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OTC regulation: Collateral management blocks derivatives reform

Scarce collateral threatens funding; New systems complex and expensive

Clearing reform in the over-the-counter (OTC) derivatives markets will not reduce systemic risk, according to 50% of market participants surveyed at a recent industry gathering at University College London.

Of the 34 leading firms represented in the collateral-optimization debate only 44% thought that regulatory changes will achieve their intended effect of making the financial system safer.

These changes include the Dodd-Frank Act in the US and new European market infrastructure regulation.

It’s a discouraging conclusion from industry leaders. Derivatives reform was designed to offer them a clear bargain: reform might reduce margins, especially for the better-rated banks that dominate trading volumes in the derivatives markets, but by making the whole system safer it should bring a compensating benefit and the prospect of higher volumes of client business.

That’s not how it looks to those working at the coalface, apparently, where the costs of overhauling banks’ collateral-management systems are so hefty that the share of a handful of leading dealing firms might even rise, so increasing the financial system’s potential vulnerability to the collapse of a small handful of counterparties.

At first sight, it seems odd that industry leaders should be so downbeat, given the orderly unwind of so many trades when MF Global collapsed.

David Field, executive director of consultancy firm Rule Financial

"Banks are being forced to offer client clearing to protect their franchise, or they risk being disintermediated – clients will simply go elsewhere"

David Field, Rule Financial

"The good news from MF Global was that it showed trades don’t have to be centrally cleared to be safe," says David Field, executive director of consultancy firm Rule Financial. "The vast majority of its trades were bilateral and collateralized, and unwound without hitch."

The industry’s difficulty stems largely from the operational challenge of overhauling its collateral-management systems to respond to daily and intra-day calls from central clearing parties, while also potentially organizing such responses on behalf of clients, and while managing collateral to be posted and required from other counterparties on a bilateral basis.

"Banks are being forced to offer client clearing to protect their franchise, or they risk being disintermediated – clients will simply go elsewhere," says Field. "The concept of legally separated, operationally commingled accounts will increase flexibility while decreasing costs. But we’re hearing push back from the buy side, who are nervous about commingling, so the jury is out on its future uptake. Many banks have still not worked out how they are going to charge their trading desks, let alone their clients, for the true cost of collateral, which will include use of the bank’s balance sheet."

Most banks still operate several collateral-management systems that grew up within individual business units at a time when their own collateral was generally abundant compared with demands for it. All that has changed. Collateral is suddenly precious, scarce and much in demand, including for banks’ daily funding and liquidity needs.

The days when banks could fund themselves in the money markets on an uncollateralized basis are gone and banks must manage collateral much more intensively. But this is proving to be a challenge.

"There’s no one reason why even the big banks found it harder than they thought to build solutions," says David Little, director of strategy and business development for securities finance and collateral management at Calypso Technology, a financial IT firm.

"There is a huge amount of data on different classes of collateral held across many divisions often subject to varying legal documents and credit support agreements that all needs to be brought together. There are collateral performance and valuation issues, and banks will have to require collateral from customers they didn’t previously demand it from, because the capital cost from taking the counterparty risk of not demanding collateral would be punitive."

Good systems to cope with all this will have to be capable of calculating haircuts on all manner of collateral, as banks look across their available inventory and seek to wring advantages from identifying cheapest-to-deliver collateral against their various legal requirements.

At a time when banks are struggling to fund themselves, and earnings in corporate and investment banking divisions are collapsing, building such systems is an expensive headache. Some of the biggest banks are spending $40 million a year today on collateral-management infrastructure and are still only in the early stages of multi-year investment projects.

Those that stick with it might eventually reap the benefits in higher volumes. Many more banks will likely decide the investment is not worth it and so leave the financial system exposed to dependence on a few large derivatives trading counterparts: the very problem that derivatives regulation was supposed to tackle.

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