Beat the Experts

Between the contributors to this website we ought to be able to answer any question on OTC derivatives and the post-trade space – go ahead and see if you can ask a question we can’t answer. Add your question to the comments below or email me direct using the Contact page.

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Inbox 2013-03-27 15-49-30

Subscribe and Receive a Daily Summary

If you want to avoid RSS, and also avoid individual emails, I have setup a daily summary of the days posts, sent out at 5pm each week day. An example is shown below (truncated), the email is brief and can be scanned quickly. Sign up using this URL to visit the list: http://eepurl.com/xkKtT each email will […]

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D087 2013 02 13 CCP Notionals

Latest CCP & SDR Status Charts as of Feb 2013

Here is the status of CCPs and SDRs for OTC products. Data for the CCPs is from the respective websites, data for the SDRs is from the recent FSB (mid-2012) progress report. Click on the charts to enlarge. Update on Feb 13th Fixed ICE EU numbers, not linked properly, now showing latest numbers Labelled numbers […]

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emir timeline

Official Timeline for EMIR

UPDATE 18th March: New timeline from ESMA: Source: http://www.esma.europa.eu/page/European-Market-Infrastructure-Regulation-EMIR Also: EMIR Q&A EMIR Q&A_2013-03-20 (2013-324) UPDATE Mar 4th: ESMA made another timeline update, here’s the corresponding timeline courtesy of Tom Riesack at Capco (Twitter: here LinkedIn here). Download the accompanying PDF by clicking here: EMIR Timeline (Update as of 4.3.2013) v2 UPDATE 27th Feb: A new cleaned up chart provided by Tom […]

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O’Malia speech – useful synopsis of what’s not yet regulated

A way through the fog of CFTC Title VII final rules, exemptive orders and no action letters is offered by Commissioner O’Malia’s speech to Energy Risk 2013.  He uses a Rumsfeld-like categorization of known unknowns and unknown unknowns to sum up what’s still to be done and to be discovered as a result on reporting, clearing […]

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Useful Roundup of SEF rules plus Q&As

All the source materials from the CFTC on the new SEF rules. CFTC Votes SEF Rules Forward.  

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Buy Side Backs Bloomberg Margin Request | Makes No Sense

All this debate on the appropriate holding period for futures, swaps or their hybrids, would be avoided if the CFTC and other regulators developed an approach that obliged each DCO (CCP) to provide empirical evidence for the product and market they wish to clear. This evidence would include trading data, portfolio data from market markers, the default process description, and dry runs of the default process off-line.

It is entirely wrong for the holding period for a market/product to be set without such evidence, either from a DCO, or from the CFTC themselves. The current approach by the CFTC is opaque – how did they arrive at their current (arbitrary) decisions for futures versus swaps? Lets see their method, their data and their explanation and prove to the market, the results make sense.

Buy Side Backs Bloomberg Margin Request :: TabbFORUM – Where Capital Markets Speak.

 

The echo of CFTC’s approval on Final SEF Rules

Yesterday, the CFTC met to vote on final rules for swap execution facilities (SEFs). The Commission’s five members voted in a public meeting on new platforms for swaps that will bring bilateral trading to an end, and transfer trades to centralized, transparent marketplaces. A lot of criticism on these decisions is already loudly expressed from some of the commissioners themselves, stated at the vote in their prepared statements and also SIFMA that released a statement arguing that the new rules ‘will negatively impact investors and hinder the ability of American businesses to manage risk.’

You can find more details in the links below:

Maria L.

The CFTC has approved SEF rules, block rules, MAT rules

Almost unbelievably, the CFTC has voted in favor of the trade execution rules.

The CFTC voted 3-2 to pass the Swaps Blocks Rule. The CFTC also voted 3-2 to approve the Made Available to trade rule. The agency voted 4-1 to pass the SEF rules. Lastly, the Commissioners voted unanimously to approve the Interpretive Guidance and Policy Statement on Disruptive Practices.

State Street put together two good overviews of what the rules look like here and here.

SEC advise EC and ESMA to consult on EMIR equivalency

“European authorities should consult on their approach to determining whether foreign derivatives regimes are equivalent to the European Market Infrastructure Regulation (EMIR) because these decisions have the power to break up the over-the-counter derivatives clearing system“.  This is Eric Pan speaking, associate director in the office of international affairs at the US Securities and Exchange Commission (SEC) , at an industry briefing organised by the Futures and Options Association in London today.

In other words, SEC urges ESMA and EC to adopt US practice and solicit public comment on what they draft. The public, market participants and other interested parties should be able to take a look at what the regulators are suggesting and indicate where they may have got certain things wrong or suggest where they can do things better. They strongly advise them to stray away from the “all-or-nothing” approach.

I can agree on this point, however, some little voices keep popping up at the back of my head telling me that US based CCPs fear that they will loose a big market share if ESMA does not give them authorisation…..

More details here.

Maria L.

The EMIR Delusion

Reblogged from Regulatory Reform:

Introduction

Under EMIR, parties to OTC derivative transactions are classified as either:

  • financial counterparties (“FC”);
  • non-financial counterparties which have exceeded the clearing threshold (“NFC+”); or
  • non-financial counterparties which have not exceeded the clearing threshold (“NFC-”).

Whilst primarily used to determine whether a counterparty is subject to the obligation to clear, in reality a number of different EMIR requirements can apply depending on the exact counterparty classification. 

Read more… 1,383 more words

Anecdotal and empirical evidence would suggest that the market is currently doing very little in the way of understanding, confirming or monitoring EMIR counterparty classifications.

First FCM completes production testing with CreditLink | Market Infrastructure

Things are moving fast in US and the first FCM has completed its production testing with CreditLink. One of the fundamental points of CFTC regulation 1.7 provides that clearing firms and buy-side firms should be able to ensure certainty of clearing acceptance by their clearing member at the time of execution and this service offers them the ability to manage trading and clearing limits in low latency for interest rate, credit and foreign exchange (FX) swaps.

More details here.

P.S I haven’t seen any announcement by MarkitServ on Credit Centre by the way. Any news there?

Maria L.

Allen & Overy on EMIR

Allen & Overy published a short summary of EMIR key points and make some noteworthy comments. “Structured finance vehicles” part caught my eye in particular, where it’s more than obvious that these entities will give their compliance departments lots of headaches….

Check this out here.

Maria L.

iPhone 4 32GB | For Sale

I have an iPhone 4 for sale, it’s a UK phone, currently on O2, but not locked to a network as it came from Apple originally. It’s in good condition, fully working. I think I’ve got a box somewhere, and a charger if you need it. Looking at completed successful eBay sales, it appears to be worth £225.

IMG_0101

OTC Derivatives, Bilateral Trading and Central Clearing | David Murphy | Palgrave Macmillan

On the 26th of July, open your wallet for the next book with a chapter by myself on the mechanics of clearing, plus a whole lot from David Murphy too.

OTC Derivatives, Bilateral Trading and Central Clearing | David Murphy | Palgrave Macmillan.