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Interviews &
Columns
By michael decker, bda
BONDING TIME with Michael Decker of the Bond Dealers of America and featuring Peter Borstelmann of ICE Bonds
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The BDA’s regular podcast series on bond market technologies and the impacts on market structure
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Mike Decker, BDA:

BDA is pleased to welcome Peter Borstelmann to our next edition of our fixed income podcast series. Peter Borstelmann is president of ICE Bonds, which is part of the fixed income business at Intercontinental Exchange. Peter oversees a team that's responsible for ICE's fixed income trading platforms including Bond Point, TMC Bonds, and ICE Credit Trade, as well as ICE ETF Hub, a new primary market trading platform for ETFs.
Prior to joining ICE in 2014, Peter was a director at Barclays' Prime Services, responsible for managing the US over the counter clearing business. He joined Barclays in 2004 after receiving a BS in finance and entrepreneurship from Villanova University. Thank you again, Peter, for joining us. Let's start by talking about SEC rule 15c2-11. This is one of BDA's highest advocacy priorities. 15c2-11 has been in the SEC's rule book for 50 years, and all that time it's been a penny stock rule, applied to quotations for over the counter equities. The rule requires a trader before publishing a quotation to a quotation medium to review certain issue or financial filings and other issuer information and ensure that all that information is available publicly.
The SEC this year decided that the rule will now apply to fixed income as well. They provided a staff no action letter for some relief, but many fundamental compliance questions associated with applying the rule to fixed income quotations remain. So Peter, are there activities that traders might conduct using ICE Bonds' products or services that would meet the definition of publishing a quotation to a quotation medium in the context of the SEC's new interpretation of rule 15c2-11?

Peter Borstelmann, ICE Bonds:

Thanks, Mike. And I appreciate the opportunity today and appreciate your efforts and the collective efforts around this rule. I know it's taking a considerable amount of time and focus over the past few months. I think after a lot of that effort, we did get a bit more clarity and guidance around how this rule will impact the fixed income markets and how broker, dealers, clients alike need to operate with this rule in mind. And when you look at ICE Bonds, being an ATS or a series of ATS platforms through ICE Credit Trade, Bond Point, and TMC, it definitely had us concerned about what the impact would be. And we are obviously mindful of liquidity potentially ceasing for a while as people evaluated how this rule impacted their day to day operations.
As we looked and worked with the SEC in conjunction with you and SIFMA, and we got that clarity that when you look at an ATS and you look at how we operate and how some of our peers operate, whether they're at ATS or not, we do fit the definition of a quotation medium. And the obligation will fall on those that are providing liquidity to make sure that they're checking the bonds, the [inaudible 00:03:03], that they're quoting to make sure that it's in compliance, there's publicly available information.
As an ATS platform, we're looking at further ways to help give that guidance to liquidity providers, but it really falls within our ICE Data Services group, which is part of our bids division, that is working to help the liquidity providers comply with this rule and build out the appropriate policies and procedures to make sure that they're checking that what they're providing quotes on is in compliance. And I think ultimately it comes down to these entities doing the homework, understanding the rule, and making their own interpretive decisions as to how they need to make their businesses comply.
So far, with a few weeks into the year and the rule kicking in, we have not seen a material drop off in liquidity. There are certain segments of the market where people are treading carefully and making sure that the necessarily information is obtainable. But by and large, liquidity has not dropped off, which is especially important given the volatility that we've seen over the past few weeks.

MD:

Good. That's good to hear. We recently had a conversation with FINRA staff that are working on building an examination program for this rule in fixed income. And one bit of good news they told us is they definitively said that they aren't yet examining dealers for compliance with 15c2-11 and fixed income. So let's hope that they maintain that status for a while. And we and SIFMA are also looking at possibly at requesting guidance on some open compliance issues from the SEC, so that exercise might shed some light on how to comply with the rule as well.

PB:

And I think what I'd add there is the SEC is just looking at ways to further electronify the market, not impede the good progress that has been made over the past few years, so I think it's key that they're not looking to enforce and they're not looking to examine. And I think as firms show good faith and work towards implementing a solution, I think that will bode well and go a long way with the commission.

MD:

I think so too. So let's talk about the year ahead for ICE Bonds. What are your plans for 2022?

PB:

Yeah. We have a lot in our priority queue. And as you mentioned in your kind introduction, ICE is very uniquely positioned and we have a number of different assets within our portfolio. I can probably spend the whole podcast talking through, but I figured we'd just focus on a few key themes, and one of those being the intersection of execution and data is becoming more and more transparent, especially over the course of the pandemic. And the key theme that we hear and see is: How can we help our counter parties do more with less? And one of those has to do with helping them get key market data or data and analytics into their various platforms, or what we call upstream integration.
So working with external vendors such as the LMS platforms, the dawn of more and more fixed income EMS platforms, to help our customers get the necessary data and analytics into their platform so they can execute more efficiently and work again with, do more with less. So that's definitely a big thing and theme of what we're trying to achieve within ICE Bonds. And then continue to build upon some of the work that we've been doing over the past two years as we venture into more of the institutional sized trading. When you look at the assets that we've acquired over time, the Bond Point and TMC footprint was more retail wealth focused. So we're continuing to build on that strength, but also, looking to expand our protocols and broaden the community within ICE Bonds.
And I'd say the last is focusing on the muni market. It's such a fascinating component of the fixed income landscape with so many different instruments to trade, and so much going on with the changing regulatory space and expected rate environment. The munis are a differentiator within our portfolio, and we're working with customers and our clients to figure out how we can innovate and bring more trading protocols and solutions to that space.

