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Concept

The decision to architecturally fuse a Systematic Internaliser (SI) into a Request for Quote (RFQ) workflow is a declaration of intent. It signals a firm’s transition from passively accepting market structure to actively shaping its interaction with it. You are here because you recognize that the sources of liquidity are no longer monolithic.

They are fragmented, governed by complex regulations, and accessible only through precise technological protocols. The core challenge is one of orchestration ▴ how to build a system that can intelligently and simultaneously solicit liquidity from both public venues and the proprietary, principal-based pools offered by SIs, thereby creating a single, coherent view of the executable market.

A Systematic Internaliser, under the MiFID II framework, is an investment firm that executes client orders on its own account on an organized, frequent, and substantial basis. Functionally, it is a private liquidity source with public obligations. It represents a pool of capital that a firm has committed to deploying, offering quotes that are firm and executable for those it chooses to engage.

This is a source of liquidity that exists outside the central limit order book, accessible bilaterally. Its defining characteristic is the dual nature of being a private counterparty that is simultaneously bound by public transparency rules, a direct consequence of its scale and market impact.

Integrating Systematic Internalisers transforms a standard RFQ process into a dynamic liquidity sourcing engine, essential for navigating modern fragmented markets.

The RFQ workflow, in its foundational state, is a bilateral price discovery protocol. An institution sends a request for a price on a specific instrument to a select group of liquidity providers. Those providers respond with their quotes, and the initiator can choose to execute. Its power lies in its discretion.

It minimizes information leakage by revealing the trade inquiry only to trusted counterparties. When you begin to integrate SIs into this process, you are not merely adding another destination to a dropdown menu. You are building a logical layer into your execution management system (EMS) or order management system (OMS) that understands the unique regulatory and technological identity of an SI. This system must know which entities are designated SIs for which asset classes, under what size thresholds they are obligated to quote, and how to communicate with them using standardized electronic protocols. The integration is the creation of a system that treats SIs as a first-class liquidity source, queryable with the same efficiency and atomicity as any other market destination.


Strategy

The strategic imperative for integrating SI liquidity into a bilateral price discovery protocol is rooted in the mandate for best execution. In a market governed by MiFID II, demonstrating that a firm has taken all sufficient steps to achieve the best possible result for a client is a non-negotiable, data-driven requirement. Architecting a workflow that systematically includes SIs provides a powerful, auditable answer to this mandate. It creates a competitive pricing environment where the proprietary liquidity of an SI is benchmarked in real-time against other dealers and venues, ensuring that the final execution decision is based on a comprehensive view of available prices.

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Why Should You Prioritize This Integration?

The rationale extends beyond regulatory compliance into the domain of execution quality and operational alpha. By building the technological bridges to SIs, a trading desk gains access to liquidity that may not be present on lit exchanges, particularly for large-in-scale (LIS) orders or trades in less liquid instruments. This access can significantly reduce market impact, as the inquiry is contained within a bilateral channel, preventing the information leakage that often accompanies the working of a large order on a public venue. The strategic goal is to build a more resilient and adaptive execution process that can dynamically shift between liquidity sources based on order characteristics, market conditions, and regulatory obligations.

A successful SI integration strategy hinges on creating a unified view of fragmented liquidity to demonstrably improve execution outcomes.

A core component of the strategy involves choosing the correct integration model. Each approach presents a different balance of control, cost, and complexity. The decision rests on a firm’s existing technological infrastructure, internal expertise, and long-term strategic goals.

Comparison of SI Integration Models
Integration Model Description Advantages Disadvantages
Direct Connectivity Establishing individual point-to-point connections, typically via the FIX protocol, to each SI a firm wishes to trade with. Lowest latency; maximum control over connection and protocol specifics; no third-party dependency. High implementation and maintenance overhead; requires significant in-house technical expertise; scales poorly as the number of SIs increases.
EMS/OMS Hub Leveraging an existing Execution or Order Management System as a central hub. The EMS/OMS vendor manages the connections to the SIs. Faster time-to-market; lower maintenance burden; leverages existing user workflows and interfaces. Dependent on vendor’s roadmap and SI coverage; potential for higher latency; may involve additional vendor fees.
Third-Party Aggregator Utilizing a specialized technology provider that offers a unified API for accessing a wide network of SIs and other liquidity sources. Broadest initial access to liquidity; simplified connectivity through a single integration point; vendor handles normalization. Introduces another potential point of failure; adds a layer of cost; less control over the underlying network and protocol.
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What Are the Foundational Strategic Decisions?

Before a single line of code is written, the strategic framework must be defined. This involves a series of critical decisions that will shape the technological and operational outcome.

