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Concept

The evaluation of a Systematic Internaliser’s execution quality is a primary function of a buy-side trading desk’s operational mandate. It represents a critical control point in the institutional investment process, directly impacting portfolio returns and the fulfillment of fiduciary duties. The central challenge resides in quantifying the value of a bilateral, off-venue execution against the public, multilateral liquidity available on lit exchanges.

A sophisticated buy-side firm approaches this task by constructing a multi-faceted analytical framework that moves beyond simple price comparisons to dissect the true cost and benefit of engaging with a specific SI. This framework is built upon a deep understanding of market microstructure and the inherent trade-offs between price improvement, market impact, and the probability of execution.

At its core, an SI is an investment firm that executes client orders on its own account on an organized, frequent, systematic, and substantial basis. This structure presents both opportunities and complexities for the buy-side. The primary opportunity lies in the potential for price improvement, where an SI may offer a price better than the prevailing European Best Bid and Offer (EBBO). This is a direct, measurable benefit to the client.

The complexity arises from the opaque nature of this bilateral liquidity pool. Unlike a central limit order book, the depth and availability of liquidity are not fully transparent pre-trade. Therefore, the buy-side firm must develop its own intelligence layer to assess the quality and reliability of each SI relationship.

A firm’s ability to systematically measure SI performance is a direct reflection of its internal data architecture and analytical capabilities.

The regulatory landscape, particularly MiFID II, provides a foundation for this evaluation. It mandates that SIs publish firm quotes for liquid instruments and report on execution quality through standardized reports like RTS 27. These reports offer a starting point, providing data on price, costs, and likelihood of execution. A truly effective evaluation, however, goes much further.

It integrates this public data with the firm’s own proprietary trade data to build a granular, historical picture of each SI’s performance under various market conditions and for different types of orders. This internal analysis is the only way to move from a generic assessment to a tailored, actionable strategy for allocating order flow.

The objective is to create a system that can answer fundamental questions about each SI relationship. When an order is routed to an SI, is the firm consistently receiving a better outcome than it would have on a lit market? What is the implicit cost of this execution in terms of potential market impact and information leakage? How does the reliability of the SI’s quotes change during periods of market stress?

Answering these questions requires a disciplined, data-driven approach that treats SI evaluation as a core component of the firm’s overall execution strategy. The ultimate goal is to build a dynamic routing policy that leverages SIs for their strengths while mitigating their inherent risks, ensuring that every execution contributes positively to the portfolio’s performance.


Strategy

A robust strategy for evaluating Systematic Internaliser (SI) execution quality is built on two pillars ▴ a qualitative assessment of the SI’s operational model and a rigorous quantitative analysis of its execution data. This dual approach allows a buy-side firm to understand both the “how” and the “what” of an SI’s performance, creating a comprehensive picture that informs trading decisions and routing logic. The strategy must be systematic, repeatable, and integrated into the firm’s broader Transaction Cost Analysis (TCA) framework.

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Qualitative Assessment Framework

Before any quantitative analysis can be meaningful, the buy-side firm must understand the nature of the SI it is dealing with. SIs are not a monolithic group; they operate with different business models and risk appetites. A qualitative framework helps categorize SIs and sets the context for interpreting performance metrics.

  • Business Model Analysis ▴ The firm should determine if the SI is primarily an Electronic Liquidity Provider (ELP) or a traditional bank desk. ELPs often use high-frequency trading strategies and may offer very competitive pricing on standard orders in liquid stocks, while a bank’s SI may have a greater capacity for larger, more complex orders due to its access to a larger balance sheet and different risk management capabilities.
  • Transparency and Communication ▴ The quality of the relationship with the SI is a significant factor. A valuable SI partner will be transparent about its operating model, provide clear explanations for its execution outcomes, and be responsive to inquiries. Regular review meetings are essential for building this understanding and addressing any performance issues.
  • Risk Appetite and Quoting Behavior ▴ The firm should assess the SI’s consistency in providing quotes, especially during volatile market conditions. An SI that frequently withdraws liquidity or significantly widens its spreads during periods of stress may be an unreliable partner for certain types of order flow. This assessment is often based on the trading desk’s direct experience and anecdotal evidence, which is then validated by quantitative data.
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Quantitative Measurement System

The core of the evaluation strategy is a set of key performance indicators (KPIs) that measure execution quality across several dimensions. These metrics should be calculated using the firm’s own execution data and compared against benchmarks derived from market data feeds. This allows for a precise, apples-to-apples comparison of SI performance against both other SIs and public trading venues.

