The thing about useful stuff is

Roger Barton sets up new market infrastructure consultancy Monday, March 14, 2011

Good luck to Roger Barton, until recently managing director and head of regulatory policy for Europe at Tradeweb, who has left to set up a consultancy specialising in market structures and regulatory reform. The firm is called Financial Reform Consultancy.

Many companies certainly need help of this sort to help navigate through the hugely complex and rapid changes being caused by new regulations in the US and EU. Even keeping up with the huge reading list generated by regulation is an massive task in itself - making sense of it and evaluating it on a holistic basis to assess business impact is something few do well.

Labels: CCP, Dodd-Frank, EMIR, OTC, SEF, Tradeweb

posted by John Wilson @ 10:48 AM Permanent Link ,

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Japan's CCP connundrum

Derivatives Week 14th March 2011 edition is reporting that Japan's Regulators are seeking to provide clearing members with limited liability at the same time as preserving the local law which precludes a CCP from going bust.

The reported solution for who should pick up losses in the event of a default exhausting the resources of the CCP, which includes capped contributions of surviving members, is to declear trades back to their original counterparties.

This is an awful solution, widely rejected in almost all major CCPs, for several reasons.

Firstly, it removes certainty from clearing. As a consequence, counterparties will retain a contingent exposure to their original counterparty, with a consequential capital requirement.

Secondly, in most CCPs, trades are offset with each other to create net positions with the CCP. Under this model, one clearly cannot net trades since preserving the identity of the original counterparty is essential if trades are to ever be re-allocated back. As a result, whilst one may have exited a position some months/years ago, a potential exposure remains if those trades are ever unwound by the CCP to revert back to a bilateral exposure. To close such an exposure in the ordinary course of business, one may have to do offsetting trades with the original counterparty, but even that may not suffice depending upon how the CCP determination of unallocated trades works.

Whilst members cannot be exposed to an unlimited liability in order to keep a CCP afloat, and the possibility of a CCP failure sends terror into the heart of regulators, operating contingent clearing simply creates other unpalatable problems.

I sincerely hope that the groups working on this will come up with a more palatable solution, hamstrung as they are by the notion that a CCP may not go bust.

Labels: auction, CCP, CDS, Credit default swap, Japan, member default

posted by John Wilson @ 10:05 AM Permanent Link ,

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DTCC buys their way into Europe Wednesday, October 22, 2008

After many years of fruitless toil in Europe [read London], DTCC has evidently decided to rapidly accelerate Diana Chan's attempt to build a clearing business for DTCC in Europe and is to buy LCH.Clearnet for €739 million. The announcement is here.

EuroCCP, DTCC's European subsidiary, had won business from Turquoise but in taking over one of the major European players, DTCC has instantly vaulted up the central counterparty league table in Europe. Interestingly, the existing LCH CEO, Roger Liddell whom I briefly worked with at Goldman, will be the CEO of the new combined European entity ["LCH.Clearnet HoldCo"].

Roger was made Head of Global Operations at Goldman Sachs in 2000. He was responsible for all businesses including equities, fixed income, foreign exchange, derivatives, commodities, asset management, prime brokerage and private wealth management. He is already very well known to DTCC as a consequence.

Where this leaves Diana Chan and her experienced COO, Trevor Spanner, is presently unclear.

I suspect that the combined entity in Europe will simply adopt LCH's systems, requiring Turquoise to migrate platforms. The larger question is to what extent DTCC will embark on the ambitious project to integrate the European infrastructure with the domestic US infrastructure.