  • SI Selection and Prioritization Which SIs offer the most competitive pricing and deepest liquidity in the firm’s core instruments? The process begins with analyzing historical trade data and engaging with potential SI counterparties to understand their offerings.
  • Workflow Automation Logic How will the system decide when to include SIs in an RFQ? This logic must be encoded into the firm’s smart order router or RFQ engine, considering factors like order size, instrument liquidity classification (liquid, illiquid, LIS), and the client’s execution instructions.
  • Data Management and Governance A clear strategy is required for capturing, storing, and analyzing the data generated from SI interactions. This includes quote data, execution reports, and the mandatory post-trade transparency flags that SIs provide. This data is the bedrock of TCA and best execution analysis.
  • User Interface and Trader Workflow How will traders interact with this new source of liquidity? The integration must be seamless, presenting SI quotes within the existing RFQ ticket in the EMS/OMS, allowing for efficient comparison and execution without disrupting established workflows.


Execution

The execution phase translates strategic objectives into a functioning, resilient, and compliant technological reality. This is a multi-faceted engineering challenge that spans connectivity, protocol implementation, system integration, and rigorous testing. It requires a disciplined project management approach and deep expertise in financial technology protocols and market structure.

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The Operational Playbook

A structured, phased approach is essential for managing the complexity of the integration. This playbook outlines a clear path from initial concept to a fully operational system.

  1. Phase 1 Discovery and Scoping
    • Counterparty Due Diligence Identify and engage with the technical teams of the target SIs. Obtain their FIX specification documents, rules of engagement, and testing schedules.
    • Internal System Analysis Conduct a thorough audit of the existing OMS/EMS, RFQ engine, and database schemas to identify all points of impact.
    • Define Requirements Create a detailed business requirements document (BRD) specifying the exact functional behavior, from how an SI is added to an RFQ ticket to how post-trade reports are processed and stored.
  2. Phase 2 Architectural Design
    • Connectivity Blueprint Finalize the connectivity method (e.g. dedicated line, VPN) and design the network architecture, including firewall rules and security protocols.
    • Data Flow Mapping Create detailed diagrams illustrating the flow of messages (Quote Request, Quote Response, Execution Report) between the firm’s systems and the SI’s systems.
    • SOR/RFQ Engine Logic Design the specific algorithms and rules that will govern when and how SIs are included in the price discovery process. This logic must be flexible enough to handle different instrument types and market conditions.
  3. Phase 3 Development and Integration
    • FIX Engine Configuration Configure the firm’s FIX engine to establish sessions with the SIs. This includes setting up CompIDs, defining heartbeats, and handling sequence number resets.
    • Message Handling Develop the code to create, parse, and process the relevant FIX messages. This requires careful handling of repeating groups for legs in multi-leg orders and custom tags specific to an SI.
    • OMS/EMS Enhancement Modify the trading system’s front-end to display SI quotes and back-end to persist trade data correctly, including all MiFID II required flags.
  4. Phase 4 Testing and Certification
    • Connectivity and Session Layer Testing Verify that a stable FIX session can be established and maintained with each SI in their UAT environment.
    • Application Layer Testing Conduct a full suite of message tests ▴ send RFQs, receive quotes, handle quote cancellations, submit orders, and process execution reports. Test edge cases like rejected quotes and stale prices.
    • User Acceptance Testing (UAT) Have traders run through realistic trading scenarios in the test environment to ensure the workflow is intuitive and meets their requirements.
    • Performance and Failover Testing Load test the system to ensure it can handle the expected message volume without performance degradation. Test the failover mechanisms by simulating network outages or SI system failures.
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Quantitative Modeling and Data Analysis

Data is the lifeblood of this system. The architecture must be designed to not only facilitate trades but also to generate the rich datasets required for quantitative analysis, regulatory reporting, and continuous improvement of the execution logic. The following tables illustrate the types of data structures and analysis that are central to the system’s intelligence.

The value of an SI integration is realized through rigorous data analysis that proves and improves execution quality over time.
Table 1 Pre-Trade SI Eligibility and Routing Matrix
Instrument Class Trade Notional (EUR) Liquidity Profile SI Counterparty FIX Session Status Include in RFQ?
EU Corporate Bond 15,000,000 Large-in-Scale (LIS) SI-BANK-A Active Yes
EU Corporate Bond 15,000,000 Large-in-Scale (LIS) SI-BANK-B Active Yes
EU Equity Option 500,000 Liquid SI-BANK-C Inactive No
EU Equity Option 500,000 Liquid SI-BANK-A Active Yes
Sovereign Bond 50,000,000 Large-in-Scale (LIS) SI-BANK-D Active Yes

This pre-trade matrix is a simplified representation of the logic within the RFQ engine. Before any request is sent, the system checks the instrument type, the size of the order against MiFID II thresholds (like LIS), and the real-time status of the connection to each potential SI counterparty. This ensures that RFQs are only sent to counterparties that are active and relevant for that specific order, improving efficiency and reducing unnecessary network traffic.

