, with the following characteristics that it:
  • is aimed at developers for creating and running cloud applications, not end consumers
  • provides self-service access to computing resources
  • allows very granular, on-demand allocation of computing resources
  • charges for the consumption of computing resources in a very granular manner

David then explained that due to its ambiguity he disliked the usage of the term "Private Cloud" in the ongoing debate about publicly available cloud services (such as those provided my Amazon, Microsoft and Google) vs. private clouds deployed within private institutions. David said the main difference was that private clouds do not have the economics of public clouds (i.e. pay for what you use only when you need it). That point seemed straightforward, however I would have thought that with a large global organisation with many different departmental computing demands the economics of a private cloud would be similar to a public one.

David then went on to explain that there are two kinds of Cloud Platform:

• Infrastructure as a Service (IaaS) - this is a cloud platform the provides a developer with a virtual machine (VM) that has (almost) full access within it; put another way the development environment gives the developer total control but with that control comes responsibility.
• Platform as a Service (PaaS) - this is a cloud platform that runs an application that a developer has created; it is easy to use but has limited control for the developer.

David put forward that there has been only 5 major software technology platforms over the past 50 years:

• Mainframe
• Mini-Computer
• PC
• PC-based Server
• Mobile

He perceives that the Cloud is the 6th major software technology platform, and as such he is extremely enthusiastic about the opportunity and benefits that this presents to the whole of the software industry and its consumers.

David categorised Microsoft's cloud platform as (mostly) PaaS, which had three main components:

• Windows Azure - for environment for running cloud applications within the platform
• SQL Azure - relational storage within the platform
• Windows Azure Platform AppFabric – (David noted the long name and sympathised with trying to name things sensibly) this provides and manages the infrastructure within the platform

He then moved on to describe the main usage scenarios for Windows Azure, for applications that:

• need massive scale, such as Web 2.0 applications
• need high reliability
• have highly variable loading
• have short or unpredictable lifetimes
• need parallell processing
• will either fail fast or scale fast
• do not fit easily in a single organisation's data centre, such as joint venture
• need external storage

David said that in the fail quickly or scale quickly scenario, this was squarely aimed at technology start-ups where using Cloud technologies would effectively increase the frequency at which new ideas could be tried out at less economic cost if they go wrong, but are ready to scale massively if they become the new "Facebook" - so much so that many of the VCs in Silicon Valley are now insisting that start-ups use cloud technology as a condition of funding.

Amazon's Elastic Compute Cloud (Amazon EC2) was the first major commercial cloud platform, and David categorised this as IaaS, where effectively you get a Virtual Machine (VM) environment that provides a lot of control but requires more effort to control than an PaaS such as Azure.

David said that he was surprised that the Google App Engine, which has Python and now Java as its programming languages, did not come with any traditional relational storage (unlike most other cloud platforms) but on speaking with Google he found that the storage engine and the whole platform is again designed primarily for Web 2.0 apps and as such storage usage was more about retrieving photos, video etc and less about querying across many records.

David was very complimentary about the cloud platform from Salesforce.com called Force.com, He said that the sales pitch from Salesforce.com would be straight to business users, effectively saying that they could build scaleable, resilient applications without involving the IT department and without needing programming expertise. He asked the audience if anyone had used these tools and a few folks confirmed that they were extremely impressed by what the platform offered.

Bob Muglia (President, Server and Business Tools, Microsoft) then gave a quick talk on Microsoft's plans for Azure. He mentioned how Microsoft's new search engine, Bing, was based on several hundred thousand servers running in Azure, but only had a handful of operating staff in contrast with the usual economics (taken from Gartner) that usually 1 operations person was needed for every 50 servers. He emphasised that Microsoft was committed to the further development of "on premises" operating systems but that Microsoft was totally committed to cloud computing, its development and its support.

He said that some of the tools found in the Microsoft technology suite, such as SQL Reporting Services, are not yet available in the cloud on Azure/SQL Azure (due end of year though) - he said that he hoped that people understood that re-engineering an existing application for the cloud sometimes took time to ensure the scaleable and reliability demanded when providing the functionality through the cloud. The vision put forward by Bob for development of cloud applications seemed very compelling, with Microsoft aiming to make things such enabling resilience for a globally available cloud application as simple as ticking a check-box in Microsoft Visual Studio. He put forward that the major barrier to cloud adoption was the human aspect of trust of moving applications "off premises". He said that he saw a fundamental shift across all industries to cloud development and deployment, but added there may be some areas such as government and finance where this process takes a lot longer.

