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vice president, risk solutions, SunGard's capital markets business

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Risk Management: Conferences, Convergence and Catastrophe

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This blog post was originally published on TabbFORUM.

Late October 2012 saw an RMA conference on risk management in Dallas, the annual FIA conference in Chicago, and a catastrophic natural disaster in and around New York. While these were separate events with very different impact levels, all three were connected by the complexity of modern risk management, what it means, and how its outputs can be understood and used.

Dallas

Conversation at the Risk Management Association event in Dallas was focused largely on developing, implementing and managing a risk appetite within a financial institution. This tackled from multiple angles, including liquidity risk, market risk and credit risk. The recurring theme of the discussions was the difficulty in developing a framework that works both top-down from an enterprise-wide risk tolerance perspective, and bottom-up from an individual risk contributor’s perspective.

Risk appetite definitions ranged across benchmarked “active” risk budgeting (VaR against benchmarks), economic capital, collateral and funding costs, VaR and VaR shortfall. As has been noted before, it is interesting that in the aftermath of a financial crisis which saw VaR receive critical attention, its use is expanding into bilateral calculation of collateral and central clearing margins.

Chicago

It was those same central clearing margins that took center stage at Chicago’s Futures Industry Association conference. As a business more used to exact calculations built on lot sizes and observable prices, the relative complexity, convexity and simulation-based margining of interest rate swaps are causing many to strengthen their technical architecture and approach. As the single largest OTC derivative class heads to the margin model, FCMs and their clients are becoming familiar with historic simulation, decay factors and look-back periods. At the same time, the margin posted is looking more and more like an alternative for economic capital, even using the same techniques to generate the number.

The VaR number itself, of course, is essentially predicting the minimum loss that would be expected to happen at the specified percentile. For example, a 99th percent VaR predicts the minimum loss that should be expected to happen once in every hundred days.

New York, New Jersey, and Neighboring Areas

As the conferences in Dallas and Chicago were happening, the tri-state area of New York, New Jersey and Connecticut were actually experiencing a devastating weather event.

The parallels between a VaR calculation and this “perfect storm” are as inescapable as they are shocking. Defined variously as a tail event or a 2.33 standard deviation event, the VaR cases are typically characterized by multiple loss-causing events occurring within the same simulation. This is a low percentile by definition, but has an extremely large impact. In terms of what faced the northeast U.S., a high tide and a hurricane create the worst possible outcome for the shoreline areas. Here, risk management hits closer to home.

Risk management is a control function that mitigates, to a degree, the impact of the extremes. It is also a fact that events deep in the tail are often uncontrollable.  It was with shock that reports of Hurricane Sandy’s effects were viewed, and with a sense of humility that the aftermath restorations are being tackled.

Risk can often be seen as a dry academic subject, as more theory than reality, and the discussions in Dallas and Chicago could lend weight to that opinion. However, the events in the tri-state area graphically and violently demonstrated that tail events do happen, and enormous damage can be caused when extremes collide.

While you’re here…

head of product management, Adaptiv, SunGard’s capital markets business

FULL STEAM AHEAD TO A NEW BEGINNING?

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This blog post originally appeared on FOW.

The rapid response to the financial crisis initiated by the G20 has led to a plethora of new regulations which sometimes seem like a never-ending series of sticky plasters trying to patch up a leaky hull. No sooner has one leak been fixed (think Stressed VaR or Incremental Risk Charge) than another springs forth (think CVA or Wrong-Way Risk). Inevitably in times of crisis and emergency this approach is needed to steady the ship, but shouldn’t we also be trying to steer a course to a safe harbor?

This seems to be the thinking behind the Basel Committee on Banking Supervision’s latest consultation document entitled “Fundamental review of the trading book.” The aim of this review is to set a consistent framework within which to think about regulatory capital and, despite the name, it touches upon the banking book as well as the trading book.

