대체거래시스템(ATS) 도입에 따른 과제

This paper looks at a broad range of potentially significant developments that could result from the introduction of alternative trading systems (ATS) in the Korean stock market, mainly in terms of market structure and the role of policymakers. After analyzing the situation, we argue that the following concerns or tasks should be taken in order to nurture desirable ATS conditions in Korea before the implementation. First, the legal definition of ATS in Korea is slightly different from the globally accepted one. This could be confusing in the discussions about market macrostructure, particularly the establishment of the organized OTC and the business range of securities firms for OTC equity trading. Second, the legal definition of “Best Execution” in Korea seems very similar to the one in MiFID, but not to the one in Reg NMS, so it is unclear whether the Korean version of Best Execution will be able to secure only its positive effects for such a small market as Korea. Third, the introduction of ATS will create multiple trading centers in Korea, so that it is essential to establish a virtual intermarket consolidation system and its operator before the implementation of Best Execution. This will facilitate market efficiency resulting from competition among multiple trading centers. In addition, the fee structures of individual trading centers should be closely monitored to prevent the erosion of fairness in competition. Fourth, the possible conflicts of interests arising from the KRX’s execution of the clearing and the market supervision of rival ATS should be examined and handled properly. ATS should also be implemented and developed in Korea together with policy goals on domestic market macrostructure and the pursuit of international market status. Fifth, the market microstructure should be appropriately maintained. A sophisticated mechanism for market stability such as the European volatility interruption system should be established for individual stocks. This mechanism should be harmonized among individual trading centers at the whole market level. Then, various new order types should be introduced, but the rules against any abuse through these new order types should be proactively enacted. The pre- and post-transparency on dark pools should be strengthened as well. Sixth, the “full scale,” not limited versions, of ATS should be introduced to Korea. If not, Korea will not only fall behind other neighboring countries in the regional stock market competition, but also the development of the domestic IT industry will be delayed. Seventh, what matters most is the policymakers’ role. Policymakers should have a strong understanding of the latest trading-related IT and continuously upgrade their monitoring systems. It is necessary that policymakers have a clear vision and philosophy on their policy toward the Korean stock markets, which would facilitate the consistent promotion of the above six tasks related to the implementation of ATS in Korea. Without a blueprint about the full scope of ATS introduction in Korea, any discussion regarding the Korean stock market macrostructure will be relevant only in the short term.