The event then switched to presentations by EasyJet, RiskMetrics and SeeTheDifference. The head of IT at EasyJet gave his pitch first. His department get an annual budget of 0.75% (small?) of turnover of £2.5bn (larger, so translating to £18.75m) and has around 60 people. He presented how EasyJet has taken an incremental approach to the adoption of cloud computing, utilising both "on-premises" and cloud ("off-premises") technology together (exposing end points of applications into the cloud at first). He advised this approach since it:

• was a smaller step than full-blown adoption
• was lower risk
• demonstrated big value in a short time-frame
• leveraged the rich functionality available in Azure
• accelerated acceptance of cloud technology

Dr Rob Fraser of RiskMetrics was next up. He explained whilst Moore's Law says that computing power doubles every 18 months, the calculations needed for risk management have doubled every six months. This has driven the need for parallel computing to meet this calculation need, and that RiskMetrics' RiskBurst service uses around 2,500 64-bit Opteron cores in their data centre but combines this with use of Azure to meet the peaks in calculation needed during each day (the similarities with power consumption management were pretty apparent). He said that average CPU consumption was around 18% of peak, hence a combination of both on and off premises compute power was a good solution for them. He mentioned that the management of this hybrid combination of technologies, and in particular being able to show real-time billing for it was a key area of investment for RiskMetrics.

The final presentation was by SeeTheDifference. The main point of this presentation was that this charitable organisation had zero permanent staff involved in IT, but regardless was able to deliver a very professional, reliable and scaleable website using external consultants to build on Azure.

Final section of the morning was a roundtable discussion with questions from the audience. The EasyJet guy said that the human mindset was key to the adoption of cloud computing. In terms of what keeps him awake at night was the thought that what would happen/how would attitudes change if any of the cloud infrastructure failed - so far it has experienced 100% up time. Rob of RiskMetrics was concerned about the stability of the platform, trying to ensuring that any changes introduced do not damage reliability. He added that he disagreed with Bob Muglia and thought that financial institutions would adopt public clouds quickly – he cited their experience of their revenues now being 90% based from service provision not on-premises applications. David said that he took some of the comments from Bob to indicate that Microsoft would also offer more of a pure VM (IaaS) soon in addition to the PaaS approach of Azure. David said that trust was the major issue in cloud adoption and he advised an incremental approach so "get your feet wet" then build from there.

On the whole the presentations were good and my knowledge of cloud technology has improved a bit - certainly it is fantastically appealing to develop globally available applications with no scaling, no resilience or data replication issues - it sounds too good to be true which generally means it is, so I guess there is much more work to do in gaining trust and acceptance for this technology. So my (pragmatic?) cynicism remains - but cloudy days are certainly coming and for a change maybe this is something to very much look forward to.

Good post from Robert Peston on the BBC website on part that the Product Control Group did (or rather didn't?...) play in the problems at Lehman's, according to the official US bankruptcy report on Lehman's by Anton Valukas.The post highlights the report's findings that the Product Control Group did not have the quant experience to keep up with CDO trading desk.

Interesting findings on Lehman's, but variants on this theme seem to be elsewhere too. A contact who knew Merrill's New York trading operation in the run up to the crisis recently asked me how many quants did I think used to work on the CDO trading desk. The surprising (?) answer was not one...

I spent the morning yesterday over at the FIMA USA event in New York, and caught the panel discussion chaired by Neil Edelstein of GoldenSource. Stand out speakers were Amy Hawkins of BNY Mellon and John Bottega of the Federal Reserve.

Neil started the panel by asking the panel for their thoughts on the current drive to improve "data management for risk". Transparency and quality were mentioned a lot unsurprisingly, with John Bottega adding that he was aware that a lot of banks were now focussed on the data that in the past had been "not available" for risk management, not just the quality of data that is readily accessible. All panelists focussed on the need to manage risk across the whole institution, not just by product silo.

On the topic of data standards and transparency, John referred the audience to testimony on the Mortgage Backed Securities (MBS) market presented to the US Government by the XBRL group. Apparently the filing process for mortgages allows free format filing and so is of little use from an automated processing point of view. John also pointed out that a key piece of data in assessing risk is that the "first time buyer" flag was found to be present in only 15% of the filings.