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Predictive Scenario Analysis

To understand the system in action, consider a detailed case study. A portfolio manager at “Alpha Hound Asset Management,” a mid-sized institutional firm, needs to execute a complex order ▴ buying a 2,000-lot calendar spread on a major European stock index option. This involves simultaneously buying a near-term call option and selling a longer-term call option with the same strike price. The total notional value is significant, and the liquidity on the lit exchange for this specific spread is thin.

Placing the order directly on the market would likely move the price and result in considerable slippage. This is a classic use case for a sophisticated RFQ workflow.

The portfolio manager, Sarah, stages the multi-leg order in Alpha Hound’s EMS. The EMS, recently upgraded with an integrated SI-aware RFQ engine, immediately recognizes the order’s characteristics. Its internal logic identifies the instrument as a non-equity derivative for which three major investment banks ▴ let’s call them SI-DEUT, SI-SOCGEN, and SI-BARC ▴ are registered Systematic Internalisers in the relevant jurisdiction. The system also has two other non-SI dealers, “Global Liquidity” and “Axon Trading,” configured in its RFQ panel.

The RFQ engine automatically initiates the process. It constructs a FIX 4.4 Quote Request (Tag 35=R) message. The message is populated with a unique QuoteReqID (Tag 131). The NoRelatedSym (Tag 146) field is set to 2, indicating a multi-leg instrument.

The repeating group for the legs is meticulously filled out, specifying the LegSecurityID, LegSide (Buy for the near-term, Sell for the far-term), and LegOrderQty for each of the two options. The QuoteRequestType (Tag 303) is set to ‘Manual’, indicating a trader-initiated request.

The engine then opens five parallel communication streams. It sends the identical FIX message to the five configured liquidity providers over their secure VPN connections. On Sarah’s EMS dashboard, a new RFQ ticket appears.

It shows the five counterparties with a “Pending” status next to their names. The clock starts ticking.

Within 400 milliseconds, the first response arrives. It’s from SI-DEUT. The EMS receives a Quote Response (Tag 35=AG) message. The system parses the message, extracting the firm bid and offer prices for the spread and displaying them on Sarah’s screen.

The quote is marked with a flag indicating it is from an SI. Shortly after, responses from SI-SOCGEN and Global Liquidity arrive. Axon Trading sends a QuoteRequestReject (Tag 35=b) message, with QuoteRejectReason (Tag 300) indicating ‘No interest’. SI-BARC is the last to respond, nearly a full second after the request was sent.

Sarah’s screen now presents a clear, consolidated view of the market. The system’s integrated Transaction Cost Analysis (TCA) module overlays real-time calculations next to each quote, showing the spread-to-mid and the potential price improvement against the prevailing, albeit thin, on-screen market. The quotes are:

  • SI-DEUT ▴ 2.15 EUR / 2.18 EUR (for the full 2,000 lots)
  • SI-SOCGEN ▴ 2.14 EUR / 2.17 EUR (for up to 1,500 lots)
  • Global Liquidity ▴ 2.13 EUR / 2.20 EUR (for up to 1,000 lots)
  • SI-BARC ▴ 2.16 EUR / 2.19 EUR (for the full 2,000 lots)

The best offer is from SI-SOCGEN at 2.17 EUR, but only for a partial fill. The next best is from SI-DEUT at 2.18 EUR. Sarah’s objective is to complete the full size with minimal impact and the best possible average price. She instructs the EMS to execute.

The system’s execution logic is configured for “sweep-to-fill.” It instantly sends two New Order – Single (Tag 35=D) messages. The first is to SI-SOCGEN to lift their offer for 1,500 lots at 2.17 EUR. The second is sent microseconds later to SI-DEUT to lift their offer for the remaining 500 lots at 2.18 EUR.

Within moments, Execution Report (Tag 35=8) messages flow back from both SIs. Both are ExecType (Tag 150) = ‘Fill’. The order is complete. The average execution price is 2.1725 EUR, a significant improvement over the 2.20 EUR price from the non-SI dealer and what she would have likely achieved on the lit market.

Critically, the entire price discovery process was contained. The market only saw the post-trade reports.

The final step is automated. The SIs, as per their MiFID II obligation, handle the trade reporting to an Approved Publication Arrangement (APA). Their execution report messages sent back to Alpha Hound contain a TradeReportID and a flag indicating the reporting responsibility has been met.

Sarah’s system ingests this information, automatically enriching the trade blotter with the necessary data for her firm’s best execution committee and regulatory audit trail. The entire operation, from staging the order to receiving the final fills and compliance data, took less than three seconds.

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System Integration and Technological Architecture

The technological core of this integration is the Financial Information eXchange (FIX) protocol. While some SIs may offer REST APIs for ancillary functions like retrieving their SI status for certain instruments, the high-speed, stateful communication required for quoting and trading is the domain of FIX.