The suggestion that will inevitably grab the most headlines is the proposal to replace VaR (Value at Risk) as the main measure of market risk with ES (Expected Shortfall). Although controversial, this has many practical and theoretical advantages. The main stated benefit is that whereas VaR provides a lower bound on extreme losses (“you’ll lose at least this much, but we can’t say how much worse it could get”), ES tries to quantify what dangers lurk in the tail of the loss distribution (“this is the average of the really bad losses”).

However since ES relies on much the same simulation framework as VaR, it still suffers from some of the other drawbacks, such as the assumption that looking into the past can tell you something about the future. Also, back-testing ES (i.e. trying to judge whether your model is in fact good at predicting the future) is a lot more complex than back-testing the simpler VaR concept.

Some other proposals, such as introducing liquidity assessments into market risk measures, seem particularly prescient in the light of recent multi-billion dollar trading losses in illiquid credit default indices. However it seems unlikely that the traders taking on those positions didn’t know that there was finite liquidity available, and so the question is whether or not a liquidity indicator would have led to risk management overruling the trading desk’s strategy.

Probably the most significant proposals from a long-term perspective surround the boundary between the trading book and the banking book. One of the major issues of the financial crisis was the ability of banks to arbitrage between the two books; the tightening up of rules about where assets are accounted for can only help. Since interest rate risk is a pillar 1 item for the trading book but a pillar 2 item for the banking book there is more work to be done, but getting a comprehensive and consistent framework across all areas of risk is one way to ensure our banks weather future storms better than they managed the recent ones.

While you’re here…

trading and client connectivity, SunGard’s global trading business

HOW REAL-TIME CAN RISK MANAGEMENT BE?

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This blog post also appears on ATMonitor.

The regulatory push towards real-time trading risk management was addressed in a panel session at the 2012 SunGard Industry Seminar in London. The discussion pulled together of a lot of useful information for participants, but ultimately didn’t generate too much controversy. It seems that the regulators are for the most part pushing at an open door with their demands for tighter pre-trade risk controls. Stories abound, we’re told, of risk management teams now able to pursue projects they had long thought important or even necessary, but had historically lost out to other competing priorities.

During the panel discussion, Simmy Grewal of Aite Group presented a round-up of the major regulatory initiatives that touch on this area. It’s a considerable list.

  • The U.S. SEC Market Access Rule (15c3-5) is designed to eliminate “naked access” to equity execution venues and requires brokers to establish pre-trade risk controls in all cases.
  • The U.S. CFTC’s proposal for position limits on commodity derivatives (part of the Dodd-Frank legislation) still faces legal challenges, and requires more work on establishment of futures/swaps equivalents, but if enforced later this year, will effectively require global controls of pre-trade risk.
  • In the EU, the MiFID II proposals include text that implies ESMA will develop commodity derivative position limit standards similar to those of the CFTC.
  • Also in the EU, ESMA’s Guidelines on pre-trade risk management for automated trading engines are currently being incorporated into national regulations.
  • The real-time application of credit valuation adjustment (CVA) techniques to provide accurate measures of counterparty and liquidity risk exposures in OTC markets is required under the Basel III rules.

Stuart Adams of FIX Protocol Limited brought an interesting perspective to the discussion: FPL has been very active in the pre-trade risk field, and is due shortly to publish an update to its 2011 Risk Controls guidelines, extending their scope to cover listed derivatives as well as equities.

Throughout the discussion, the panel addressed questions around three different areas.

How real-time can risk management be?

You don’t get more real-time than pre-trade – which is now being required in a range of cases. The major difficulty with being fully real-time is that in most trading firms of any size there will be multiple trading architectures in use, and also there will be trading on multiple exchanges. Limits and margin then have to be allocated and shared across them, and it’s hard to do this optimally. This is a particular challenge in derivatives trading, given the complexities of managing margin. Risk also has to be managed across related asset classes – typically futures, options and swaps.

The push for better risk management comes at the same time as an urgent priority on lower latency. This places tight limits on how much checking you can do pre-trade and creates a challenge for software builders – how fast can they make the checks run? As a result, we see firms making necessary practical compromises: for example, pattern risk controls (recommended in the FPL Guidelines) are generally placed post-trade.