John also mentioned that if loans and mortgages could be given standard identifiers, then this would enable new levels of risk management - for instance it should be able to extract those obligations against a specific region that for example is experiencing economic recession. These would be the benefits of getting data standards in place.

As was later expanded upon in a later talk by Kay Vicino of Northern Trust, there was a lot of panel discussion on organisational data governance and the management structures needed to achieve it. On the governance side of things then whilst it is not an exciting topic, it is obviously vital - main point seems to be establishing data ownership and responsibilities which brings me back to the point that a lot of (most?) data management issues are down to managing people and organisational politics, not just down to good technology (although it helps!).

Overall a reasonable panel, and the XBRL testimony looks worth a more detailed read (if the testimony link doesn't work then go to the www.xbrl.org site and search for a report called "Using Standards for Transparency")

The current finanical crisis in Greece has prompted an outburst of entertaining discussion at the FT about CDS contracts, initiated by a feature article by Wolfgang Munchau who advocates that naked CDS contracts should be banned. The main argument used is that you should not be able to insure against a risk that you do not face e.g. buying insurance on somebody else's house then arranging to have the house burnt down. In support of Mr Munchau, one reader letter points out that insurance without interest in the insured item has been illegal since 1746, which on the face of it seems a long enough time to be a credible point in the discussion.

However, in using this argument then Mr Munchau seems be to attacking the whole of the derivatives industry not just CDS, for example the same argument could be used to ban the use of naked index puts to hedge equity market risk. I guess he is also helping some of the politicians in the EU direct attention away from Greece's financial mismanagement more towards the "evils" of the derivatives markets and hedge funds.

Some good letters in response, for instance this one with a good illustration of what hedging would be like without intermediaries to buy and sell risks that they do not own, plus another more direct one from the Association of Corporate Treasurers.

Whilst talking of Greece and credit, the FT Alphaville team also poked some fun at Anatole Kaletsky, the economist of the London Times Newspaper, who has recently done some interesting articles in the paper concerning his predictions about the stresses being suffered by Greece and the Euro. From their post, it would seem that Mr Kaletsky also runs a credit related fund, so it is implied that some of his newspaper views need to "calibrated" against his own vested interests...

Thomson Reuters held a panel event on data management at their London offices on Tuesday last week, with speakers from Barcap, LCH.Clearnet, DB, Mizuho and Citi. This event was held in follow up to their recent report "Beyond Golden Copy". Below are some of my notes on the summary points the panelists made:

• The Value of Data - Kris Bhattacharjee of Barcap said that there were currently two main drivers behind the perceived business value of data; i) Regulators are expecting more information, adding additional requirements and conducting more adhoc reporting requests. ii) Business users/decision makers want more granular understanding of trading and risk management data, in order to decide how best to allocate scarce capital to what trading positions.
• Data Metrics - Kris said that the metrics were many but timeliness of data was becoming a key metric - over the past two years regulators have moved from allowing say 2 months as a reporting timeline down to 10 days recently. Additionally timeliness is again vital as regulators demand adhoc reporting in response to market events.
• Accuracy/Completeness - Again regulators are driving this, with the "bad numbers in, bad numbers out" as the main motivation. Unsurprisingly, counterparty data is also being required at a new level of detail and accuracy down to a portfolio level in light of the crisis.
• Granularity of Data - Deeper granularity of data being driven by scarce capital and the need to understand how efficiently it is being used. Basel II has also driven greater granularity over Basel I. Reflecting what I have heard from some our clients, Kris added that the data associated with securitised products had increased greatly as people need to understand exposure/risk and pricing in more detail (rather than assume blanket statistical behaviour for a whole basket of assets).
• Stress Scenarios - Kris again mentioned the understanding of counterparty exposure driving the need for new data sets, as had the initiative of banks having "living wills" to allow a bank to be wound down in an orderly manner.
• Everybody has Left the Building! - Martin Taylor of LCH.Clearnet was a great speaker and said that the biggest new problem that the collapse of Lehman's created was that ordinarily there are people around to help with extracting from systems what the exposure is to the various counterparties. In the Lehman's case there was nobody around to help, making the process very difficult and leading to the need for changes to address this problem.
• Mandating Data Integrity - Martin added that data security, integrity and auditabiliy were vital, and in particular put emphasis on the people that are running the systems that they have their own form of integrity so that an institution knows that the people can trusted but is also capable to deal with a situation where the people are not around to help. Martin felt that this level of data management should be mandated on the industry and that there was an awful lot that finance could learn from industries such as Pharmaceuticals in terms of product approval and management/robustness of data.
• Data with No Cost or Value - Neil Fletcher of DB was another good speaker who started his talk by saying that pre-crisis people thought of data as project based, otherwise dealt with it on an adhoc basis and considered data as having no cost or value. Institutions had a spaghetti approach to data, with systems/projects being process not data based i.e. the systems get only the isolated data sets they need only when they need it.
• Quality is Now the Data Driver - Neil said that 18 months on from the crisis, then whilst ROI is still important for data projects then quality of data is the key driver.
• Sponsorship and Ownership of Data - Neil added that quality data is an asset as are the systems that produce data quality, and to ensure success data management projects needed high level business sponsorship, but also ongoing and clearly defined ownership of all data sets and their quality.
• Enterprise Data Virtualisation - Neil said that DB were embarking on a long term project to ensure that all systems get data from the same logical place on a global basis, and that they were investing heavily in data virtualisation technology as a key means of achieving this goal. DB are starting with reference data, moving to transactional/positional data and on to other data types. For each type/category of data ownership would be clearly defined across all systems and would enable real-time transformation of the data into whatever format it is needed in.
• Enterprise Data Model - Neil said that as a result of this virtualisation approach then you have to invest in putting together an enterprise data model for all data used in an institution. From my point of view this could be interpreted as a move back to "big EDM" (with all the project risk that implies) but I guess it is being approach on a more staged manner.
• Lip Service to Data has Ended - Neil summarised by saying that lip service to data management has ended with the start of the crisis and that 18 months on the enthusiasm for dealing with the data problem has not diminished.
• Publish/Validate/Subscribe - Simon Tweddle of Mizuho echoed a lot of what Neil said in approach to global data management and ownership, but added that he believed that the model of publish/subscribe needs to change to publish/validate/subscribe to ensure data quality.

