FIA EPTA is appreciative of the opportunity to provide an industry review and analysis of the FCA Occasional Paper No. 50, “Quantifying the High-Frequency Trading ‘Arms Race’: A new methodology and estimates” by Matteo Aquilina, Eric Budish and Peter O’Neill (“the Occasional Paper”). The paper is highly relevant for our industry as it touches closely on areas our members are active in within the financial markets as market makers and liquidity providers. FIA EPTA members observe that the methodology applied by the authors of the Occasional Paper has several significant shortcomings. In line with this, FIA EPTA believes it is important to share our feedback regarding the Occasional Paper.
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