Where do buy- and sell-side firms need to place emphasis in their compliance efforts?

There are difficult decisions here, given that many other issues are live at the same time, particularly in Europe, with the rest of MiFID and the MAD review. But getting pre-trade risk management right, across the industry, has to be a major priority. There will be no excuses for anyone breaking a limit.

Firms need to ensure that comprehensive software controls are in place for all electronic trading, whether from screens or automated trading engines. Where these already exist, the systems in place and how they are configured need to be reviewed. Not all systems will be capable of handling all checks in 15c3-5 or the ESMA Guidelines. Firms also need to ensure that the controls are well documented.

The challenges multiply where different markets and diverse trading architectures are involved, but technology solutions exist that can help optimize the management of such environments.

Can some real business benefits be gained at the same time?

Arguably, given the scale of what can happen in an electronic trading environment, every trading firm should be on the same side as the regulators. We’ve certainly seen examples of both brokers and buy-side firms using the regulations as a lever to make risk management or technology improvements that did not previously get budget or resource focus. This shouldn’t come as a surprise. We are, after all, talking about the avoidance of what could in the worst case be catastrophic risks.

This panel session amounted to a general agreement that there is little point in fighting the regulatory direction on pre-trade risk management and that in many ways it will benefit business. The big issues include assuring the quality of systems for each trading architecture and asset class, and deciding how far to go with the more complex controls in order to optimize the use of available capital and margin.

While you’re here…

vice president, risk solutions, SunGard's capital markets business

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Q&A: HOW WILL RISK MANAGEMENT CHANGE TO SUPPORT THE NEW OTC DERIVATIVES MODEL?

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Last week I participated in a webinar and a Twitterview with DerivSource, covering the changing landscape of risk management in the new OTC derivatives workflow model.  It goes without saying that risk is at the center of regulatory reform; the new world of risk management must develop to meet the new requirements and challenges facing the OTC derivatives markets.

During the Twitterview in particular, DerivSource boiled down several big questions about drivers of change with regard to risk management today. It’s amazing how much you can actually discuss in a few simple tweets. This Twitterview, under the #derivrisk hashtag, touches on drivers and changes to risk management in the OTC derivatives markets, credit valuation adjustment (CVA), risk with relation to CCPs and potential strains on liquidity, the role of “real time” in risk, and more.

If you missed this risk management Twitterview with DerivSource, search #derivrisk or follow the full Q&A below. And as always, if you have your own questions about risk management in the changing OTC derivatives landscape, leave me a comment or ask me on Twitter to continue the conversation.

QUESTION: What is the biggest driver for risk mgmt improvements – transparency requirements or new risk in the new OTC model? #derivrisk

MARCUSCREERISK: New risks in the OTC clearing space are a far bigger driver for risk mgmt in my opinion…The FCM world is facing longer tenors, and more complexity than it has hitherto known #derivrisk

QUESTION: What is the biggest change impacting pre-trade risk mgmt for firms participating in the new OTC derivatives market? #derivrisk

MARCUSCREERISK: Understanding the longer term impact on the portfolio, and on the margin requirements, of any new trade… A deteriorating position in a longer dated trade could cause serious liquidity issues #derivrisk

QUESTION: How are firms improving market risk mgmt to support the new OTC derivatives model? #derivrisk

MARCUSCREERISK: We are seeing a great deal of proactive improvements w/ firms looking to… Leverage the risk experiences of the bilateral world and to tightly manage VaR driven margin requirements #derivrisk

QUESTION: What challenges do firms face in improving credit risk mgmt to support the new OTC model? #derivrisk

MARCUSCREERISK: Credit risk is less of an issue w/ central clearing. It’s replaced by potentially more dangerous liquidity risk… Credit risk remains central focus for bilateral trading, w/ firms bolstering collateral management & CVA measurement #derivrisk

QUESTION: What about credit valuation adjustment activities (CVA)? What is the driver behind improvements to #CVA activities? #derivrisk