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How Do You Measure Price Improvement?

Price improvement is the most direct measure of the value provided by an SI. It quantifies the benefit of trading with the SI compared to executing on a lit market. The analysis should go beyond a simple average to understand the distribution and consistency of this benefit.

SI Price Improvement Metrics
Metric Description Formula / Calculation Method Strategic Implication
Average Price Improvement (PI) per Share The average amount by which the execution price was better than the EBBO at the time of the trade. (EBBO Midpoint – Execution Price) for buys / (Execution Price – EBBO Midpoint) for sells. Calculated for each fill and averaged. Provides a headline measure of the economic benefit of using the SI. A higher value is generally better.
PI Frequency The percentage of trades that received any price improvement. (Number of Trades with PI > 0) / (Total Number of Trades) Measures the consistency of the SI’s pricing. A high frequency indicates a reliable source of improved prices.
PI at Touch The percentage of trades executed at the best bid (for sells) or best offer (for buys). (Number of Trades at EBBO) / (Total Number of Trades) Indicates the SI’s ability to match the best available public price.
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What Is the True Cost of Execution?

Beyond the headline price, a sophisticated analysis must consider the implicit costs of trading. These metrics help uncover the hidden costs associated with market impact and adverse selection, providing a more complete picture of the total cost of execution.

SI Implicit Cost Metrics
Metric Description Formula / Calculation Method Strategic Implication
Effective Spread Measures the cost of crossing the spread, relative to the mid-point of the public market spread at the time of execution. 2 |Execution Price – Midpoint at Execution| A lower effective spread indicates a lower cost of liquidity. This can be compared to the quoted spread on lit venues.
Post-Trade Reversion Measures the tendency of the price to move back in the opposite direction after the trade, suggesting the trade had a temporary market impact. A negative reversion is a cost to the liquidity provider (the SI) and a benefit to the buy-side. Analysis of the market price at various time intervals (e.g. 1 minute, 5 minutes) after the trade. High positive reversion may indicate that the SI is providing liquidity at a cost that is passed back to the market, or that the firm’s orders are predictable.
Implementation Shortfall The total cost of the execution relative to the price at the time the decision to trade was made (the arrival price). (Execution Price – Arrival Price) / Arrival Price This is a comprehensive measure that captures both explicit costs and implicit costs like market impact and delay costs.

By combining these qualitative and quantitative frameworks, a buy-side firm can move from a simple ranking of SIs to a strategic allocation of order flow. For example, an order for a liquid stock with low urgency might be routed to an ELP-style SI that consistently offers high-frequency price improvement. A larger, more sensitive order might be directed to a bank SI that has demonstrated a capacity to handle size with minimal market reversion, even if the headline price improvement is lower. This data-driven approach ensures that the firm is continuously optimizing its execution strategy to achieve the best possible results for its clients.


Execution

Executing a systematic evaluation of SI performance requires a disciplined operational process. This process transforms the strategic framework into a repeatable, data-driven workflow that generates actionable intelligence for the trading desk. It involves three key stages ▴ data architecture and collection, the analytical engine and scorecarding, and the governance and review cycle. This operational playbook ensures that SI selection and routing are based on empirical evidence, fulfilling the firm’s best execution obligations and enhancing portfolio performance.

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The Operational Playbook for SI Evaluation

A successful SI evaluation program is built on a clear, step-by-step process that is embedded in the firm’s daily operations. This playbook ensures consistency and rigor in the analysis.

