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CCP Risk Assessments Did you know? CCPs will be taking on the burden of clearing much of the US $633.58 trillion OTC derivatives market, a market widely blamed for exacerbating the post 2007 global financial crises. This risk will be concentrated into CCPs; each CCP has its own way of operating, its own risk waterfall, within its distinct regulatory and legal framework, placing greater systemic risk upon each one. Overview End users are being forced into mandatory clearing at CCPs. How do you assess if these infrastructure institutions are fit for purpose? In response to G20 and supplementary initiatives regarding mandatory clearing, Thomas Murray Data Services established an industry-driven central counterparty (CCP) risk assessment programme. The service supports global regulatory imperatives to assess and monitor CCPs as risk concentrating vehicles. Thomas Murray Data Services has been performing risk assessments in the post-trade space for over 15 years and now we are working with major CCPs to compile comprehensive risk assessments that will enable our clients to understand every risk before selecting a clearing house. How is your margin calculated? Where does it go? What is your full, potential liability? How can a CCP mitigate your risk? Central clearing of OTC derivatives is well underway in the US with Phases I and II of the CFTC’s implementation having come into force. The EU is behind in terms of implementation, but mandatory clearing is expected to enter into force in late 2014. Issue There is huge potential for systemic risk in CCPs, and the consequences of a CCP failure could be very serious for you as a participant and the market at large. What happens to your collateral contribution in the event of a default? What happens to your open positions? If a major participant at the CCP goes into default, how quickly does your collateral come under threat? All of these questions, and more, are hugely important in making a decision as to which CCP(s) best fit your needs. Clearing houses operate within a competitive environment, a risk in itself, so you have choice and it is imperative that you make the right choice. You want robustness and a risk waterfall, plus margining requirements that you are comfortable with. There is a regulatory obligation upon clearing brokers to conduct operational reviews of the CCPs that they work with. This needs to be conducted annually and can be an onerous and expensive task. There is also a commercial imperative to benchmark each CCP, including its membership – the CCP is mutualising risk, but who else is in the group? Thomas Murray Data Services 1st Floor, 1 Farrier’s Yard, 77 Fulham Palace Road, Hammersmith, London W6 8AH Tel: +44 (0) 20 8600 2300 Email: [email protected] http://ds.thomasmurray.com Provider of Global Capital Market & Cash Data
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Page 1: CCP Risk Assessments - Thomas Murray Data Servicesds.thomasmurray.com/.../files/documents/TMDS_CCP_Risk_Assessm… · CCP Risk Assessments Did you know? CCPs will be taking on the

CCP Risk Assessments

Did you know?

CCPs will be taking on the burden of clearing much of the US $633.58 trillion OTC derivatives market, a market widely blamed for exacerbating the post 2007 global financial crises. This risk will be concentrated into CCPs; each CCP has its own way of operating, its own risk waterfall, within its distinct regulatory and legal framework, placing greater systemic risk upon each one.

OverviewEnd users are being forced into mandatory clearing at CCPs.

How do you assess if these infrastructure institutions are fit

for purpose? In response to G20 and supplementary initiatives

regarding mandatory clearing, Thomas Murray Data Services

established an industry-driven central counterparty (CCP) risk

assessment programme. The service supports global regulatory

imperatives to assess and monitor CCPs as risk concentrating

vehicles.

Thomas Murray Data Services has been performing risk

assessments in the post-trade space for over 15 years and now

we are working with major CCPs to compile comprehensive

risk assessments that will enable our clients to understand

every risk before selecting a clearing house. How is your margin

calculated? Where does it go? What is your full, potential

liability? How can a CCP mitigate your risk?

Central clearing of OTC derivatives is well underway in the US

with Phases I and II of the CFTC’s implementation having come

into force. The EU is behind in terms of implementation, but

mandatory clearing is expected to enter into force in late 2014.

IssueThere is huge potential for systemic risk in CCPs, and the

consequences of a CCP failure could be very serious for you as

a participant and the market at large. What happens to your

collateral contribution in the event of a default? What happens

to your open positions? If a major participant at the CCP goes

into default, how quickly does your collateral come under threat?

All of these questions, and more, are hugely important in

making a decision as to which CCP(s) best fit your needs.

Clearing houses operate within a competitive environment, a

risk in itself, so you have choice and it is imperative that you

make the right choice. You want robustness and a risk waterfall,

plus margining requirements that you are comfortable with.

There is a regulatory obligation upon clearing brokers to

conduct operational reviews of the CCPs that they work with.

This needs to be conducted annually and can be an onerous

and expensive task. There is also a commercial imperative to

benchmark each CCP, including its membership – the CCP is

mutualising risk, but who else is in the group?

Thomas Murray Data Services

1st Floor, 1 Farrier’s Yard, 77 Fulham Palace Road, Hammersmith, London W6 8AH

Tel: +44 (0) 20 8600 2300 Email: [email protected] http://ds.thomasmurray.com

Provider of GlobalCapital Market & Cash Data

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SolutionThe Thomas Murray Data Services CCP Risk Assessment looks to

determine the extent to which the CCP manages your risk burden.

