Solutions: Post-Trade


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Author: Rich Hulit, executive vice president, SunGard’s brokerage & clearance business

Beginning Jan. 1, 2011, cost basis reporting will be mandatory for all brokers executing transactions that involve publicly traded securities. This may prove to be easier said than done.

You must address technology and data issues now if you are to ensure future compliance with the regulations. But cost basis is not just about tax systems or even compliance. If it is approached the right way, this challenge may actually help increase efficiency, strengthen customer service and foster transparency.

That’s why our next Professional Services Perspectives Webinar will delve into the cost basis challenge – and how you can turn it into an advantage. My colleague David Elichman, who runs our Professional Services tax practice area, will lead the discussion.

  • Are you up to date on the regulations?
  • How does workflow play a part?
  • What are the technology challenges?
  • How are you approaching cost basis system integration?
  • What are your training and resourcing strategies?

Be part of the discussion – join the latest installment of our Professional Services Perspectives Webinar series and receive a free copy of our new white paper: “Cost Basis – Turning compliance into an opportunity to improve your business.”

WEBINAR: Turning cost basis into an advantage
DATE: Thursday, June 10, 2010
TIME: 1:00 p.m. EST

I look forward to you joining us on Thursday, June 10 for this important discussion of how you can turn cost basis into an advantage. Register today to make sure you are part of the conversation.


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A joint venture between KAS BANK and SunGard is delivering superior control to trading firms.

The European securities market is “on fire” as trading venues and market participants continue to reinvent themselves in the wake of the introduction of the Markets in Financial Instruments Directive (MiFID), says Laurens Vis, UK Managing Director, KAS BANK.

“MiFID had a profound effect on organisations in all markets, enabling participants to trade freely across Europe,” says Vis. “There is no longer a single platform on which ISINs are traded, which means our clients must provide trading capabilities throughout Europe, in order to meet the needs of their own clients as they increasingly trade across borders.”

KAS BANK is a specialist European bank offering a wide range of securities and investor services. Its clients include institutional investors such as pension funds, insurance companies and asset managers, as well as financial institutions including banks and brokers. Established more than 200 years ago, KAS BANK has always focused on securities services and acts as a general clearing member on most of Europe’s main exchanges and MTFs as well as on exchanges further afield including NYSE Euronext and Hong Kong. The bank is also a member of the major European central security depositaries (CSDs), such as Crest, Euroclear and Clearstream.

Post-trade complexity

Vis says the requirement to trade on multiple markets presents challenges not only on the trading side, but also on the post-trading side of the markets. Just as the number of trading venues has proliferated since the introduction of MiFID, so too has the number of clearing venues as many central counterparties (CCPs) have been launched to service the new MTFs.

Before MiFID, a stock would trade on a single stock exchange and be cleared on a single CCP and settled at a single CSD. In the MiFID world, trading firms must establish relationships with many more exchanges and with additional post-trade infrastructures, all at increased cost and complexity. Firms will have to consider how they will collect and process trade information once deals have been transacted in this more complex environment.

And as MiFID is reviewed, with details of a ‘MiFID II’ expected to be released by the European Commision this year, financial institutions could be in for a shock, says Vis. “In MiFID I, best execution was based on the venues on which a broker was prepared to trade. In MiFID II this may not be possible – brokers may be forced to seek the best price across all venues on which a stock is available for trading. This will be a significant challenge because sell-side firms will have to connect to a growing number of exchanges and MTFs and the corresponding CCPs that clear for them.”

In reality, some firms will be unable to afford or maintain the necessary post-trade infrastructure required. This increasingly complex and fragmented environment has led many broking firms to seek providers that can help them with connectivity at the front end, as well as those that can provide post-trade clearing and settlement services.

An integrated solution

“More and more brokers have been coming to us, seeking fully integrated services not only for the clearing and settlement elements, but also for other back-office components, such as static data maintenance, settlement instructions, cash and stock reconciliation, contract notes and trade accounting,” says Peter Rouwen, Director, Sales and Business Development at KAS BANK. “These brokers simply do not have the economies of scale to establish multiple relationships with a range of service and systems providers, and are instead looking for an integrated solution with a variable cost structure.”

In order to provide an all-in service proposition, KAS BANK partnered with SunGard to offer a new service under its Broker Services division. Underpinning the service is SunGard’s Stream RIMS Middle and Back Office, a comprehensive, real-time securities post-execution processing solution. Stream RIMS is highly scalable and its comprehensive use of automation enables global capital markets organisations to achieve maximum STP.