  1. Data Aggregation ▴ The first step is to create a unified data environment. This involves capturing and time-stamping all relevant data points for every order routed to an SI. This includes the order’s characteristics (size, instrument, timing), the execution details (price, quantity, venue), and a snapshot of the market state at the time of execution (EBBO, depth, volatility). This data must be sourced from the firm’s Order Management System (OMS) and a real-time market data feed.
  2. Benchmark Calculation ▴ For each execution, a set of benchmarks must be calculated. The primary benchmark is the EBBO at the time of trade. Other relevant benchmarks include the arrival price (the market price when the order was created) and the interval Volume-Weighted Average Price (VWAP) for the duration of the order’s life.
  3. Metric Computation ▴ Using the aggregated data and benchmarks, the quantitative metrics outlined in the strategy section are computed. This should be an automated process that runs daily or weekly, feeding a central TCA database.
  4. Scorecard Generation ▴ The computed metrics are then rolled up into a standardized SI scorecard. This scorecard provides a concise, comparative view of all SI partners across the key performance dimensions of Price, Cost, and Likelihood of Execution. The scorecard should allow for filtering by market conditions, order size, and instrument liquidity to enable granular analysis.
  5. Qualitative Overlay ▴ The quantitative scorecard is then combined with the qualitative assessments from the trading desk. This includes notes on the SI’s responsiveness, reliability during market stress, and any specific issues encountered.
  6. Performance Review and Action ▴ The final step is a regular, formal review of SI performance, typically conducted by a Best Execution Committee. This review identifies underperforming SIs, highlights top performers, and leads to concrete actions, such as adjusting routing tables, engaging with an SI to address issues, or terminating a relationship.
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Quantitative Modeling and Data Analysis

The heart of the execution process is the analytical engine that powers the SI scorecard. This requires a robust data model and a clear understanding of how to interpret the results. The goal is to normalize performance across different market conditions and order types to make fair comparisons.

For example, a firm might use a weighted scoring system to create a single composite score for each SI. This allows for a quick comparison but also allows for drilling down into the component parts.

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How Can We Standardize SI Performance?

A standardized scorecard is essential for comparing different SI venues. The following table provides a template for how such a scorecard could be structured, using a hypothetical weighting system to arrive at a composite score. The weights would be determined by the firm based on its own execution philosophy and priorities.

Sample SI Evaluation Scorecard
Performance Category Metric Weight SI ‘A’ Score (Normalized) SI ‘B’ Score (Normalized) Weighted Score (SI A) Weighted Score (SI B)
Price Average Price Improvement 30% 85 / 100 70 / 100 25.5 21.0
PI Frequency 20% 90 / 100 95 / 100 18.0 19.0
Cost Effective Spread vs. EBBO 25% 80 / 100 90 / 100 20.0 22.5
Post-Trade Reversion (1 min) 15% 75 / 100 60 / 100 11.3 9.0
Likelihood Fill Rate 10% 98 / 100 99 / 100 9.8 9.9
Total Composite Score 100% 84.6 81.4
The consistent application of a data-driven evaluation framework transforms best execution from a regulatory requirement into a source of competitive advantage.

This type of analysis allows the trading desk to make informed, evidence-based decisions. In the example above, SI ‘A’ provides better overall price improvement, but SI ‘B’ offers tighter effective spreads. A cost-sensitive algorithm might favor SI ‘B’, while an algorithm seeking to maximize explicit price improvement might favor SI ‘A’. This level of granularity is the hallmark of a sophisticated execution management system.

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System Integration and Technological Architecture

The successful execution of this evaluation strategy is heavily dependent on the firm’s technological infrastructure. The core components are the Order Management System (OMS), the Execution Management System (EMS), and a dedicated TCA system. The OMS/EMS must be configured to capture the necessary data points for each order, including high-precision timestamps. The TCA system, whether built in-house or provided by a third-party vendor, must have the flexibility to ingest this data, integrate it with market data, and perform the complex calculations required.

The output of the TCA system should then feed back into the EMS’s smart order router, allowing the routing logic to be dynamically updated based on the latest SI performance data. This creates a closed-loop system where performance is constantly measured, evaluated, and used to optimize future trading decisions.