The architecture must include a robust FIX engine capable of managing multiple concurrent sessions. This engine serves as the gateway between the firm’s internal systems (OMS/EMS) and the SIs. A critical component is the normalization layer. Even though FIX is a standard, different SIs may have minor variations in their implementation or use proprietary tags for specific features.

The normalization engine is a piece of middleware that translates these variations into a single, consistent internal data format that the OMS/EMS can understand. This prevents the need to write custom logic for every single SI.

Key technological components include:

  • High-Availability FIX Engine ▴ Must support at least FIX 4.2 and 4.4, with full session management, message recovery, and failover capabilities.
  • Low-Latency Network ▴ While not requiring the microsecond sensitivity of HFT, the network (VPN or dedicated line) must provide reliable, low-latency connectivity to ensure quotes are received and orders are sent in a timely manner.
  • Data Normalization Layer ▴ A middleware component to translate different SI FIX dialects into a unified internal message format.
  • OMS/EMS Integration Points ▴ The OMS/EMS must be extensible. This requires APIs or plug-in architectures that allow the RFQ engine to be integrated, the trader UI to be modified, and the trade database to be extended with new fields for SI-specific data.
  • Secure Data Warehouse ▴ A repository for storing all RFQ and trade data for TCA, regulatory reporting, and surveillance. This database must be secure, auditable, and capable of handling large volumes of time-series data.

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References

  • ICMA. “MiFID II/R implementation ▴ road tests and safety nets.” International Capital Market Association.
  • ICMA. “MiFID II implementation ▴ the Systematic Internaliser regime.” International Capital Market Association, 6 Apr. 2017.
  • European Securities and Markets Authority. “MiFIR report on systematic internalisers in non-equity instruments.” ESMA, 16 July 2020, ESMA70-156-2756.
  • B2BITS, EPAM Systems. “RFQ Flow Migration to FIXEdge Java.” B2BITS.
  • “Best Execution Under MiFID II.” Corvil, 2017.
  • “Systematic internaliser (SI) in MiFID II – a counterparty, not a trading venue.” Compliance & Risks, 25 Feb. 2014.
  • Deutsche Börse AG. “Systematic Internalisers.” Deutsche Börse Group.
  • BaFin. “Systematic internalisers ▴ Main points of the new supervisory regime under MiFID II.” Bundesanstalt für Finanzdienstleistungsaufsicht, 2 May 2017.
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Reflection

The architectural integration of Systematic Internalisers into an RFQ workflow is a profound upgrade to a firm’s execution capabilities. The process moves a trading desk from being a price taker, subject to the liquidity visible on public screens, to becoming a strategic liquidity solicitor, capable of creating its own competitive auctions on demand. The framework detailed here provides the necessary components, protocols, and strategic considerations for this undertaking.

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How Does This Capability Reshape Your Firm’s Place in the Market?

Consider your current execution protocol. How much potential price improvement is left unrealized by not systematically accessing these proprietary liquidity pools? How does information leakage from working large orders on lit venues impact your alpha? The technology described is the apparatus for answering these questions with data.

It transforms the abstract mandate of best execution into a quantifiable, improvable engineering discipline. The ultimate outcome is a more robust, adaptive, and intelligent trading infrastructure, which is the foundational element of a durable competitive edge in modern financial markets.

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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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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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Bilateral Price Discovery Protocol

Information leakage in bilateral price discovery is the systemic risk of revealing trading intent, which counterparties can exploit.
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Rfq Workflow

Meaning ▴ The RFQ Workflow defines a structured, programmatic process for a principal to solicit actionable price quotations from a pre-defined set of liquidity providers for a specific financial instrument and notional quantity.
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Execution Management System

Meaning ▴ An Execution Management System (EMS) is a specialized software application engineered to facilitate and optimize the electronic execution of financial trades across diverse venues and asset classes.
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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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Price Discovery

Meaning ▴ Price discovery is the continuous, dynamic process by which the market determines the fair value of an asset through the collective interaction of supply and demand.
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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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Large-In-Scale

Meaning ▴ Large-in-Scale designates an order quantity significantly exceeding typical displayed liquidity on lit exchanges, necessitating specialized execution protocols to mitigate market impact and price dislocation.
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Rfq Engine

Meaning ▴ An RFQ Engine is a specialized computational system designed to automate the process of requesting and receiving price quotes for financial instruments, particularly illiquid or bespoke digital asset derivatives, from a selected pool of liquidity providers.
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Fix Engine

Meaning ▴ A FIX Engine represents a software application designed to facilitate electronic communication of trade-related messages between financial institutions using the Financial Information eXchange protocol.
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Systematic Internalisers

Meaning ▴ A market participant, typically a broker-dealer, systematically executing client orders against its own inventory or other client orders off-exchange, acting as principal.
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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.