Post-trade risk reduction has become increasingly common as a means to reduce risks in the derivatives market. Portfolio compression is a case in point: offsetting trades between multiple parties are torn up, which reduces the size of gross exposures, in turn reducing systemic risk. Over €1,000 trillion in derivatives exposures has been eliminated in this manner.
Regulators recognize the value of compression. Under the European Market Infrastructure Regulation (EMIR), market participants with more than 500 over-the-counter (OTC) trades on their books are required to examine the possibility of performing portfolio compression twice a year.
However, EMIR simultaneously disincentivizes use of this service by requiring administrative trades that result from compression, and which fall under the clearing mandate, to be cleared. This limits the ability of participants to perform compression and reduce risk.
The same is true of other post-trade risk reduction services like counterparty rebalancing. This involves inserting new, market-risk neutral transactions into netting sets to reduce risk exposures between counterparties. This decreases counterparty credit risk and therefore reduces systemic risk. However, those new transactions are required to be cleared if they are subject to the clearing obligation, preventing counterparty rebalancing risk reduction from taking place. As a result, counterparty rebalancing today is only limited to FX derivatives, which are not subject to the clearing obligation. Over €100 billion in counterparty credit risk has been reduced in this manner.
ISDA, the EBF, ICMA and ISLA believe EMIR should be amended as part of the Regulatory Fitness and Performance program (REFIT) to allow non-price forming, market-risk neutral transactions that result from post-trade risk reduction services to be exempted from the clearing obligation.
To read the full whitepaper, click on the link below.
Documents (1) for Incentivizing Post-trade Risk Reduction
Latest
Expanding Legal Agreement Coverage in the CDM
This paper examines the recent extension of the Common Domain Model (CDM)1 to represent two of the most significant, and previously undeveloped, areas of its legal agreement model: umbrella agreements and contract amendments. Umbrella agreements are widely used to document...
ISDA Omnibus Canadian Representation Letter
On September 2, ISDA published the Omnibus Canadian Representation Letter, which combines previously published representation letters drafted to assist firms in compliance with Canadian trade reporting, business conduct, regulatory margin and clearing classification rules. The Omnibus Canadian Letter is designed...
Joint Response on Cross-margining
On August 31, ISDA and FIA submitted a letter to the US Commodity Futures and Trading Commission (CFTC) and the Securities and Exchange Commission (SEC) on the agencies’ joint request for comment on the implementation of portfolio margining and cross-margining...
Accounting for Carbon Credits: Latest Developments
This paper updates and extends the analysis set out in ISDA’s October 2023 paper on accounting for carbon credits. While preserving the original focus on the accounting treatment of voluntary carbon credits (VCCs) and compliance carbon credits (CCCs), it expands...
