I am pleased to be here today to
discuss the evolution of our equity markets and the appropriate
role for policymakers in this period of rapid change. Publicly
traded equities are a significant source of capital for firms, and
equity markets are a key part of the process of allocating capital
among competing uses in our economy. Through issuance of equities,
firms enable broad sets of investors to share in the risks and
rewards of economic activity. The pricing of existing capital
assets plays an important role in directing investments in new
capital assets.
Today, equities constitute a
substantial portion of the net worth of households, both direct
holdings of shares and indirect holdings through mutual and
pension funds. In addition, U.S. equity markets are a significant
factor in the international competitiveness of our finance
industry. For these reasons it is vital that our public policies
foster equity markets that remain efficient, innovative, and
competitive.
In my remarks today, I shall be
expressing my own views and not necessarily those of the Federal
Reserve Board. I shall endeavor to set out a few broad principles
that I believe should govern the evolution of our stock exchanges.
Clearly, however, Chairman Levitt and his staff at the Securities
and Exchange Commission (SEC) have enormous expertise that must be
brought to bear on this issue, and they, along with the Congress,
should lead the way in formulating and implementing appropriate
public policies.
Implications of Changes in
Technology
More powerful and functional computers and newer
telecommunications technologies, in combination with deregulatory
innovations by the SEC, have facilitated the development of new
trading venues for equities. These new venues offer investors a
wide range of alternatives for entering orders and executing
trades. Some of the new trading mechanisms also offer speedier
executions or greater anonymity, which are important to some types
of investors. Many allow customer orders to be matched directly,
without the traditional intervention of a specialist or market
maker. As alternative trading venues proliferate and flourish,
they have attracted increasingly larger volumes from the Nasdaq
market and to a lesser extent from the other exchanges. This
competition among trading systems in the short run has resulted in
market fragmentation not all orders to buy and sell securities
necessarily have the opportunity to interact with one another.
Concerns that this fragmentation
will have adverse implications for market efficiency and investor
protection are, as I understand it, the prime motivations for this
hearing. The prices established in equity markets, as I noted at
the outset, are a device through which capital is allocated.
Investors rely on them in making portfolio decisions. These prices
should reflect the supplies and demands of participants across all
markets at a given time. Fragmentation thus raises questions about
the quality and completeness of the price discovery process and
concerns that investors' orders to buy and sell securities may not
be executed at the best price or the lowest cost. Fragmentation
also creates the impression, and perhaps the reality, that
separate pools of liquidity yield a lower volume of liquidity in
the aggregate. Particularly in times of stress, liquidity simply
may not be there or it may not be there in depth.
But these concerns about
fragmentation must be placed in perspective. Market structures are
constantly evolving, and activity shifts in response to
innovations in trading and the development of new financial
instruments. In the long run, unfettered competitive pressures
will foster consolidation as liquidity tends to centralize in the
system providing the narrowest bid-offer spread at volume. Two or
more venues trading the same security or commodity will naturally
converge toward a single market. One market offering marginally
narrower bid-ask spreads at volume will attract the business of
others, improving its liquidity further, and reducing that of its
competitors. This, in turn, will engender an even greater
competitive imbalance, leading eventually to full consolidation.
Of course, this process may not be fully realized if there are
impediments to competition or if markets are able to establish and
secure niches by competing on factors other than price.
We need to be particularly
careful, however, not to unintentionally and unnecessarily
undermine sources of the extraordinary franchise values that have
been built in to our equity markets, a process beginning with the
Buttonwood Agreement of 1792 that founded what became the New York
Stock Exchange. Participants in our equity markets have succeeded
in concentrating a great depth of liquidity that is the envy of
other nations and a symbol of the United States as the world's
preeminent financial power.
Yet our established markets are
undergoing profound competitive pressures and challenges, which
they cannot fail to meet if they are to survive. The very
financial participants they serve are signaling that our exchanges
may soon become noncompetitive, and their centralized liquidity
could drift to other, presumably far more automated, venues. The
Nasdaq, as I noted earlier, has seen significant volume migrate to
other trading systems. The NYSE and regional exchanges, too,
recognize that investors may increasingly choose to execute their
trades elsewhere.
Just as the market provides
investors' valuations of the long-term prospects of individual
equities trading on exchanges, the market also signals its
assessment of the values of memberships in the exchanges
themselves. It is evident from these evaluations that market
participants appear to be increasingly discounting the earnings
from seats on the NYSE itself relative to the earnings of the
stocks that trade on it. Since 1996, for example, price-earnings
ratios of NYSE stocks have risen by half. The ratio of seat prices
to the underlying earnings from seat leasing has barely budged.
This clearly implies uncertainty about the future of the exchange.
It would be unfortunate if this prized institution symbolizing
American financial hegemony allowed itself to become marginalized.
