Streetwise Professor Critiques BOE Staff Working Paper

Steven Lofchie Commentary by Steven Lofchie

Responding to the findings of a Bank of England staff working paper ("BOE Paper") that favor the liquidity impact of swap execution facilities ("SEFs"), University of Houston Finance Professor Craig Pirrong asked "the dog food question": "If the dog food is as great as the ads say, why don't the dogs eat it? If SEFs are so much more liquid, why don't traders flock to them?"

After criticizing the BOE Paper's findings on liquidity, Professor Pirrong pointed to another of its findings regarding the fragmentation of the interest rate swap along geographic/currency lines, which showed SEFs gaining far lower penetration in Euro-denominated swaps dominated by European banks that are able to avoid the SEF mandate. He noted that "[t]he choices of those who have the choice strongly suggest that the statistical evidence purportedly showing lower execution costs on SEFs is flawed and misleading."

Professor Pirrong emphasized that "there was never a compelling case – or even a weak one – for forcing diverse market users with diverse transactional needs to use a one-size-fits-all execution method." He praised CFTC Chair Timothy Massad's recent call for a "free-to-choose approach" instead.

Commentary

Professor Pirrong's comments on the working paper also pertain to a number of recent studies of the effect of new regulation on liquidity in the debt market: governmental researchers are able to find that new regulations have no negative effects as long as the researchers select the right measures. In the fixed income markets, for example, researchers have found no increase in bid-offer spreads. Further, researchers found significant diminutions in trade size, resulting in positions that take far longer to move out of, as well as the decreased willingness of dealers to take risks when adding a position to their own books.
 
Professor Pirrong is not the first person to raise questions about dog food. For those who want to know more about the subject, we've provided a link to "Investigations of a Dog," by Franz Kafka.

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