10 myths around EMIR, Dodd-Frank Act, CCP and central clearing of OTC derivatives
Story from another consultancy, Foxeye: 10 myths around EMIR, Dodd-Frank Act, CCP and central clearing of OTC derivatives. And here's the myth-busters: Achieving compliance just means selecting a clearing broker: If only
Story from another consultancy, Foxeye: 10 myths around EMIR, Dodd-Frank Act, CCP and central clearing of OTC derivatives. And here's the myth-busters:
- Achieving compliance just means selecting a clearing broker: If only it were that simple, you also need to implement a whole new workflow and economic model for central clearing.
- When we are compliant with EMIR, we are also compliant with DFA: How anyone could believe this is beyond me, but no, although they are similar, the specifics in the US go way beyond those of the EU including business conduct rules and the Volker rule
- Let's not do backloading, it has an impact on P&L: Well maybe, but for now you can free up your credit lines and swap regulatory capital for initial margin
- I only need one clearing broker, that's easy! Yeah, until that one goes bust, and you don't have a backup
- Only centrally cleared deals have to be reported to transaction repositories: In the EU & US all OTCs need reporting, plus in the EU you will need to report exchange traded products too
- Only new deals affect capital charges: yeah right. Think again.
- Why should I clear now, nobody clears: 105 entities clear at SwapClear, who hold fully half of the entire worlds stock of OTC notional
- EMIR is a standalone regulation and done by ESMA: Partly right
- EMIR is about clearing, so let's just not do any IRS and CDS and we are fine: In the short term that might work, but not once the EU or US expand the mandated products
- CCP has no impact on my business model, it is a pure back office topic: See point 1, and know that clearing will affect your Regulatory Capital, CVA and margin funding costs. The front office will notice once they see the costs allocated to their P&L.
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