Each assessment brings transparency to the industry for the benefit

of users, and offers cost savings to regulated firms that are required

to perform operational reviews and risk assessments on CCPs.

CCPs become the buyer to every seller and the seller to every

buyer. This requires the CCP to step into all eligible contracts,

not just selected contracts. This process makes CCPs risk-

concentration vehicles so that an assessment of their risk

management techniques is of paramount importance. In such

a situation, transparency is critical, as is the ability to compare

one CCP against another where there is user choice. CCPs

are often multi-jurisdictional. Their use for some products is

mandatory, while for others it is optional. Ownership of CCPs

varies, and this can lead to conflicting and diverse stakeholder

interests. An independent assessment of CCP risk is therefore

critical to the users of these entities.

CCP Risk Assessments Deliver:

Risk Assessment Reports

An in-depth structured risk assessment report, along with

access to the underlying supporting database.

Surveillance

On-going newsflashes (emailed) advising of changes that

impact the assessment reports, with the assessments being

continuously updated in near real-time.

Global Coverage

26 reports are immediately available covering CCPs across 18

major markets.

Transparency Index

Index of the level of disclosure by each CCP and their

engagement with external reviews.

Buy-Side and Regulatory Interest

Thomas Murray Data Services has generated a great deal of

interest from both the buy side and the international policy

community. Our conversations with regulators ensure that our

work maintains currency with the evolving regulatory thinking.

Groups include: Bank of England, European Central Bank,

BIS, Basel Committee of Banking Supervisors, CPSS, Financial

Stability Board, BaFin, IOSCO, FSA, PRC (Federal Reserve) as

well as being regular presenters at CCP12 meetings worldwide.

BenefitsSome touch points that have triggered interest in subscribing to

the service include:

• A level review of the field, with truly independent external

assessment, using a single model across all CCPs.

• A better, deeper understanding of the risk models used,

the availability of margin offsets and a common industry

standard for classifying the risks globally.

• Transparency on risk that will allow users to choose

counterparties on a basis other than price alone.

• Up-to-date analysis of interoperability and any risk issues

resulting.

• The collateral crunch has highlighted how CCPs optimise

collateral and how its treatment is increasingly important.

An ability to compare CCPs is extremely useful.

• The enormous funds being funnelled into CCPs will put

their treasury operations under the spotlight. An objective

assessment of the credit risk is required.

• The liquidity management tools that CCPs will rely on in

a crisis - credit lines, repos, central bank support etc. - are

critical to understand.

• Full-time equivalency savings – reducing the cost of

regulation by wholesaling the solution rather than

duplicating it within each regulated group.

• Expanded coverage at a low cost. Client requests for CCP services in markets not currently covered would require

expensive operational reviews.

Thomas Murray Data Services

1st Floor, 1 Farrier’s Yard, 77 Fulham Palace Road, Hammersmith, London W6 8AH

Tel: +44 (0) 20 8600 2300 Email: [email protected] http://ds.thomasmurray.com

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Risk Methodology The CCP Risk Assessments have been designed to provide an

independent assessment of CCPs across a range of defined

risks:

• Counterparty Risk

• Treasury and Liquidity Risk

• Asset Safety Risk

• Financial Risk

• Operational Risk

• Governance and Transparency Risk

All the data for each CCP is structured in a consistent way to

enable users to compare one against the other. Whether it is

CCP interoperability or the impact of individual segregation on

the default fund waterfall, the risk assessment should provide

users with a primary source of information.

CCP Risk Assessments Service

Cassa di Compensazione e Garanzia S.p.A. (CC&G) CCP

Risk Assessments Report

CCP Assessment Reports Available29 CCP Risk Assessments across 21 markets are currently available:

ASX Clear (Futures) Pty Ltd Australia

CDCC Canada

LCH Clearnet SA France

Eurex Clearing AG Germany

Hong Kong Clearing Corporation (HKCC) Hong Kong

Hong Kong Securities Clearing Corp Ltd (HKSCC) Hong Kong

The Clearing Corporation of India Ltd (CCIL) India

Tel Aviv Stock Exchange Clearing House (TASECH) Israel

CC&G Italy

Japan Securities Clearing Corporation (JSCC) Japan

Korea Exchange (KRX) Korea

Bursa Malaysia Derivatives Clearing Malaysia

Asigna Mexico

Contraparte Central de Valores (CCV) Mexico

The Central Depository (Pte) Limited (CDP) Singapore

SGX-DC Singapore

SAFCOM South Africa

BME CLEAR Spain

NASDAQ OMX Clearing Sweden

SIX x-clear Switzerland

TAIFEX Taiwan

CME Clearing Europe United Kingdom

ICE Clear Europe United Kingdom

LCH Clearnet Ltd United Kingdom

CME Clearing (CME) USA

ICE Clear Credit USA

ICE Clear U.S. USA

The Options Clearing Corporation (OCC) USA

Dubai Commodities Clearing Corporation UAE

Thomas Murray Data Services

1st Floor, 1 Farrier’s Yard, 77 Fulham Palace Road, Hammersmith, London W6 8AH

Tel: +44 (0) 20 8600 2300 Email: [email protected] http://ds.thomasmurray.com

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Intermediaries subscribing to the product can white label the

CCP risk assessments for distribution to their end-clients. This

provides an independent source of information to end-users

who need to make a choice of CCP driven by the asset safety

considerations on offer. Thomas Murray Data Services’ white

label solution provides a proven solution including real-time

updates on client customisation.