MARCUSCREERISK: Controlling #CVA on bilateral trading enables front office to directly control its credit risk profile… It’s also interesting how different models are emerging from advisory to CVA-specific trading desks #derivrisk

QUESTION: Clearing via CCPs for some swaps introduces new liquidity strains. How will risk mgmt change to mitigate new liquidity risks? #derivrisk

MARCUSCREERISK: Since margins are determined, in part, by VaR-based models, firms can approximate & stress expected margins… This is the foundation of a working #riskculture and the best defense against liquidity risks #derivrisk

QUESTION: Is real-time risk management necessary to support trading and clearing OTC derivatives going forward? #derivrisk

MARCUSCREERISK: Real time is an interesting topic. The risk that cleared OTC trades carry is liquidity/margin based… Margin is driven by VaR models, using clean end-of-day data. As new trades enter portfolios, they need… to be reflected as they happen, but real time pricing has a far smaller impact #derivrisk

QUESTION: Enterprise-wide risk mgmt – a buzz term or necessity to support newly regulated OTC market? #derivrisk

MARCUSCREERISK: This was, is and should continue to be the focus and aim of all financial firms… Risk taking is what firms do. Understanding risk at all levels is vital 4 controlling biz & underlying risk takers within biz #derivrisk

QUESTION: What advice would you give a CRO struggling to make sense of how risk mgmt will change in the new OTC derivatives market? #derivrisk

MARCUSCREERISK: Call @SunGard! Seriously, the key is “risk” has not really changed at all. Best practice has become regulation… and to a certain extent, liquidity risk has been increased at the cost of decreasing credit risk… The need for a strong risk culture underpinning the firm has always been there, now it’s just more obvious #derivrisk

 

global head of strategy, SunGard's capital markets business

10 TRENDS IN OTC DERIVATIVES

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It is clear that regulatory changes are transforming the OTC derivatives space, from execution to settlement. There are many challenges at play here. As we head into 2012, market participants will need to manage large volumes of data in order to clear and process trades, and we will see new pressures on the cost and the more effective use of capital. In response to this industry transformation, my team and I have identified 10 key trends shaping OTC derivatives today.

I have posted the full list below. How is your firm approaching these 10 trends in OTC derivatives?

  1. Regulations such as Basel III, Dodd-Frank, EMIR and MiFID II are spurring financial services firms to improve their return on capital rather than simply focus on top line revenues.
  2. Shrinking profit margins may drive existing players to exit certain asset classes, such as structured equity, rates or credit markets.
  3. Competition will increase as greater transparency into OTC derivatives pricing and lower barriers to entry attract new players to the market.
  4. Firms will leverage new electronic trading capabilities for OTC derivatives to help reduce running costs and improve returns, particularly in their flow trading and market-making businesses.
  5. The cost of participating in OTC derivatives trading will rise, with the introduction of central counterparties altering the risk profile and margin requirements of OTC derivatives portfolios.
  6. Clearinghouses and market participants will require a consolidated view of collateral assets and margin movements to manage new pressures on margin and liquidity as well as new regulatory requirements for collateral.
  7. The need to optimize collateral and leverage every margin offset opportunity will become more pressing as the new capital charges take hold.
  8. Real-time risk analytics will become a necessity, with market best practice moving towards the incorporation of Credit Value Adjustment on a pre-deal basis.
  9. Firms will need to aggregate data from across asset classes and business silos as regulatory agencies shift the burden of reporting position limits and large trades from exchanges or clearing houses to firms.
  10. Firms will demand agility and adaptability from their technology given the uncertainty about the exact details and timelines for the new rules.

product manager, SunGard’s capital markets business

3 STEPS TO MANAGING CVA

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I recently participated in a video interview with Finextra that covered trends and challenges with regard to credit valuation adjustment. In this four-minute video, I touch upon three steps to effectively managing CVA, including deciding on an operating model, consolidating data and systems, and getting information out to decision makers.

