Professional Documents
Culture Documents
counterparty clearing
Dr Jon Gregory
www.oftraining.com
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 1
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 2
Some Initial Thoughts
“If history repeats itself, and the unexpected always happens, how
incapable must Man be of learning from experience.”,
George Bernard Shaw (1856 - 1950)
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 3
The Monoline Debacle
• The most recent attempt to create high quality counterparties was not
so successful (see www.oftraining.com for these papers)
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 4
Pros and Cons of Central Clearing
i) Background
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 5
The Birth of OTC Derivatives
IR and Currency CDS EQD
Notional Outstanding ($Tr)
500,000
400,000
300,000
200,000
100,000
0
1H98
2H98
1H99
2H99
1H00
2H00
1H01
2H01
1H02
2H02
1H03
2H03
1H04
2H04
1H05
2H05
1H06
2H06
1H07
2H07
1H08
2H08
• OTC dominate exchange traded derivatives
• But credit crisis has curtailed strong growth in derivatives markets
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 6
Relative Size of Derivatives Markets
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 7
Counterparty Risk by Asset Class
• “PLEASE GIVE A BREAKDOWN OF WHERE YOU FEEL
YOUR COUNTERPARTY RESIDES IN TERMS OF ASSET
CLASS”
Interest-rates
FX
Commodity
Equity
Credit derivative
Exotics
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 8
Pros and Cons of Central Clearing
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 9
Mitigating Counterparty Risk – Netting
• Disadvantages
‒ Gives OTC derivatives counterparties preferential treatment compared to other
creditors of a bankrupt institution
‒ Legal risk
‒ May allow excessive growth in OTC derivatives markets
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 10
Mitigating Counterparty Risk – Close-out
• Disadvantages
‒ Gives OTC derivatives counterparties preferential treatment compared to other
creditors of a bankrupt institution
‒ Legal risk
‒ May allow excessive growth in OTC derivatives markets
‒ Walkaway features (non-standard) allow an institution to gain from their
counterparty’s default
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 11
Mitigating Counterparty Risk
– Additional Termination Events (ATEs)
• Advantages
‒ Allows exposure to be terminated with a counterparty in distress without any loss
• Disadvantages
‒ Relationship issues
‒ Early termination events with multiple counterparties create a death spiral (AIG)
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 12
Mitigating Counterparty Risk – Collateral
• Two way collateral agreements are perhaps the optimal way to reduce
credit exposure and counterparty risk
• Advantages
‒ Can, in theory at least, completely eradicate counterparty risk (assuming no jumps
in market variables)
• Disadvantages
‒ Creates operational, legal and liquidity risks
‒ Not ideal to post cash collateral, especially when there are liquidity issues
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 13
Mitigating Counterparty Risk – Hedging
• Hedging counterparty risk has become practical with the birth of the
credit derivatives market in the last decade
• Advantages
‒ Credit default swaps (CDSs) can hedge directly an exposure vis à vie a credit line
‒ Contingent CDS can completely remove counterparty risk for a given trade
‒ Index CDS can hedge the overall sensitivity of counterparty to market spreads
(CVA)
• Disadvantages
‒ Insufficient liquidity in credit derivatives products, especially single name
‒ Contingent CDS are very limited
‒ Credit derivatives themselves have severe counterparty risks
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 14
Pros and Cons of Central Clearing
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 15
Advantages of Central Clearing
• Multilateral netting
• Loss mutualisation
• Standardisation
• Capital reduction
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 16
Multilateral Netting (I)
• Multilateral netting
Bilateral netting Multilateral netting
A B A B
F C F CCP C
E D E D
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 17
Multilateral Netting (II)
A A A
3 3 0
5 5 2 2 0
5 0
2
B C B C B C
3
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 18
Advantages of Central Clearing
• Multilateral netting
• Loss mutualisation
• Standardisation
• Capital reduction
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 19
CCP Waterfall
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 20
Advantages of Central Clearing
• Multilateral netting
• Loss mutualisation
• Standardisation
• Capital reduction
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 21
Standardisation
• Impact
‒ Easier to unwind trades (together with multilateral netting benefits)
‒ More counterparties will trade in certain products
‒ Reduction in asymmetric information
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 22
Advantages of Central Clearing
• Multilateral netting
• Loss mutualisation
• Standardisation
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 23
Advantages of Central Clearing
• Multilateral netting
• Loss mutualisation
• Standardisation
• Capital reduction
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 24
Legal and Operational Efficiencies
‒ Netting services
‒ Collateral management
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 25
Pros and Cons of Central Clearing
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 26
Disadvantages of Central Clearing
• Standardisation
• Competition
• CCP failure
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 27
Multilateral vs Bilateral Netting
• Netting increase
‒ Removal of bilateral netting benefits of that asset class
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 28
Will Exposure Be Reduced?