The partnership with SunGard means KAS BANK can provide a multitude of clients with a single, global platform for clearing, settlement and back-office services. The bank’s clients do not have to run their own back offices and can therefore focus on core trading activities and adding value for their clients, says Rouwen.

“We had clients who were already using SunGard’s products and it was natural that SunGard became our partner,” he says.

“SunGard has experience in providing back office services and has a similar ‘pure player’ approach to KAS BANK. We believe that the combination of a securities services provider and an IT provider can achieve strong results.”

The service consolidates previously separate functions on to a single, robust platform that is linked directly to KAS BANK’s cross-border clearing and settlement platform. Clients can deal exclusively with KAS BANK for all elements in the trading chain – from front-office deal capture through to cash and stock position reconciliation. Other features built on the Stream RIMS-based service include full trade accounting, provision of contract notes, posting to the general ledger and comprehensive regulatory reporting from a single source.

“With the introduction of Stream RIMS we now have a full suite of back-office services combined with post-trade DMA services,” says Vis. “Our offering delivers much greater control and transparency for the benefit of our customers.”

The service is aimed at securities houses that do not conduct enough transactions to justify the significant investment required to establish back-office infrastructures for the fragmented MiFID environment.


MiFID unleashed significant price competition at the trading level, which exposed the high costs of the post-trade world. But in a more competitive environment, downward pressure on pricing is being felt along the value chain and for that reason, says Vis, KAS BANK’s clients have had to reinvent themselves and play to their core strengths. By offering a completely seamless post-trade service, KAS BANK will help its clients to gain greater control over their costs in order to focus on revenue generating front-office activities.

“The joint venture with SunGard will enable our clients to offload fixed costs in their middle and back offices and move to a more variable cost base,” says Vis.

Clients will be able to capitalise on the expertise of both KAS BANK and SunGard, something they may not have been able to do alone. “Firms who typically would have had to invest in separate back-office systems and links to securities services providers, can now use one party – KAS BANK – to take care of their core back-office functionality,” says Rouwen. “Our partnership with SunGard has changed the way we deal with our clients. We have bridged the gap between the back offices of our clients and our clearing and settlement services, offering a best of breed service. It has been a big step forward.”

As the European trading, clearing and settlement world continues to fragment and increase in complexity, says Vis, the combination of KAS BANK and SunGard will deliver superior control to trading firms, which is a “good thing for the market”.


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In Hong Kong the back-office support of derivatives activity has become more complex because volumes are rising and products traded are becoming more elaborate. The capabilities of back-office organisations are being stretched and the current level of technology is not resilient enough. More ASP (application service provider) service is needed.

Key points of the session:

  • The push to clear OTC derivatives is putting stresses on systems and procedures. 
  • Differing symbology among exchanges is creating problems for cleared trades. 
  • Asia has an opportunity to grab market share in the midst of regulatory uncertainty. 
  • But investment in compliance personnel and technology will be required.


  • Michael Stanhope [MOD] – Moderator – CEO, Hubbis
  • Albert Helmig [AH] – President, Hong Kong Mercantile Exchange
  • James Drumm [JD] – Executive Director, Omgeo Pte Ltd, Asia
  • John Warren [JW] – Director, Post Trade Group, SunGard
  • Robb Arnulphy [RA] – Clearing and Settlement, Noble Group, Hong Kong


JW – Post-trade clearing and settlement of derivatives, over the last two years, has grown in complexity. The push for OTC products incorporation into the cleared environment has created challenges for providers, custodians, and the exchanges themselves.

AH – It is popular in the current environment, after the crisis in debt instruments, to try to clear everything. That sounds easy from a regulatory, systemic risk, scenario but there are enormous unintended consequences. It creates an enormous strain – timing issues, capacity issues, and huge cost issues. OTC derivative clearing requires enormous bandwidth for small transactions and small clearing revenue and I’m not sure the cost/benefit ratio is sound for the exchanges.

RA – We’ve seen a lot of movement in the commodity world to clear OTC swaps; we’re finding that automating these poses some challenges – certainly when you have multiple exchanges offering clearing of the same product. Selecting which exchange to clear that product on, and how you reflect that in the systems adds a certain complexity that you don’t find in the futures and options world.

Has the regulatory pendulum now swung too far to one side?