For more information please contact:

Derek Duggan, Director Sales & Marketing

Email: [email protected]

Tel: +44 (0) 20 8600 2300

Risk Definitions & ExplanationA standard risk model for all CCPs including the following risks and key

information:

Counterparty Risk

One of the major roles of the CCP is to mitigate counterparty risk between the

clearing members. It does this by ensuring that the margin models and default

fund are sufficient to cover market movements in the event of stress and default.

Clearing members are particularly keen to ensure that the margin and default

models do not expose them to undue exposure while at the same time providing

acceptable levels of risk mutualisation. The membership criteria (including credit

checks), limitations on liability and waterfalls attached to the default fund are all

drivers of counterparty risk. The collateral that a CCP accepts introduces credit

risk that may compound the counterparty risk which the CCP is managing. This

can be managed via concentration limits and risk assessed haircuts. The funds

that a CCP places in the market will also incur credit risk.

Treasury and Liquidity Risk

Treasury: The CCP collects participants’ margin and default funds and may

invest these independently using its own commercial criteria. These funds can be

significant and represent a large amount of collateral available to the financial

sector. Clearing members (and their clients) who provide these funds, have a keen

interest in knowing how they are invested on their behalf. A CCP can manage its

market risk by ensuring that it has proper Treasury controls around the deposits

and investments that it makes, employing appropriate limits and ensuring that

the safekeeping arrangements are adequate. This is not the market risk embedded

in a derivatives contract.

Liquidity: The CCP is obliged to repay margin monies as positions and risks in the

market vary. It is required, therefore, to ensure that the assets it maintains are

sufficiently liquid such that it can repay margins at short notice. It may achieve

this by ensuring that its market investments are extremely liquid or in cases of

market stress, that it has alternative credit lines to provide liquidity.

• Funding Liquidity Risk - the risk that a bank will not be able to meet efficiently

the expected and unexpected current and future cash flows and collateral

needs without affecting either its daily operations or its financial condition.

• Market Liquidity Risk - the risk that a bank cannot easily offset or eliminate a

position at the prevailing market price because of inadequate market depth

or market disruption.

The benefits arising from netting and the compression ratios achieved by the CCP

will impact the liquidity requirements of its clearing members.

Asset Safety Risk

Some of the margin arrangements provide for the collection of non-cash

collateral that needs to be held in custody. Clearing members will want to ensure

that they have title to the collateral in the event of a default by another member

or in the event of a default by the CCP itself. Where the collateral is managed by

a third party the CCP will want to ensure that the proper controls are in place by

that organisation that protect the rights of the clearing members to the collateral.

Where the CCP accepts collateral it should ensure that title is appropriate and

that any rehypothecation is properly controlled. If the CCP engages in stock

lending it should manage the risk mismatch between borrowing and lending.

Financial Risk

The risk to the CCP’s own financial condition, which arises from the CCP’s

contributions to the waterfall, losses arising from Market Risk, competitive

pressures and ability to continue as a viable company. Basel III requires the CCP

to contribute to the default fund, which in turn impacts the clearing member’s

capital requirement against its own contribution to the default fund. The level

of support from shareholders, clearing members and possibly governments will

mitigate this risk.

Operational Risk

The risk that deficiencies in information systems or internal controls, human

error or management failures will result in losses either to the CCP or its

clearing members, leading to delays, losses, liquidity problems and in some

cases systemic risk. Includes the ability to process transactions efficiently, the

level of STP (either internal or via third parties), the number of trading venues

supported across the range of products and the level of client segregation. This

risk can be assessed in terms of the availability of the CCP’s infrastructure and

the level of service quality.

Governance and Transparency Risk

The risk that a clearing member may incur a loss arising from the CCP not acting

according to good governance arrangements or not providing full and accurate

information on its activities. The rules, margining methodologies and investment

policies of the CCP should be clear and transparent to the CCP’s stakeholders.

The role of the Board and any Committees constituted under the CCP’s rules

should be clearly laid out and the participants should be suitably qualified. All the

stakeholders should be identified and represented in the governance of the CCP.

Thomas Murray Data Services

1st Floor, 1 Farrier’s Yard, 77 Fulham Palace Road, Hammersmith, London W6 8AH

Tel: +44 (0) 20 8600 2300 Email: [email protected] http://ds.thomasmurray.com


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