Chances of Sebi going China way

Thanks for the detailed point-by-point critique. :saluting_face:
Let me start by addressing the weakest parts of my previous post above -

Firstly, whether algo/HFT trading is even dominant enough to warrant our attention/question it

Based on publicly available data,
HFT trading was atleast 23% of all trades on NSE (25% by volume) in 2015 itself.

  • Message Traffic:
    • ~83% of all messages.
  • Order Management:
    • ~87% of all order revisions were made by HFTs.
    • ~70% of all order cancellations were made by HFTs.
    • ~50% of limit order submissions came from HFTs.

Over the subsequent years,
i could only find numbers that clubbed algo and HFT into a single bucket
which has apparently hit ~60% of the market trades.

Sources: [1a][1b] [2] [3]

Secondly, a clear distinction between the various entities involved

Very well spotted.
Not a very clear distinction. Hence the air-quotes around these 3 terms in my previous post.

Upon further thought,
one way to better express what i had in mind is as follows -

  • “Producer”, “Consumer” → “value-adding” intermediaries

    • Investors who bear fundamental risk.
    • Traders who provide liquidity and aid price discovery.
  • “middlemen” → “profiteering” intermediaries

    • Predatory High Frequency Trading, latency arbitrage, quote stuffing, …

At a given price, a buyer AND a seller both often exist for a trade to successfully conclude
i.e. a willing trade occurs with both the participants in the trade valuing themselves to be better-off as perfect information is unlikely in real markets.

Searching online, found a few metrics to objectively identify such profiteering middlemen.

Logical objective metrics that can be used to distinguish between value-adding intermediaries (who provide liquidity and price discovery) and profiteering middle-men (associated with rent extraction, latency arbitrage, quote stuffing, …).

1. Spread Decomposition (Realized vs. Effective Spread)

The Logic:
A benevolent market maker earns the spread but often loses on the price move (adverse selection). A predatory trader profits from the price move itself or by “picking off” stale quotes. This metric compares the cost to the aggressive trader against the profit of the passive provider.

  • Metric: Difference between Effective Spread (immediate cost) and Realized Spread (profit after time $t$).
  • Distinction:
    • Value Adder: High Effective Spread, Low/Negative Price Impact (Realized Spread < Effective Spread). They bear the risk of holding the asset.
    • Profiteer: Low Realized Spread for the counter-party or High Price Impact. If the price moves against the victim immediately after the trade, the middle-man likely engaged in latency arbitrage.

Reference: Does Algorithmic Trading Improve Liquidity? (Hendershott, Jones, Menkveld, 2011) - Journal of Finance


2. Order-to-Trade Ratio (OTR) & Cancellation Rates

The Logic:
Value-adding market makers must post quotes to provide liquidity. However, statistically anomalous ratios (e.g., 1000:1) suggest strategies based on the illusion of liquidity rather than provision.

  • Metric: Ratio of (New Orders + Modifications + Cancellations) to Executed Trades.
  • Distinction:
    • Value Adder: Reasonable ratios consistent with market volatility updates.
    • Profiteer: Extremely high OTRs indicate Quote Stuffing or Layering—creating “ghost liquidity” that vanishes when accessed, often used to slow down competitors or trigger algorithms.

References: ESMA Final Report on Draft Regulatory Technical Standards (MiFID II)* - Section 3.4 on OTR and
MiFID II RTS 9 Article 2.


3. Inventory Mean Reversion (Holding Period)

The Logic:
Profiteering middle-men (pure arbitrageurs) avoid inventory risk entirely, seeking to end the day (or minute) flat. Investors and genuine Market Makers hold risk for longer periods.

  • Metric: Inventory Half-Life. How long does it take for a participant’s inventory to revert to zero?
  • Distinction:
    • Value Adder: Willing to hold inventory for minutes/hours to facilitate large block trades.
    • Profiteer: Inventory reverts to zero in seconds/milliseconds. They effectively transfer risk rather than absorb it.