MD:

Sounds like a busy year. How do you differentiate yourself from your competition?

PB:

When you look at the way that ICE has ventured into the fixed income space through the acquisition of IDC and then the acquisitions of Bond Point and TMC, we are very uniquely positioned in bringing together a very broad range of solutions for fixed income trading and risk management. By pooling together various assets across the execution, our strengths in muni as well as the data side, we feel we bring a very unique proposition compared to some of our peers. And you're starting to see that resonate with our subscriber base as we start to pull together our various data offerings alongside execution.
I think you couple that with some of the unique instruments that we have, such as our derivative support through our legacy credit act solutions, or the unique assets that we've created through the ETF hub or our fixed income select platform, which helps bring together our data and execution in a unique ecosystem.

MD:

Great. You mentioned a few minutes ago the pandemic. How have you all managed through the pandemic? Was it relatively easy to move from work in the office to work at home and back? And what lessons have you learned from the experience?

PB:

Yeah. It's been an interesting journey. When you dig back to, call if February or March of 2020, and being that we're almost two years into that, I remember before we left, we thought we'd be leaving the city for a week or two, and we'd reconvene. And hard to believe, two years later. I'd say it was relatively seamless. And we within ICE, but I think the collective industry has proven that we can operate in an environment where teams are separated and logistics are fractured, when historically people were afraid that it would not work. And that's why there was hesitation to kind of give that flexibility.
So I think it's been great that people can be nimble and flexible, but I do think, and you hear this consistently within ICE, but also with some of our peers and our customers, the day to day interaction, the human interaction is missing. And the longer that this goes on, the harder that it is. And what we've seen through getting in front of clients or getting back together with the teams, the conversations are that much more fruitful and productive. So we are clamoring for that time where going back to the office becomes more consistent, and having that face to face dialogue, both internally and externally.
That being said, I think you are going to see more flexibility going forward because it does work. And I think the benefits of being able to have a bit more family time, or have flexibility to work from the comfort of your home or a different location are invaluable. And people have learned to adapt to that. I think one consistent thing that I see and have heard is through this whole pandemic, people are working that much harder. Right? The break point between home life and professional life has really become blurred, so people are working incredibly hard, but perhaps not the most efficiently or the smartest. And I think once you start to get back to that in the office setting, you'll start to see even more efficiency come back into the mix.

MD:

What's your status currently? You have sort of a hybrid system, some people coming in some days, but not all.

PB:

Yeah, so we initially started, which was the common rotational colors or numbered teams, but as the pandemic became more intense in the early days, we went to a full work from home model. And then ICE has been really accommodating throughout the whole pandemic in giving flexibility, but it's etched in our DNA that the collaboration and the camaraderie of being together in an office. So we have opened our offices. We were doing a mandatory Tuesday, Thursday rotation to have everybody come together to have meetings, to have that collaboration, and then separate for a few days to social distance and get back to kind of that hybrid style.
With the recent spike, we have relaxed the mandatory requirements for Tuesdays and Thursdays. And senior management is evaluating when we come back in. But I think we're all hopeful that we'll be able to come back together soon and get that collaboration going again because the difference that we saw once we had that mandatory within ICE Bonds, things that would take a couple of days in the heart of the pandemic, things were getting done in a matter of minutes because you had that water cooler talk or side by side conversation with your colleagues, and idea generation thrived that much more.

MD:

Right. Let's talk about the broader market and industry. What's your sense of the general state of the fixed income trading markets? How are liquidity and trading volumes? And is the market functioning in a healthy way?

PB:

Yeah. I think as you look at fixed income markets, as it pertains to ICE Bonds and our customer segment, there was a pullback in liquidity as people evaluated which instruments to invest in. But you're starting to see that come back as we're going into a changing rate environment. But I think when you look at the fixed income market in general, more and more electronification, the advent of portfolio trading as a way to manage and off lay risk is becoming a staple in the ecosystem. The growth of fixed income ETFs over the past few years has been exponential, and that's playing a part in the growth of certain fixed income electronification.
I think that's a trend that you're going to see for some time. And I think the pandemic has helped in that regard too. Again, as people are fractured from the normal work environment, the need for again, managing more with less has become even more apparent. And you see individuals looking to automate certain segments of the market so they can put more time and focus on bigger or more targeted trades.

MD:

And where are the biggest growth opportunities for ICE? Where is the market growing in a way that ICE is positioned to take best advantage?

