Perspectives on Exchange-Traded Funds

Are exchange-traded funds good or bad for the market?

That was the title of a lively and interesting session at Markets Media's third annual Global Markets Summit last Thursday. The session was organized as an old-fashioned debate between two teams. On one side were David Weild and Harold Bradley (joined later by Robert Litan on video), who argued that heavily traded funds composed of relatively illiquid small-cap stocks were responsible, in part, for the sharp decline in initial public offerings over the past decade, with devastating consequences for capital formation and job creation.

Responding to these claims were Bruce Lavine, Adam Patti and Robert Holderith, all representing major sponsors of funds (WisdomTree, IndexIQ and EGShares respectively). The sponsors argued that they are marketing a product that is vastly superior to the traditional open-end fund, provides investors with significant liquidity, transparency and tax advantages, and is rapidly gaining market share precisely because of these benefits. From their perspective, it makes as little sense to blame exchange-traded funds for declining initial public offerings and the sluggish rate of job creation as it does to blame them for hurricanes or influenza epidemics.

So who is right?

Bradley and Litan have previously argued their position in a lengthy and data-filled report, and Wield has testified on the issue before the joint CFTC-SEC committee on emerging regulatory issues. Their argument, in a nutshell, is this: The prices of thinly traded stocks can become much more volatile as a result of inclusion in a heavily traded fund as a consequence of the creation and redemption mechanism. For instance, a rise in the price of shares in the fund relative to net asset value induces authorized participants to create new shares while simultaneously buying all underlying securities regardless of the relation between their current prices and any assessment of fundamental value. Similarly a fall in the fund price relative to net asset value can trigger simultaneous sales of a broad range of securities, resulting in significant price declines for relatively illiquid stocks. This process results not only in greater volatility but also in a sharply increased correlation of returns on individual stocks. The scope for risk-reduction through diversification is accordingly reduced, which in turn influences the asset allocation decisions of long term investors. The result is a reduction in the flow of capital to the smaller, more innovative segments of the market, with predictably dire consequences for job creation.

The sponsors do not deny the possibility of these effects, but argue that any mispricing in the markets for individual stocks represents a profit opportunity for alert fundamental traders, and that this should prevent prolonged or major departures of prices from fundamentals. But this is too sanguine an assessment. Fundamental research is costly and its profitability depends not only on the scale of mispricing that is uncovered but also on the size of the positions that can be taken in order to profit from it. Furthermore, since a significant proportion of trades are driven by the arbitrage activities of authorized participants, mispricing need not be quickly or reliably corrected. Both illiquidity and high volatility serve as a deterrent to fundamental research in such markets.

The problem, in other words, is real. But what I find puzzling about Bradley's position on this issue is that he seems unable (or unwilling) to recognize that precisely the same effects can be generated by high-frequency trading. As was apparent in an earlier session at the conference, he remains among the most vocal and fervent defenders of the new market makers. His justification for this is that spreads have declined dramatically, lowering the costs of trading for all market participants, including long term investors.

There is no doubt the costs of trading are a fraction of what they used to be, but a single-minded focus on spreads misses the big picture. It is worth bringing to mind John Bogle's wise words:

It is the iron law of the markets, the undefiable rules of arithmetic: Gross return in the market, less the costs of financial intermediation, equals the net return actually delivered to market participants.  

If spreads and costs per trade decline, but holding periods shrink to such a degree that overall trading expenditures rise (due to significantly increased volume), the net return to long term investors as a group must fall. Furthermore, if increases in volatility and correlation induce shifts in asset allocation that have the effect of reducing financing for small companies with high growth potential, then even gross returns could decline.

I have been arguing for a while now that the stability of an asset market depends on the composition of trading strategies and, in particular, that one needs a large enough share of information trading to ensure that prices track fundamentals reasonably well. But changes in technology and regulation have allowed technical strategies to proliferate, and high frequency trading is a significant part of this phenomenon. The predictable result is a secular increase in asset price volatity and an increased frequency of bubbles and crashes.

The flash crash of May 6 was just a symptom of this. Viewed in isolation, it was a minor event: prices fell (or rose, in some cases) to patently absurd levels, then snapped back within a matter of minutes. But the crash was the canary in the proverbial coal mine -- it was important precisely because it made visible what is ordinarily concealed from view. Departures of prices from fundamentals are routine events that, especially on the upside, are not quickly corrected. Some of the proposed responses to the crash that were favored at the conference -- such as trading halts followed by call auctions -- are cosmetic changes. They will have the effect of silencing the canary while doing nothing to lower toxicity in the mine.

It is the unremarkable, invisible, gradually accumulating departures of prices from fundamentals that are the real problem. These show up in the magnitude and clustering of asset price volatility and, through their effects on the composition of portfolios, leave their mark on the path of capital allocation, employment, and economic growth.

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I am grateful to Terry Flanagan of Markets Media Magazine for the invitation to attend the summit.

I would also like to mention that the Kauffman report contains a number of assertions with which I disagree. For instance, Bradley and Litan endorse the claims of Bogan, Connor and Bogan that an exchange-traded fund with significant short interest could collapse with some investors unable to redeem their shares. This has been refuted very effectively by Steve Waldman in his comments on the Bogan post, and by Kid Dynamite. It is unfortunate that most responses to the report have focused on this dubious claim, rather than the more legitimate arguments that are advanced there.

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Update (12/11). David Weild writes in to say:

I think we are seeing capital leave the microcap markets for a variety of reasons including:

• Loss of liquidity providers
• Emergence of ETFs (they don't buy IPOs and most don't buy follow-on offerings)
• Indexing displacing fundamental investing (again, when this occurs, the funds stop investing in IPOs)
• Loss of the retail broker as a stock seller.

If you don't have access to sufficient capital then capital formation, innovation and economic growth will suffer. That is clearly where we are.

I have also heard from someone who was once active in convincing the SEC to expand approval of ETF applications (and prefers to remain anonymous). He asserts that "the effects now being debated were certainly not an anticipated consequence. I can't remember a single conversation externally or internally at the SEC about whether the creation and redemption mechanism would increase correlations."

In hindsight it seems obvious that returns would become more highly correlated, but the fact that it was completely unanticipated at the time illustrates the enormous challenge of regulatory adaptation to financial innovation.