Most of the panelists agreed that bringing in experience from external industries (Pharma, Oil & Gas, Internet Search etc) would be beneficial since we should not assume that the financial market has the expertise to get data management right first time (take a look at this article from the FT for a related idea). Martin of LCH.Clearnet was convinced that mandated data management would come and would be beneficial, which some of other panelists did not agree with and suggested that the industry needs to get ahead of the regulators to head this possibility off. Simon said that the focus on complex data/products was wrong given that the basics (what is our exposure to this counterparty?) were not being done (not sure I agree with this totally, both are needed given the losses from CDOs etc). Overall it was good panel with some interesting debate and speakers.

Interesting reading in a survey put together by Lepus and Thomson Reuters and publicised on Finextra this week. Summary findings:

• Data management budgets are increasing, with 77% of firms intending to increase spend on data quality and consistency and 32% saying spend would increase significantly.
• Tearing down data silos is a key initiative, 70% of firms are looking to revise data management solutions as a result of the crisis, and 31% of firms cited data quality and consistency as the most important driver.
• Data management for risk is the top concern, with 87.25% of firms looking to integrate data repositories in risk, and 62.5% saying that they were close/very close.

This seems to be consistent with another article on Finextra this week, with Deloitte predicting a much greater spend on risk management projects. Putting the marketing aspects aside for a moment, I don't think it is abundantly clear from the actual content of the Lepus survey as to why the title includes the phrase "...Beyond Golden Copy" other than the type of data management they refer to seems to have more emphasis on global/firm-wide data integration than your traditional EDM golden copy data warehouse approach.

It is also interesting to hear so much about consistent data across the entire enterprise (driven by risk and regulation) which seems to echo the "big EDM" projects of old that did prove that successful, and to some degree is at odds with what the likes of Golden Source and Asset Control are currently saying about choosing smaller projects to bite off on rather than the enterprise approach. I would suggest however that there is no issue in having smaller projects in mind so long as they are compatible with the overall goal.

The integration and consistentency of data across front, middle and back office was also interesting, and in particular the front office integration echos some of the things I have been saying about the need for analytics management and the management of front office data as part of the data management process, not something to be ignored in the hope it sorts itself out.

Just caught up with this article appeared on the A-Team website - Bloomberg is facing pressure from the industry with regards to users concerns about its initiative to make its codes freely available (see previous post Truly "Open" Bloomberg?). In the article, Max Woolfenden, managing director of FOW Tradedata, recognizes the potential of the BSYM website but advocates more progresses to be made in order to improve completeness of the data offered and in particular to clarify what exactly 'open' means.

