A lot has been stated concerning the non-bank high-frequency buying and selling (HFT) corporations that supposedly lurk on the nameless spot overseas trade major venues of EBS Market and Matching, ready to choose off the unsuspecting banks managing shopper threat.
Some research argue these corporations can pull liquidity or widen spreads sharply in a disaster, a priority the Swiss Nationwide Financial institution raised this 12 months.
However others argue non-banks contribute considerably to liquidity by passively buying and selling in opposition to the pricing errors created by sellers’ aggressive flows, and provide the dominant share of value discovery via their high-frequency quote updates.
In an try to tell the talk, Paul Houston of CME Group and Simon Jones of LSEG gave a presentation to the European Central Financial institution’s overseas trade contact group (FXCG) assembly in June, revealing contemporary particulars on the participant combine on their venues, and on how non-banks and financial institution market-makers really commerce.
The presentation first checked out who makes liquidity. On LSEG Matching, roughly 67% of liquidity suppliers (LPs) have been banks and 33% non-banks as of June 2026, up sharply from January 2022 when non-banks accounted for simply 20%.
On EBS, the cut up is about 60% financial institution and 40% non-bank – a mixture formed by the entry rule for its EBS Stay Extremely information feed, which requires individuals to make markets for at the very least 40% of their weekly volumes and contribute a minimal of $200 million in day by day movement.
That maker/taker stability strikes sharply when volatility spikes. On LSEG Matching, banks run a median ratio of 55:45; on March 3, within the opening days of the Iran battle, it jumped to 70:30. Nonetheless non-banks barely flinched, with their ratio solely shifting from 33:67 to 30:70.
The variety of non-bank market-makers on the first venues has additionally thinned. EBS hosted roughly 90 in 2016, and that determine has since greater than halved.
The attrition is concentrated among the many smallest gamers. The inhabitants of non-banks buying and selling as much as $250 million has fallen by round 70% since 2016, whereas the share transacting greater than $2 billion has held regular – proof that the enterprise is consolidating round a handful of enormous, well-capitalised corporations.
The FXCG minutes echoed this, noting that non-banks have “turn into necessary gamers in FX spot markets, significantly in liquid G10 pairs, however their exercise is more and more concentrated amongst a small variety of giant corporations”.
Citadel Securities, Jane Road, Optiver and XTX Markets are among the many established market-makers, alongside HFT names corresponding to Soar Buying and selling, Virtu and Tower Analysis. Different corporations, nevertheless, corresponding to Circulation Merchants, are understood to have pulled again a bit from FX market-making through the years.
The presentation additionally highlighted variations in quoting behaviour between the banks and non-banks. Median order life for banks was 290 seconds on EBS and 181 seconds on Matching, whereas for non-banks it was 2.95 seconds and 1.64 seconds.
A case examine of the Financial institution of Japan’s intervention on April 30 confirmed that as US greenback/yen slid from 159.35 to 155.50, 385 pips traded on EBS and 98.4% of all accessible value factors modified palms – a burst of exercise that noticed decade-high volumes of $77 billion of USD/JPY on the day.
Non-banks tracked spot tick by tick because the pair fell over roughly two hours. They repeatedly refreshed their quotes across the contact and cancelled inside seconds, so their liquidity clustered on the prime of e book across the value.
Banks behaved in another way. They supplied sticky, longer-lasting liquidity unfold throughout the order e book that didn’t chase the transfer – and, tellingly, they have been resting bids all the best way all the way down to 155.50 nicely earlier than spot bought there.
The minutes drew the plain conclusion: a complementary two-tier construction has taken maintain in spot, wherein non-banks dominate speedy value formation whereas banks present depth, take in threat and intermediate shopper flows.
Nonetheless, the minutes additionally famous that non-bank liquidity is “conditional”, usually confined to small commerce sizes, and the FXCG flagged considerations about rising focus, restricted transparency for end-users, and the way resilient the market would show if one of many handful of dominant corporations pulled again in a interval of extreme stress.
What the presentation didn’t present is the opposite facet of that construction – the regular retreat of banks from the first venues themselves.
For years, sellers have invested in inner matching engines that skew pricing to offset residual threat, lowering their reliance on the exterior market. The rise of pod outlets and the systematic buying and selling group has accelerated the shift, supplying a steady stream of axed movement that lets sellers rotate stock with out ever touching a public venue.
As well as, market construction specialists have argued that the pool of genuinely tradable liquidity on public FX venues has thinned, as highlighted by the CME outage in November final 12 months.
However, the presentation could also be helpful for future analysis into the true mixture of non-banks and financial institution liquidity within the FX market.
Enhancing by Lukas Becker

