Cathie Armour, ASIC
ASIC has released a report on the findings of its review of the ASX outage that affected the operation of the Australian equity market on 19 September 2016. It provides a whole-of-market perspective, with observations on how ASX and other important stakeholders responded on the day.
The outage highlighted the fact that despite considerable market developments in Australia in recent years, ASX's trading system remains pivotal to the functioning of equities markets.
A general lack of confidence on the day resulted in trading drying up, with very little liquidity shifting to Chi-X's competing market. A key benefit of market competition is the availability of an alternative market when ASX is unavailable.
ASIC's review found that, in responding to the outage, ASX broadly adhered to its existing procedures for incident management. There are, however, some areas where ASX could enhance its arrangements to support technology resilience and the robustness of the wider Australian equity market. In some important areas, market participants can also take action to support these improvements.
The report makes a number of recommendations - for both ASX and market participants - designed to improve the resilience and robustness of the wider market and to promote confidence that any future incidents will be managed effectively. They include recommendations for ASX to:
- map the dependencies that stakeholders have on ASX (e.g. listing function) and mitigate the effect of system failures on these stakeholders
- review when it is appropriate for all or a subset of securities to be available for trading and consider whether the open rotation process is still necessary
- strengthen business continuity and IT disaster recovery, including system testing and recovery procedures, and a repository of documentation
- implement comprehensive and robust technology status monitoring, including automated data-integrity checking processes and system-monitoring alerts
- enhance its key enterprise architecture documentation to more fully describe 'current' and 'target' states for business processes, systems, data and information flows
- review its communication strategy, including mechanisms to communicate the status of infrastructure that other market operators are dependent on and for a 'single source of truth' for the wider market, and
- review ASX's operational risk arrangements, including the 'four eyes' principle, pre-open period and trade cancellation policy.
ASIC also identified areas where market users could contribute to a more resilient and robust market. Market participants should:
- review their arrangements for dealing with market outages, including the operation of best execution policies, algorithms and smart order routers, and arrangements for undertaking and reporting crossings, and
- review their own system-preparedness for managing market outages, including participation in market operators' business continuity testing.
ASX has already identified a number of actions to enhance its incident management capabilities and technology resilience. ASIC understands many market participants are also reviewing their preparedness for managing market outages.
ASIC Commissioner Cathie Armour said: 'The pace, complexity and dynamic nature of the Australian market and the important role of market infrastructure in its integrity and reputation continues to grow and evolve. ASX Group is embracing these developments with an expansive technology investment agenda.'
For these reasons, ASIC will undertake a wider review in 2017 of the operational and technological risk management arrangements across ASX Group.
ASIC's report also foreshadows an intention to consult in 2017 on making market integrity rules on the technological and operational performance of market operators.