According to A-Team, Bloomberg is also facing pressure with regards to a possible introduction of a new licensing structure for Service Provider Agreement (SPA) contracts for fund administration clients. Under the new system, fund administrators would be required 'to pay per security in each individual client portfolio', effectively changing the status of the fund manager to that of data re-distributor with all the cost increases that implies. It will be interesting to see where this heads - will the administrators simply pass the data costs through to their clients, absorb some costs as a competitive play or simply move away from using Bloomberg data? 

Sybase have acquired Aleri according to Finextra. It was less than a year ago when the complex event processing (“CEP”) vendors Aleri and Coral8 announced their merger (see press release); there was also a big buzz when Sybase announced a CEP capability based on Coral8 and Streambase decided to offer an Amnesty Program for Aleri-Coral8 Customers (see earlier post 'Merging in public is difficult...). And only a few months later, Microsoft announced that their CEP Orinoco (now integrated with SQL Server 2008 as StreamInsight) was heading to market (see post 'Microsoft CEP surfaces as 'Orinoco').

Another sign that CEP is moving more mainstream and that real-time everything is becoming more important? Or a good market for acquisitions?

You can talk about more robust modelling, more stringent scenario testing and even moving everything onto an exchange, but unless we move the principles of good data management (in my view: consistency, security and quality of all types of data) into the front office then we will continue to get front-office mis-marking as described in this article in the FT.

Thanks to Ralph Baxter from Cluster7 for highlighting this article for me and those of you interested in this topic of operational risk and spreadsheet mis-use should maybe go along to EuSpRiG this year, and maybe take a look at a paper Xenomorph presented at a previous conference.

Decent article(and title!) explaining ETFs in FTfm today - growth of the market sounds impressive, from $40bn in the year 2000 to over $1,000bn under management now. Seemed like a bit of a day for new financial products in the FT, with the LSE announcement of opening up direct bond trading to retail investors through offering corporate bonds issued in sizes well below the usual £50,000 size (and catching up with more usual practice in Europe). Whilst not a retail product (I guess some of us already have life insurance?), longevity derivatives seem to continue their rise too in liability driven investment.

Meanwhile over on Linkedin, Structured Products magazine are asking just what constitutes a "complex" product? A decent question since complex products are not necessarily risky, but certainly "complexity is in the eye of the beholder" is most likely answer in my view - echoing a growing problem in finance, regulation and economics at the moment; there are too many people searching for the unique "right" answer to questions that simply do not have one. Maybe we should stick to the answer to everything being "42" and give up the search for the question?...

Interesting panel debate at RiskMinds Wednesday morning, entitled "Sophisticated Complex Models vs. Crude Robust Risk Measures".

Riccardo Rebonato of RBS started off the debate in (untypically?) controversial style by saying that he thinks that the risk management models (mostly VaR) used in financial markets are peculiar. Peculiar in that coming from a physics background he is used to models that have "causal" links between inputs and outputs, whereas VaR is based simply on the P&L distribution of a portfolio i.e. all the information is contained in the data itself. Riccardo said the obvious analogy was with chartism, where decisions are made on the observed market data itself without any reference to external (exogenous) factors at all (perhaps he should have a discussion on endogenous risk with Jean-Phillippe Bouchard at Quant Invest). Riccardo suggested that in the range of models from those that are "over specified" with two many inputs to those in "reduced form", then VaR was far too much at the reduced form end.

In response to Riccardo's proposal that risk models should involve more causal ("factor") effects, Andreas Gottschling of Deutshe Bank countered with the quote from Harry S. Truman "Give me a one-handed economist! All my economists say, On the one hand on the other.". To which Riccardo acknowledged that maybe Economists and Econometrics were less suited to trading/analyst reports (e.g. give me a single view of what the prospects/returns will be) and more suited to risk management (e.g. give me a range of scenarios with supporting assumptions for each).

Chris Finger of RiskMetrics moved on to put forward an argument for standardisation of risk reporting, saying that it was impossible to say what methodology was behind the VaR numbers disclosed by major financial institutions. He proposed that risk reporting needed to be standardised and obligatory, but emphasised that risk management should not standardised. Paul Shotton of UBS agreed, saying that whilst micro-prudential risk of Pillar I had decreased risk on an individual institution level, it had increased systematic (macro) level risk and this was an area of failure for the regulators. On this the panel agreed, echoing a lot of what Avinash Persaud said in proposing the more diversity of risk management was highly desirable.