What credit valuation adjustment questions would you like to ask? Are you capitalizing on change when it comes to CVA? Read more»

global head of strategy, SunGard's capital markets business

WHAT’S IN A NAME? REGULATORY VOCABULARY MATTERS

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Earlier this month, I attended SunGard’s London City Day, and the event’s many interesting conversations really got me thinking. The event’s sessions covered topics from OTC clearing to CVA, securities finance to collateral management, but all with an underline on regulation and what this will mean for firms everywhere.

One thing in particular that struck me is our regulatory vocabulary. If you stop and think about it, it is remarkable how powerful words actually are. The words we use to define and think about these complex issues can not only help us make sense of the regulatory changes but also complicate or confuse.

For example, Read more»

product manager, SunGard’s capital markets business

THE IMPORTANCE OF CVA (CREDIT VALUATION ADJUSTMENT) IN A POST-CRISIS WORLD (PART TWO)

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Author: Dan Travers, product manager, SunGard

There are two ways in which a bank’s counterparty credit risk management can be made more efficient through the use of CVA.  First, the allocation of credit risk appetite and second, the management of that credit risk once taken

Credit risk appetite has traditionally been allocated by a “top-down” approach, where certain business lines are allowed to enter into deals with certain counterparties up to pre-determined limits.  This determines the allocation of credit risk across the bank.  Often credit risk appetite is not allocated at all between business units, but it is used up on a first-come-first-served basis until a hard stop.

Such an approach has shortcomings in terms of flexibility.  What would be more desirable is a “warning” system, whereby deals that increase the bank’s counterparty credit risk significantly are financially penalized.  But deals incurring little incremental credit risk incur little penalty.  This method takes the detailed decision making away from a central group and distributes it down the organizational structure to traders on the floor.  They are in the best position to judge the total value of a deal, taking into account all factors including deal profitability, market risk and credit risk.  As long as traders are incentivised to take this into account, a free market approach can work to optimize credit risk usage across the bank.

Counterparty credit risk is a part of being an OTC dealer, and once that credit risk is on the books, the bank must decide how to best manage those exposures.  Clearly there are obvious strategies which could be employed, like buying credit protection.  But how much should be bought?  When should I re-hedge?  What about wrong-way risk?  Should other market rate movements be hedged?

The second aspect of CVA efficiency pertains to managing this counterparty credit risk.  CVA allows us to quantify counterparty credit risk as a single, measurable, P&L number.  Responsibility for this P&L can be given to a group focussed entirely on maximizing this number.  Usually this group is the credit portfolio management desk, and sits inside the front-office.  By making this desk a profit centre, incentives can be put in place to optimize its performance, likely managing credit risk more efficiently than when treated as a bank utility function.

The above areas, enabled by CVA, have the ability to markedly improve the efficiency of a bank’s credit risk management.

product manager, SunGard’s capital markets business

THE IMPORTANCE OF CVA IN A POST-CRISIS WORLD (PART ONE)

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Author: Dan Travers, product manager, SunGard

Credit Valuation Adjustment (CVA) has become increasingly important in the derivatives trading world since the crisis as a way to price in the cost of counterparty risk. As such, there are an ever increasing number of banks adopting CVA as a core part of their process for managing counterparty credit risk.

This has traditionally been conducted by allowing traders to trade freely up to a hard stop credit limit.  However, this approach allows no visibility into how the limit is utilized, or which deals may be causing more counterparty risk than they are actually making in P&L.  By enriching the management of counterparty risk with a CVA charge for counterparty deals, trades are charged (or rewarded) for the counterparty risk they incur.  The key being that the CVA for each deal is related to the amount of counterparty risk for that specific deal only. In a portfolio of deals, it should be possible for management to see a dollar amount for the total counterparty risk the bank is taking on, as well as for each desk, book or deal.  This transparency can drive better management assessment on which areas of the bank are profitable.

Offering this deal-level CVA information to traders allows visibility into how the credit worthiness of the counterparty or the direction of positions with that counterparty may be affecting the profitability of the deal.  This information can positively affect the decision making of traders if available pre-deal.