PB:

I think it's kind of twofold. I think there's the execution side. And there are a number of areas where we feel we can enter into and offer a compelling solution to some of the incumbents. But I think when you look at the broader picture, it's growth in institutional trading, which is not something that historically ICE has been involved in. But with our technology and data, we're making inroads to that segment of the market. Piggybacking off of the strong foundation that we have through our unique ATS liquidity, through that retail wealth network that we've created through the acquisitions of Bond Point and TMC.
And as the markets become more electronified, as the fixed income markets continue to thrive, we really think that our data solutions are growth opportunity. And that's where our customers continue to gravitate towards, whether it be our pricing, our analytics, the need for data, as algorithmic trading or systematic trading grows, the data is very attractive.

MD:

It seems that some segments, some corners of the fixed income markets have been slower to transition away from voice and towards electronic execution. Institutional municipals is one segment that comes to mind. What's going on there?

PB:

Yeah. It is a segment of the market that has been slower to adopt. I think we're starting to see signs of that transition. Historically, part of the driver and reason for that why the market's been slower to transition away from voice to electronic had to do with the larger bid ask spreads compared to some other products. And there was just that maintaining of that legacy way of executing. We're starting to see more institutional activity come into the muni space, especially with the growth of taxable muni products. And we believe that over time, especially as things start to open up with the changing rate environment, see more institutional activity and the muni space.
But I think it also takes innovation and figuring out how we can bring efficiency into that execution process, and evidencing that to help make that transition over. And that could be through additional trading protocols. It could be through improved analytics or curve information to get people comfortable from moving from the old voice ways over to electronic. So that's what we're working on with our customers, is identifying where pain points reside and figuring out how we can use our technology to help bring that efficiency that they seek.

MD:

That makes a lot of sense. Let me ask about T plus one. So the new chair of the SEC, Gary Gensler, has said that he wants to pursue a transition from T plus two to T plus one during his administration. I know that there have been industry working groups that have begun mapping out what that transition might look like. It feels like T plus one is coming. It feels like it's just a matter of time. Is it too early to begin preparing?

PB:

No, I don't think it is. As a matter of fact, individuals within my team are already starting to work to prepare for this. There are some segments of the market, the treasury space, that already settled T plus one. And there is already flexibility from a trading perspective to manage different settlement dates. I think where the bigger impact will be is on the backend, and making sure the respective custodians, prime brokers, and most importantly, the clearinghouses, they are set up for this.
So I know that there are meetings and conversations going on to prepare for this. There are pages of past playbooks that the industry can use. But I think the biggest thing to ensure that this is a success is just good collaboration and partnership to make sure that everybody's aligned, all of the technology is being developed in parallel, and then the proper testing is done before it's deployed.

MD:

Right. Absolutely. What are the biggest risks your business is facing? And what are your biggest concerns for the broader fixed income markets?

PB:

It's a good question. I think growing regulation is always a concern, and just being mindful of what the regulators may be thinking. So it's ensuring that you have an open and constructive dialogue so there are no surprises akin to what happened with 15c2-11, and making sure that people are aware of regulation that's coming down the pipe. The growing proliferation of platforms and what does that do the market, there are plenty of platforms that are popping up, protocols are becoming commoditized, so people are seeking other avenues of execution.
Does that lead people to move away from platforms into dark pools? What does that do to liquidity and transparency? So it's making sure you're developing the right working relationship with liquidity providers and liquidity takers to offer a solution that encourages them to continue to electronify the market. There's obviously market turbulence. One of the pain points that we've had from, in ICE Bonds perspective, has been the low rate environment. So how long does that persist? And I think the expectation is that over the course of 2022, the Fed will change that position, which is I think long overdue and is needed to help combat some of the inflationary circumstances that we're seeing within the US.

But if that doesn't happen, what does that do on liquidity? And does it push people away from fixed income into other asset classes to seek better yield and return? So those are some of the concerns that we have.

MD:

And let me just, one last question, let me just finish with this. Where do you think collective industry work through trade associations like BDA or through other venues would provide the most benefit to the industry and the market?

PB:

Listen, I think you guys have been extremely valuable in a number of aspects, but most recently, obviously 15c2-11. But I think it's continuing to work with the industry to identify ways and for advocacy to help bring more stability to the fixed income markets, and position the industry to have a better path towards more electronification, and trying to break down hurdles that may exist that are preventing that growth. I think everybody is keen on making these markets more efficient from an operational perspective, a risk perspective, and economic perspective. And I think firms and institutions such as BDA, can play an instrumental part in helping, using the cliché, herd the collective cats to come to a solution. I think there's some things percolating about from a regulatory perspective, whether it be new rules around derivative trading in the fixed income space, or advocacy and guidance to make sure that there's a cohesive view message.

MD:

Peter Borstelmann, thank you very much for your time. We appreciate your being with us today, and thank you for ICE's continued support of BDA and our activities.

PB:

My pleasure, and our pleasure to take part in this. And we appreciate BDA and your partnership throughout the years.

MD:

And thanks, everyone, for listening.