AH – Regulation is either a little too loose or way too tight. The current environment has been seen before: ’81, after the Hunt brothers, and ’87 after Drexel it looked like this – after both we saw great regulatory change. Also, after Enron in 2001/2 you saw Sarbanes-Oxley and you’re seeing a different version of that now. The situation is one of regulatory uncertainty: the lack of certainty as to how certain instruments will be margined, how they’ll be settled, what has to be cleared.

JW –The expansion of instruments changes the face of the market but the business model itself will have to change to address the issues mentioned or else we’ll see a huge drop out of participants that will not be able to keep up with the systemic requirements of this new evolving market.

RA– In the energy markets swaps can be cleared on multiple exchanges. And there can be many instrument codes among the exchanges for effectively the same instrument. Additionally, of course, the dealer will have traded in a particular quantity whereas the exchanges report cleared swaps in lots. The reconciliation problems are endless. Mapping quantity and coding is quite difficult into a system that’s geared to reconciling futures.

JW – It is not an easy solution, getting a system designed for futures and options to aggregate trades from the swaps. And, of course the symbology is an issue that everybody is struggling with at the moment. The definitions of the back-office and post-trade are being fundamentally changed by the move to clear OTC instruments.

AH – We’re talking about encoding. I think that’s an exchange job. I believe there is an exchange solution to coding – I believe that an exchange is a service bureau, there’s a service that exchanges can perform: aggregate code and folding it into execution.

As well as taking the role of a service bureau how do you see exchanges driving into the non-exchange markets?

AH – The opportunity in capital markets for financial institutions is vast. Technology will give Asia the opportunity to exploit the economic growth model that was not possible 15 years ago. There is now enough embedded liquidity in commodities and other derivative instruments in Asia to trade our own liquidity pools in our own time zone. But technology is the must-have component and whether you are a participant, a broker, or a service provider you have to be at the leading edge of technology.

JD – There is another advantage that Asia has, it doesn’t have the heavy infrastructure, no legacy systems, and it has a clean start and can learn from the mistakes of others, EMEA and the Americas.

What are the specific problems that need to be faced?

RA – As we move OTC swaps into the clearing mechanism they fall under the oversight of the regulators – the CFTC for example – and where previously compliance systems were only looking at specific futures they now have to take into account a whole raft of swaps that have been cleared in the US. That adds another layer of complexity for our compliance people: from a back-office perspective we have to make sure that not only are we monitoring the futures levels but also the corresponding OTC swaps which fall into the same position limits.

AH – The US regulatory model of position limits for commodities will force business out of the US. Exactly as what happened with precious metals in 1981-2, after the Hunt brothers, regulation changed overnight, the base metals market went to London and never came back. That could happen now in the energy market. The paperwork and regulatory burden that could occur in the US in OTC energy swaps is going to huge. If Asia provides a solution the market will vote with its feet. Another thing: when OTC clearing is talked about I don’t think it’s understood what it means to be compliant. There will be a human resource problem regarding compliance officers with experience: the industry has consolidated so much there is now a reduced talent pool.

deputy head of strategy, SunGard’s capital markets business


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Author: Tony Scianna, executive vice president, SunGard’s brokerage & clearance business

On May 3, we launched Cliq, a Web-based service that provides standardized electronic communication and collaboration for all parties involved in global, post-trade processing of listed derivatives.

You may have seen some buzz about this new service over the past few weeks, but perhaps you’d still like to learn more about the ins and outs of Cliq, what it can do, and why it matters so much right now.

With this in mind, I invite you to join me for a free Webinar on Tuesday, May 25 at 10:00 am ET/ 3:00 pm BST to delve into the issues that Cliq is responding to and to view a live demo of the service. Since the launch earlier this month, my colleagues and I have been eager to tell you all about Cliq, but now I’d like the opportunity to show you Cliq.

During the Webinar, you will also hear expert insights from esteemed industry analyst Stephen Bruel, research director for TowerGroup’s Securities & Investments practice, regarding the critical issues facing derivatives processing.

Some of the topics Stephen and I will address include:

  • Alleviating the pain points around communication between the buy and sell sides
  • Understanding how the proposed regulatory changes could affect your business
  • Streamlining the listed derivatives post-trade process
  • Increasing transparency and efficiency
  • Decreasing counterparty risk and exposure


WEBINAR: What do the challenges facing the listed derivatives industry mean for your business?
DATE: May 25, 2010
TIME: 10:00 am ET/ 3:00 pm BST

I look forward to you joining us on Tuesday, May 25 for this timely discussion about critical industry issues and how SunGard’s Cliq fits into the mix.