But if it fails to respond to
technological change, one centralized trading venue, even the
NYSE, can be displaced by another as other trading systems take
advantage of newer technology to offer greater efficiency or to
provide new functions investors value more highly. The transition
process clearly would result in fragmentation a necessary
consequence of the process of competition in the provision of
trading services. Obviously, if fragmentation can be avoided, it
should be. But if we enter such a transition process, it probably
cannot be avoided entirely.
The Role for Policymakers
What, in general, should be the role of policymakers in this cycle
of competition, fragmentation, and consolidation? We would do well
to borrow the advice offered to the medical profession and, first,
do no harm. It has never proved wise for policymakers to try to
direct the evolution of markets, and it strikes me as especially
problematic at this juncture. The structure of our equity markets
is extraordinarily dynamic; hardly a week goes by that a new
trading venue is not announced or an enhancement to an existing
system is not trumpeted. None of us can anticipate which of these
venues will hit upon the combination of services that best meets
the needs of investors. That can only be revealed as competition
establishes winners and losers.
In light of these judgments, I
would caution against the implementation of a government mandate
for any particular form of central limit order book. Given the
pace of change in our markets, it is difficult to contemplate how
a government mandate could be implemented; systems might well be
obsolete before we were half-way through the planning process.
As this technology-led market
restructuring process plays out, there is a role for policymakers
in facilitating the transition to a long-run equilibrium market
structure. Change often proves controversial because entities
currently earning above-market rates of return owing to dominance
over a segment of a market will seek, not unexpectedly, to protect
those returns. Many will argue that the rules, regulations, or
market practices that give rise to such niches are critical for
the continued functioning of markets or are in the best interest
of investors. These same entities, however, will see the need for
additional competition in areas where others are earning above
market returns. It is the obligation of policymakers to cut
through this underbrush and ensure that market participants and
trading venues compete on as even terms as possible and that
property rights of participants be scrupulously enforced.
This suggests a re-examination
of market practices and removal of current impediments to
competition. The testimony by market participants over the last
several weeks offers some suggestions, such as broadening access
to the system by which orders are routed between trading systems.
Clearly, all market participants recommend steps that are in their
own self-interest; this, of course, is not surprising. However,
the role of policymakers is to weigh the rationale for recommended
practices and use regulatory policy to foster competition.
There are other ways in which
policymakers can facilitate the shift to a new equilibrium market
structure through steps to make competition itself more effective.
One area in which endeavors could well prove fruitful is
enhancement of the transparency in markets. The SEC's request for
comment on market fragmentation seeks suggestions to improve
disclosures both by market centers and by brokers about the
handling of orders and the execution of trades. Transparency is a
fundamental organizing principle of markets. Buyers and sellers
should be fully cognizant not only of the characteristics of goods
being bought and sold but also of the costs and methods by which
trading occurs. Only in this way will they be able to signal
through their trading patterns the market venues that best fit
their needs. Retail investors, in particular, should pay attention
to costs other than commissions that may be buried in the
contracts authorizing their transactions. Such costs could include
delayed executions, failures to execute, or forgone profit if
there is no opportunity for price improvement. Disclosure empowers
investors to make explicit choices about those factors that affect
the quality of trade executions and ultimately the returns on
their investments.
Investors also should be
particularly aware of the liquidity characteristics of the systems
with which they choose to deal. Despite the recent market
volatility, the resiliency of our vastly expanded trading systems
has not been fully tested, and there is a risk of complacency.
If investors assume their
everyday manner of dealing will always be possible in stressful
conditions, such an assumption is unlikely to be realized. The
Long Term Capital Management episode was a wake-up call to
institutional investors about the risks of dealing in illiquid
markets. The private-sector group that studied that event the
Counterparty Risk Management Policy Group noted important
deficiencies in the risk management systems of many market
participants. Improvements to these systems should help market
participants better assess the possible consequences of market
illiquidity, whether in the equity markets or in other markets.
But liquidity risk is not just an issue for institutional
investors. Retail investors, too, need to evaluate the
implications of their decisions to deal in particular trading
systems. These investors need to exercise caution when dealing in
illiquid markets, especially on a leveraged basis.
Conclusion
In conclusion, I would like to reiterate my confidence in
competition as the fundamental guide to the organization of our
markets. Although fragmentation has some undesirable consequences,
it is an inevitable part of the competitive process. Fragmentation
signals the value investors place on the services and functions
offered by competing trading systems. In the long run, activity
will migrate to the systems that best meet the needs of investors,
absent impediments to competition. In the short run, policymakers
should not attempt to anticipate the outcome of the competitive
process. Rather, they should seek to remove impediments to
competition and take judicious steps to mitigate the adverse
effects of fragmentation through policies such as enhanced
disclosure. Investors, too, can facilitate this evolutionary
process by carefully evaluating the efficiency of the trading
systems they use and the appropriateness of the trading strategies
they undertake.