• Duffie and Zhu [2009]
4 asset classes 3 asset classes 2 asset classes Required number of dealers for
16
a single asset class CPP to
Required number of dealers
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 29
Disadvantages of Central Clearing
• Standardisation
• Competition
• CCP failure
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 30
Disadvantages of Standardisation
• Many OTC derivatives are traded in a situation where only one party
has a good knowledge of the valuation of the derivative
‒ Simple customisations (slightly different maturity date for example) are reasonable
but would be prevented in a CCP market
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 31
Disadvantages of Central Clearing
• Standardisation
• Competition
• CCP failure
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 32
Risk Homogeneity / Asymmetric Information (I)
• Multilateral market
‒ Credit quality is assessed in a less granular way
‒ No incentive to monitor the credit quality of ones counterparties
‒ Weaker credit quality institutions may enter the market
‒ An institution with worsening credit quality may be ignored (to a degree)
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 33
Risk Homogeneity / Asymmetric Information (II)
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 34
Winner’s Curse (I)
‒ Wrong-way risk?
‒ The multilateral netting benefit of this trade / open positions versus hedged
positions
‒ Correlation
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 35
Winner’s Curse (II)
Interest-rate swap
CDS (index)
CDS (single-name)
CDO tranches
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 36
Disadvantages of Central Clearing
• Standardisation
• Competition
• CCP failure
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 37
Legal and Operational Risks
• CCPs reduce systemic risk in one sense but may increase it via
concentrating legal and operational risks
• Critical that a CCP has complete integrity with respect to
‒ Enforceability of netting agreements
‒ Collateral requirements
• Operational risk
‒ Systems failure
‒ Fraud
• Standardisation
• Competition
• CCP failure
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 39
The Size of a CCP
‒ More competition with the danger of CCP fees and collateral requirements being
not conservative enough
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 40
Disadvantages of Central Clearing
• Standardisation
• Competition
• CCP failure
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 41
CCP Failure
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 42
Stability of a CCP
• CCPs will
‒ Have strong margin requirements
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 43
Pros and Cons of Central Clearing
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 44
Making a CCP work
• Margin requirements
‒ Must be set very carefully
‒ Failure to post margin must be swiftly acted upon
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 45
Final Comments
• Counterparty risk has been heavily disguised over the last decade
‒ “Too big to fail” institutions representing little or no counterparty risk (Lehman, AIG)
‒ Monolines with spurious triple-A ratings
‒ Failures of practices such as special purpose entities and collateral (rehypothecation)
‒ Bilateral counterparty risk
‒ Complex structures such as leveraged super seniors (LSS)
• Will a the CCP idea work and be preferable to bilateral OTC markets?
‒ We may not know for many years
‒ CCPs must learn from past lessons of risk management failures and not be tempted
to become less conservative after long periods of low default rates
‒ A CCP failure is one obvious way in which to recreate the extreme nature of the
recent crisis
Jon Gregory (jon@oftraining.com) Impact of regulatory reform on clearing and settling OTC derivatives, 5th February 2010 page 46