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References

  • Janus Henderson. “Best Execution Policy.” Janus Henderson Investors, 2023.
  • Royal, Dan. “Buy-Side Perspective ▴ A practical approach to Best Execution.” Global Trading, 26 July 2023.
  • “Best Execution Under MiFID II.” ICMA Centre, University of Reading, 2017.
  • Autorité des marchés financiers. “quantifying systematic internalisers’ activity ▴ their share in the equity market structure and role.” AMF, 2020.
  • “Execution Quality ▴ How the Buy Side Measures it; How the Sell Side Produces it.” Coalition Greenwich, 2022.
  • Voigt, Christian. “Best execution or better execution?” The TRADE, 21 October 2016.
  • European Securities and Markets Authority. “Best execution under MIFID.” ESMA, 2015.
  • Deloitte. “Good, Better, “Best” Does your Execution stand up to MiFID II?” Deloitte, 2017.
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Reflection

The framework detailed here provides a system for the empirical evaluation of execution quality. Its implementation, however, is the beginning of a deeper inquiry. A truly advanced buy-side desk views these metrics not as a final report card, but as a diagnostic tool. The data reveals patterns and asks questions.

Why does one SI consistently outperform on small-cap orders during periods of low volatility? What does a sudden shift in reversion statistics for another SI signify about its internal risk management?

Answering these questions requires moving beyond the quantitative data and engaging in a strategic dialogue with your execution partners. The data opens the door to a more sophisticated level of interaction, one where the buy-side can articulate its needs with precision and the SI can better tailor its liquidity. The ultimate objective is to construct a resilient, intelligent execution fabric, where each liquidity source is understood and utilized for its unique strengths.

The quality of your execution is a direct output of the quality of your measurement system. How does your current framework measure up?

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Glossary

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Systematic Internaliser

Meaning ▴ A Systematic Internaliser (SI) is a financial institution executing client orders against its own capital on an organized, frequent, systematic basis off-exchange.
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Execution Quality

Meaning ▴ Execution Quality quantifies the efficacy of an order's fill, assessing how closely the achieved trade price aligns with the prevailing market price at submission, alongside consideration for speed, cost, and market impact.
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Market Microstructure

Meaning ▴ Market Microstructure refers to the study of the processes and rules by which securities are traded, focusing on the specific mechanisms of price discovery, order flow dynamics, and transaction costs within a trading venue.
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Price Improvement

Meaning ▴ Price improvement denotes the execution of a trade at a more advantageous price than the prevailing National Best Bid and Offer (NBBO) at the moment of order submission.
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Buy-Side Firm

Meaning ▴ A Buy-Side Firm functions as a primary capital allocator within the financial ecosystem, acting on behalf of institutional clients or proprietary funds to acquire and manage assets, consistently aiming to generate returns through strategic investment and trading activities across various asset classes, including institutional digital asset derivatives.
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Mifid Ii

Meaning ▴ MiFID II, the Markets in Financial Instruments Directive II, constitutes a comprehensive regulatory framework enacted by the European Union to govern financial markets, investment firms, and trading venues.
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Rts 27

Meaning ▴ RTS 27 mandates that investment firms and market operators publish detailed data on the quality of execution of transactions on their venues.
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Market Conditions

Meaning ▴ Market Conditions denote the aggregate state of variables influencing trading dynamics within a given asset class, encompassing quantifiable metrics such as prevailing liquidity levels, volatility profiles, order book depth, bid-ask spreads, and the directional pressure of order flow.
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Market Impact

Meaning ▴ Market Impact refers to the observed change in an asset's price resulting from the execution of a trading order, primarily influenced by the order's size relative to available liquidity and prevailing market conditions.
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Answering These Questions Requires

A rigorous due diligence process for an evaluated pricing provider is a systemic imperative for ensuring data integrity and operational resilience.
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Transaction Cost Analysis

Meaning ▴ Transaction Cost Analysis (TCA) is the quantitative methodology for assessing the explicit and implicit costs incurred during the execution of financial trades.
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Best Execution

Meaning ▴ Best Execution is the obligation to obtain the most favorable terms reasonably available for a client's order.
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Order Management System

Meaning ▴ A robust Order Management System is a specialized software application engineered to oversee the complete lifecycle of financial orders, from their initial generation and routing to execution and post-trade allocation.
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Arrival Price

Meaning ▴ The Arrival Price represents the market price of an asset at the precise moment an order instruction is transmitted from a Principal's system for execution.
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Management System

The OMS codifies investment strategy into compliant, executable orders; the EMS translates those orders into optimized market interaction.