On standardisation, Riccardo noted that many banks had switched from using 10-day to adjusting up a 1-day VaR, and as a result presenting a less risky picture to analysts and regulators, regardless of how risky the "tail" of each institutions' P&L distribution is. Riccardo also proposed that there should be "constructive ambiguity" over what is asked of the banks by the regulators - put another way he suggested the regulators should come up with the "curriculum" for risk but not the "questions", as definitive questions encourage arbitrage.

Andreas then brought the debate back to its title, and put forward that maybe VaR should be replaced by simpler measures such as limits on notional traded. Paul suggested that VaR was only good for simpler products and portfolios, under "normal" market conditions. He said that he had been an advocate of more stress testing for a long time as a complimentary approach to VaR, but also combined with the simpler approach of limits.

It was an interesting debate, particularly with Riccardo's proposal on VaR being too simple a measure based on statistics, and wanting a more "causal" model to be developed. Using the example of June 2007, Riccardo said that everyone knew something big was about to happen but this was not reflected in VaR calculations since they are statistically based and inherently backwards-looking and not predictive. The lack of prediction is a very valid point, but putting forward a counter-view, then I get the argument about economists giving a range of outcomes, but surely these should be fed into the scenario engine rather than trying to develop econometric models of relationships between market variables. Econometric models are just as vunerable as any other to the mis-behaviour of markets (anyone seen a stable correlation lately?).

A few of the other risk managers there expressed other views, from the more buy-side folks who were more comfortable with factor-based modelling, to risk managers who said that VaR was already "structural" with explicit relationships between valuations and interest rate inputs for example. It would be good to understand more of Riccardo's ideas on this, since it appeals from making risk a more "forward-looking" process but I find it difficult to quite grasp what "causal" model you can have of markets that is itself robust to changes in market behaviour.

Avinash Persaud of Intelligence Capital gave the opening talk of the morning at RiskMinds (see first of set of posts from last year here) and put forward a lot of the very good ideas that he has contributed to in the recent Warwick Commission Report. Main points that Avinash made:

• Regulators were admirably quick in working out where past regulation had gone wrong in focussing too much on micro (individual institution) rather than macro (whole market)/systematic risk.
• The regulators then came out with promising papers on counter cyclical regulation and other positive ideas.
• These new ideas do not win votes however and do not satisfy the public's desire to punish someone - Avinash called this the "Bad Apple" policy, with "bad bankers, bad products, bad jurisdictions" being the perceived guilty parties.
• All past crises have resulted in demands for three things: i) more risk management; ii) more regulation; and iii) more transparency.
• These are fine as demands but evidently do not prevent financial crises.
• Avinash recalled his work back at JPMorgan in the early 90's when the 4:15 report was produced for Sam Weill, which eventually led to VAR reporting becoming widespread.
• He then fast forwarded to the Asian crisis of 97 where he saw the failings of VAR (or rather its widespread use) first hand with all players using VAR which when volatility increased caused an increase in VAR causing JPM (and all) to sell causing markets to fall, increasing vol causing more selling, increasing correlation and leading to what is called the "loss spiral".
• In light of the recent crisis, Avinash said the public perception is that bankers created a load of toxic bombs (products), through them at an unsuspecting public and ran away...
• ...and in his opinion the reality is that banks created a load of toxic bombs and ran straight towards them i.e. this was a failure of risk management where bankers did not understand the risks they were buying and selling.
• He then took us back to the 1950's and the formation of modern portfolio theory with Markowitz and Danzig working at the RAND Corporation.
• At that time banks and insurers were still separate, with FX and capital controls still in place meaning that not only could the "efficient frontier" of investment portfolios be observed but it could also be acted upon.
• Now everyone has the same information everyone can observe the efficient frontier of investment opportunities but cannot exploit or act upon it, since usually everyone moves in (the "herd") and the value observed is changed by this crowded participation in the market. Here he seems to be echoing a lot of what Bob Litterman said at QuantInvest last week over the "crowded trade" and that the barriers to market knowledge and our ability to act on this knowledge have been lowered forever.
• Avinash put forward that many of the models we use today assume the statistical independence of decision making process whereas the reality is that the market is homogenous (everyone is thinking/acting the same) and hence these models are invalid in this "crowded" context.
• In light of this, the problem of risk management is not about exogenous risk (risks from outside the market, from Black Swan events to normal distributions) but more about endogenous risk i.e. peoples behaviours upon seeing opportunities cause strategic risks. (Interesting given Jean-Phillippe Bouchard at QuantInvest commenting on what makes prices move). Put another way, behaviour is the issue not the financial instruments themselves.
• Avinash proposes that risk capacity (the ability of an institution to absorb a particular type of risk) shoudl be thought through more fully, with for example insurance and pension institutions with long-term liabilities having a much greater capacity to absorb liquidity risk than banks, and banks with short term funding being a better position to manage a loan book.
• He pointed out that regulation that uses market prices to protect us against movements in market prices is doomed to failure before it starts.
• Booms occur due to some perceived "paradigm shift" technolgy leading to dramatically improved risk/return ratios - he cited things such as cars, electricity, rail, dotcom and the mantra from those involved that "This time it is different..." (see "bubble" post from last year)
• Avinash thinks the regulators are significantly to blame for the last crisis since they themselves said the latest financial innovations in credit derivatives were making us safer through sharing out risk in the system.
• He said that there is no theory for making a complex system "safe" as a whole and that the regulators did not/do not "get" this idea.
• Diversity of approach and risks in a large systems (macro financial markets) is our only current defence and regulatory "best practice" has driven conformity not diversity in the market, making systemic risks higher not lower.
• So the regulators are themselves creating a homogenised market.
• In terms of solutions, he proposes that risk and audit committees need separating so that risk management does not become a "tick box" exercise.
• He further proposes that the risk management function is given some capital so that it can place hedges at a macro level for institution (i.e. looking at the resulting risk when divisional risks have been aggregated) - here is proposing moving to risk "management" as opposed to the much more common risk "reporting" found in many institutions.
• One risk management indicator idea he proposed was to put a portfolio management model together that was linked to VAR in order to see where the "herd" is moving to (e.g. low vol, high return Asian markets of the past etc) and to move or hedge against this.
• He is concerned that applying Basel II regulation to the Insurance industry with Solvency II will mean that all players will be dancing to same VAR tune which will introduce more risk as more institutions are forced to react in the same way to market movements and volatility.
• On the same lines, Credit Rating Agency regulation will create barriers to changes in ratings methodology in response to endogenous market risk, again meaning that everyone will be forced to behave and act in the same ways.
• He summarised that "endogenous risk" (movements in the market caused by the market) and not statistical distributions that are the key issue and diversity is the only solution.

Entertaining speaker with some interesting ideas that fly in the face of much of what is being done by the regulators today, and generally well received by many of the risk managers present. Behavioural finance and the "crowded trade" (i.e. everyone doing the same thing in the market causing movements within the market) seem to be key themes occuring in a lot of what academics and practitioners have said on risk management recently. Now what to do about it? Not sure that less (not more) regulation will find many fans at the moment...answers on a postcard please!

I attended the Quant Invest 2009 event for the first time last week in Paris. The event is unsurprisingly about quantitative investment strategies, but with an institutional asset manager and hedge fund focus - so not so much about ultra-high frequency trading (although some present) but more about using quantitative techniques to manage medium/longer-term investment decisions and applied portfolio theory. A few highlights below that I found interesting:

