Friday, November 5, 2010

Comments on Jesus Fernandez-Villaverde's Recomendaciones de Lectura: Ley Dodd-Frank

Spanish - comentary on Jesus Fernandez-Villaverde's Recomendaciones de Lectura: Ley Dodd-Frank, Oct 22, 2010, http://www.fedeablogs.net/economia/?p=7059 :

hola, el artículo referido habla de "[c]entralised clearing of derivatives" y dice que, junto con "the push for greater transparency of prices, volumes, and exposures–to regulators and in aggregated form to the public–" los mercados deberían estar mejor capacitados "to deal better with counterparty risk, in terms of pricing it into bilateral contracts, as well as understanding its likely impact."

De ninguna forma se ve en ese artículo, basado en la introducción del libro que van a publicar los autores, que haya alguna preocupación por que los centralized clearinghouses puedan ser "the ultimate too big to fail organization."

Abundando en esa preocupación, un artículo en WSJ (European Clearing Reform Dealt Late Setback, Nov 01, 2010, http://online.wsj.com/article/SB10001424052748704141104575588451106445976.html) revela los últimos desarrollos en Europa al respecto:

"
[...]

Regulators were this week expected to approve a so-called "interoperability" arrangement between four of Europe's largest clearing houses [...]. However, at least one national regulator—thought to be the U.K.'s Financial Services Authority—raised concerns over the deal at the eleventh hour and has postponed its approval until the end of this month at the earliest, these people said. Those worries are understood to center on risk-management issues.

[...]

[A] source close to one of the clearers said the FSA had contacted the four central counterparties, advising them that the meeting at which the decision was expected to be made would be delayed until the end of November. The FSA wasn't available to comment.

In February this year, the regulator sent a private letter to the central counterparties in which it outlined concerns that the clearing houses needed to account for a number of risks created by interoperability. These included additional counterparty credit risk, technical, and liquidity risk. The FSA hasn't prescribed any measures, however, and has left it up to the central counterparties to work out how to address these issues.

[...]

Responding to industry pressure, LCH.Clearnet, SIX x-clear, EuroCCP and EMCF agreed to link their technology systems in the first half of last year but concerns regarding the threat of "contagion risk" between clearers—namely that the clearers could spread systemic risk across borders—led the Dutch, Swiss and U.K. regulators to halt the project last November.
"

Por supuesto, no he encontrado la carta de FSA en su website. Si alguien puede añadir más información, por favor, sería de agradecer.

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European Clearing Reform Dealt Late Setback, by Michelle Price
WSJ, Nov 01, 2010
http://online.wsj.com/article/SB10001424052748704141104575588451106445976.html

AMSTERDAM—A long-awaited agreement between four of Europe's leading clearing houses, which was expected to be signed off as early as this week and would have opened up competition in the market after years of pressure from banks and investors, has been postponed by European regulators at the last minute, according to people familiar with the matter.

Regulators were this week expected to approve a so-called "interoperability" arrangement between four of Europe's largest clearing houses: the London-based LCH.Clearnet; the Swiss clearer SIX x-clear; EuroCCP in London; and the Netherlands-based European Multilateral Clearing Facility, according to senior sources in the market infrastructure industry attending the Sibos conference in Amsterdam last week.

However, at least one national regulator—thought to be the U.K.'s Financial Services Authority—raised concerns over the deal at the eleventh hour and has postponed its approval until the end of this month at the earliest, these people said. Those worries are understood to center on risk-management issues.

Interoperability is important because it would open up the fragmented post-trade market infrastructure to competition and reduce costs for market participants and, ultimately, for investors and pension funds.

Interoperability between clearers would allow trading firms to choose which clearing house they want to clear their trades, instead of being—as they are now—forced through the clearer chosen by the exchange or platform on which they are trading.

Most exchanges and trading venues in Europe route their trades through a single clearer. All-in trading costs are consequently as much as 10 times higher than in the U.S. The lack of open competition means that fees for clearing and settlement account for the majority of trading costs for investors and market participants.

The industry hopes that interoperability could have the same impact on clearing and settlement as the 2007 markets in financial instruments directive did on equities trading, or Mifid. Mifid triggered a wave of new entrants into the equities market, increasing competition and reducing trading fees across the industry.

The head of one trading venue said last week at the Sibos international banking conference in Amsterdam: "We are expecting the go-ahead for full interoperability between these four clearers to come—at last—in the first week in November." Sources close to two of the clearers involved confirmed the expected announcement.

However, a source close to one of the clearers said the FSA had contacted the four central counterparties, advising them that the meeting at which the decision was expected to be made would be delayed until the end of November. The FSA wasn't available to comment.

In February this year, the regulator sent a private letter to the central counterparties in which it outlined concerns that the clearing houses needed to account for a number of risks created by interoperability. These included additional counterparty credit risk, technical, and liquidity risk. The FSA hasn't prescribed any measures, however, and has left it up to the central counterparties to work out how to address these issues.

The concept of interoperability was first mooted by the former European Commissioner for the internal market, Charlie McCreevy, who imposed a code of conduct on the industry in 2006. However, a combination of vested interest and protectionism by incumbent clearers meant the code was broadly ignored.

Responding to industry pressure, LCH.Clearnet, SIX x-clear, EuroCCP and EMCF agreed to link their technology systems in the first half of last year but concerns regarding the threat of "contagion risk" between clearers—namely that the clearers could spread systemic risk across borders—led the Dutch, Swiss and U.K. regulators to halt the project last November.

In August, the clearing houses re-submitted a detailed plan that addressed these concerns by including provisions for more robust risk management between the clearers. It is understood the regulators have yet to finish their analysis relating to the cash collateral provisions designed to address their concerns over contagion.

"Interoperating in cash equities is not tremendously difficult," one person close to the discussions said. "The problem has been that during the reviews that the regulators have been performing during the last year, the analysis produces a list of questions and the answers generate more questions, so it's been a fairly circular process."

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