Reference: The Flash Crash: The Impact of High Frequency Trading on an Electronic Market* (Kirilenko, Kyle, Samadi, Tuzun, 2017) - Journal of Finance


4. “Strategic Runs” Methodology (Pattern Recognition)

The Logic:
Algorithmic intermediaries often trade in bursts or sequences of trades in the same direction, followed by a reversal. This methodology identifies HFT activity without needing proprietary User IDs.

  • Metric: Identification of “runs”—sequences where a participant aggressively buys (or sells) repeatedly within a short window.
  • Distinction:
    • Momentum Ignition: A predatory strategy where the middle-man trades aggressively to trigger stop-losses.
    • Differentiation: Used to separate HFT activity (characterized by speed and inventory management) from low-frequency institutional re-balancing.

Reference: Identifying High Frequency Trading Activity Without Proprietary Data* (Chakrabarty, Comerton-Forde, Pascual).


5. Liquidity Withdrawal During Stress (The “Fair Weather” Test)

The Logic:
A true Market Maker adds value by stabilizing the market during stress. A profiteer provides liquidity only when the probability of loss is near zero and vanishes when volatility spikes.

  • Metric: Correlation between Market Volatility (VIX) and Limit Order Book Depth provided by the participant.
  • Distinction:
    • Value Adder: Low or positive correlation (remains present during stress).
    • Profiteer: Strong negative correlation (vanishes exactly when liquidity is needed).

Reference: Market Conditions, Fragility, and the Quality of Market Making* (Anand and Venkataraman, 2016) - Journal of Financial Economics.


6. Latency Arbitrage Detection

The Logic:
In fragmented markets, prices may misalign for microseconds. Participants identifying and executing against these stale prices add no price discovery value; they tax the system.

  • Metric: Identification of trades occurring simultaneously (within light-travel time) across venues where the price difference is mechanical/arbitrage-based.
  • Distinction:
    • Profiteer: Consistently engages in “sniping” stale quotes.
    • Value: Zero. This is widely considered a tax on liquidity.

Reference: The High-Frequency Trading Arms Race: Frequent Batch Auctions as a Market Design Response* (Budish, Cramton, Shim, 2015) - Quarterly Journal of Economics.


7. Toxic Flow Analysis (VPIN)

The Logic:
Measures the imbalance of buy/sell volume to detect “toxic” flow—informed traders taking advantage of market makers.

  • Metric: VPIN (Volume-Synchronized Probability of Informed Trading).
  • Distinction:
    • Profiteer: A participant consistently on the aggressive side of high-VPIN periods (utilizing information asymmetry or speed to pick off passive orders).

Reference: The Volume Clock: Insights into the High Frequency Paradigm (Easley, López de Prado, O’Hara, 2012)


8. Risk-Adjusted rate of return & Consistency Analysis

The Logic:
Use the Sharpe Ratio (Return / Volatility) and Correlation with Slippage.
Efficient markets dictate that high returns require high risk. HFTs with “infinite” Sharpe ratios are likely extracting risk-free rents (arbitrage/front-running).

  • Metric:
    1. Sharpe Ratio: (R_p - R_f) / sigma_p calculated on daily/intraday P&L.
    2. Slippage Correlation: Correlation between HFT Profit and immediate post-trade price movement against the counter-party.
  • Distinction:
    • Value Adder: Moderate Sharpe Ratio (takes inventory losses). No correlation with immediate adverse price moves (passive liquidity provision).
    • Profiteer: Extremely High Sharpe Ratio (20+). High correlation with immediate adverse price moves (sniping/latency arb).

Reference: High-Frequency Trading and the New Market Makers (Albert J Menkveld)

IIUC, access to the historical order-book / bid-ask spreads (or even a dump of live market data eg. broker API web-socket stream) should be sufficient to apply several of these methodologies.

It remains to be seen whether such “profiteering” without value-adding behaviour extends beyond HFT and Algo trading as well.


Also, this updated classification, appears to be consistent with the observation that margins have declined for some value-adding traders, as it doesn’t rule out the presence of other non-value-adding (profiteering) middlemen participants.

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