• Pierre Guilleman of Swiss Life Asset Management gave an interesting 1/2 day workshop entitled "A random walk through models":
• He is a strong supporter of the need to understand more about the data and statistical assumptions upon which any quant investment model is based and how these fit with the desired investment objectives (similar to the Modeler's Manifesto)
• He made the point that good models can sometimes be almost annoyingly simple, and cited the example by a Professor Fair of Yale who had determined that US elections were predictable based on simple parameters such as past results, inflation and gdp and that policy did not seem to be a key factor at all - annoying for the politicians anyway! 
• Pierre seems very concerned that the Solvency II regulation applied to Life Institutions will negatively influence the investment policies of many institutions - applying sell-side risk measures like VAR to the insurance industry will drive a more short-term approach to investment. He strongly believes that VAR applied to his industry should have an expected return parameter introduced to fit with longer term investment horizons of 10 to 25 years.
• Bob Litterman of Goldman Sachs Asset Management opened the first "official" day of the conference:
• Bob put forward his "scientific" approach to investment modelling going through the stages of hypothesis, test and implement. He warned against overconfidence in investment (apparently 70% of us think we are "above average"...) and impulsiveness (quick impulsiveness test: "if a bat costs $1 more than the ball, and the bat and ball together cost $1.10 then how much does the bat cost?...") 
• He said that the failure of quantitative investment models in 2007 needed to be understood given the success of quant models over past decades. In particular he thought that quant investment became the "crowded trade" of 2007 with every hedge fund having a quant investment strategy. In terms of why this became a "crowded trade" Bob thinks that the barriers to entry into quant investment (particularly technology) have lowered significantly recently.  
• He noted that factor-based investment opportunities decay quicker than they used to due to increased competition - implying the need for a more dynamic and opportunistic investment approach.  
• GSAM are now looking at new markets and new investment instruments, trying to find areas of market disruption but without following what others are doing in the market.  
• He pointed out the conflict between investors wanting more transparency over what is done for them, against the need to be more proprietary about the investment models developed.  
• Next there was a talk on regulation from the French regulator that was dull, dull, dull both in terms of content and presentation style (when will regulators actually prepare well for the talks they give?)
• Panel debate was also pretty average, with the word "alpha" being used too much in my view - asset managers of a certain type seem to hide behind this word as an opaque "magic wand" to justify what they do.
• Jean-Phillippe Bouchard of Capital Fund Management did a great talk called "Why do Prices Move?". Some points from the talk:
• He started off with a reminder about the Efficient Markets Hypothesis (EMH) and how it says that crashes and market movements are caused by events outside (endogenous to) the market such as news, events etc.
• He then said this was not born out in the data, where extreme jumps in prices were only related to news only 5% of the time.
• Volatility looks like a long memory process with clustering of vol over time - similar to behaviour in complex systems
• The sign of order flow is predictable but the price movement is not, with only 1% of daily order volume accounting for price movements over 5%
• Even very liquid stocks have low immediate liquidity, meaning that price movements can play out over many hours and days as liquidity is sought to "play-out" some change in fundamental price levels.
• Joseph Masri of the Canadian Pension Plan Investment Board then did a good talk on Risk Management:
• Jo said that sell-side risk was easier to deal with in some ways since it involved fewer strategies in high volumes, and hence could be better resourced.
• Buy-side quantitative risk was harder due to its reliance onsell-side research and risk tools, the outsourcing of credit assessment to the credit rating agencies, the loss of Bear and Lehman's having caused the buy-side to have to do more risk management itself (and through third parties) rather than rely on the sell side risk management tools.
• He said that sell-side risk models are a good start for an asset manager, but need to be adapted to give both absolute and relative risk (to a benchmark fund for instance). All models are no substitute for risk governance.
• He described the cross over from risk methods: VAR, stress testing, factor-based and their applicability to market risk, credit and counterparty risk.
• Like Pierre he was not a fan of 1 or 10 day trading VAR being applied to investment managers since this risk measure was not suitable for long term investment in his view.
• On stress testing he said this needed to be top down (using historical events etc) as well as bottom up from knowing the detail of strategy/portfolio.
• In terms of challenges in risk management he said that VAR needed more stress testing to cope with the fat tails effect in markets, that liquidity risk both of counterparties and of illiquid products was vital and the importance of stress testing (he mentioned reverse stress testing) plus also the feedback (crowding effects) of having similar investment strategies to others in the market.
• Dale Gray of the IMF gave a very interesting talk on how he and Bob Merton have been applying the contingent claims model of a company (looking at equity in terms of option payoffs for shareholders and bondholders) to whole economies:
• He said that some of his work was being applied to produce a model for the pricing of the implicit guarantees offered by governments to banks
• He said these models were also applicable to macro-prudential risk
• Very interesting talk, and if he really has something of macro-level risk then this is great relative to the wooly approach by the regulators so far

There were some other good talks from Danielle Bernardi on Behavioural Finance, Martin Martens on Fixed Income Quant Investment, Vassilios Papathanakos on Stochastic Portfolio Theory (seemed to be a "holy grail" of investment model, giving good returns even in the crisis - begs the question why he is telling everyone about it?), Claudio Albanese on unified derivative pricing/calibration across all markets (again another "holy grail" worth more investigation) and Terry Lyons on speeding up monte carlo simulations.

Overall a good conference although the quality of the asset managers present seemed very digital from those who really seemed to know what they talking about to those who plainly did not (in my limited view!). Along this line of thought, I think it be good to test whether there is an inverse relationship between the quality of the asset manager and the amount of times they use the word "alpha" to explain what they are doing...

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