If you would like someone from SunGard to contact you about Cliq, please click here.

deputy head of strategy, SunGard’s capital markets business


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Author: Tony Scianna, executive vice president, SunGard’s brokerage & clearance business

I recently participated in an interview with Jessica Titlebaum, editor/producer at John J. Lothian & Company and freelance journalist. Jessica asked me some good questions about myself and my work at SunGard, in particular about Cliq.

I’ve re-posted the interview below, which you can find originally published on MarketsWiki. Leave a comment if you learn something new about me, or if you have your own questions about Cliq, my role in SunGard’s brokerage & clearance business, or my favorite music.

Five Minutes with Anthony Scianna from SunGard

SunGard recently released Cliq, a Web-based service that standardizes electronic communication between the buy-side and sell-side institutional firms that are involved in listed derivatives post-trade activity. MarketsWiki’s Jessica Titlebaum sat down with Anthony Scianna, SunGard’s executive vice president of product management and marketing, to discuss Cliq, how Scianna got in the industry and how he spends his time outside of work.

Q: How did you get into this business?

A: In college, I was a chemical engineer and I was good at math. Wall Street was wide open and my first job was a trainee margin clerk at Hornblower & Weeks, Hemphill, Noyes. Vincent Fay ran all of margining while I worked there. He wrote the credit division handbook and it was interesting to train under him. I spent a year there and then moved to Spears, Leads and Kellogg.

I will never forget my interview (at Spears, Leads and Kellogg). It went extremely well. He was asking me very direct questions about margining and after I answered them all correctly, he asked me when I could start. I began as a margin clerk and by the time I left, nine years later, I was running their retail margin department.

I came to SunGard in April 2001 as part of a move to hire industry knowledgeable people. I was a business guy working in global business development and part of the reason I was hired was because I was a customer of SunGard. In between Spears and SunGard, I was at Refco (Securities) helping develop the globalization of the Phase3 work. (Stream Phase3 is a securities processing system.) When I was hired at SunGard, they wanted me to continue to develop Phase3.

Q: As [executive] vice president of product management and marketing, what are some of your responsibilities? What is your daily routine?

A: As product manager, I try to make sure we are setting the right strategic direction for our solutions. Given the current market conditions, we try to utilize technology to help our customers prepare for the changing business and regulatory environment.

We are part of the brokerage and clearance business within SunGard Financial Systems, focused on business processes related to the management of post-trade services for all types of financial institutions, including broker dealers, FCMs, banks and investment firms, etc.

In terms of a daily routine, I travel a lot. I go to the gym more when I travel than when I am at home…but I am always talking with customers.

I look at our products and after talking to customers, determine what functionalities we should be adding. Should we be investing more money into our products or should we spend our money on other functionalities? I have a team that manages each product and we look at all the moving pieces. We look at what we have, what we are trying to do and develop and then, roll it up all into a single format.

For example, we have been working on Cliq for the last nine months. After the acquisition of GL Trade, customers were asking us what happens next since we had a lot of moving parts. We looked at our customer’s pain points and asked how we could help the industry. We came up with Cliq, a Web-based service that standardizes the communication between the buy and sell-side financial institutions. This way everyone can see the transparency of the transaction from the moment a trade is made… By offering Cliq, we are offering a solution to efficiency, transparency and network challenges that the industry faces on a daily basis.

Q: If you weren’t in this position, what would you be doing?

A: When I was in high school and college, I never thought I would have a job that would be in an office all day. I grew up in the 60’s and 70’s. I thought I would be changing the world, a park ranger, spending time outdoors…

Q: What is the hardest part of your job?

A: Finding the time to do everything and knowing what time zone I am in when I am doing it.

Also, it is hard to know how much time to be spending on what. Maybe I will decide to spend more time on the OTC space and not so much the equity space. That would affect products in different ways. It is not that I am turning my back on one product or another. It is more about looking ahead and seeing what we should focus on for 2011. Also, it is important to be there for our customers when they need us. Going out and talking to customers, talking on panels, being prepared for what comes next.

It is hard to prepare for what comes next with all the regulation and business proxies in flux. As a vendor, it is hard to see where we should spend our time.

Q: Did you have any mentors throughout your career?

A: I learned a lot from the margin clerks at Hornblower. A guy working at Spears, Leads and Kellogg, Joseph Roeffler, mentored me and taught me more about the business and more than I have learned anywhere else. He taught me why we did what we did and why the business was what it was. Debts, interests, credits…you come in as a trainee not really understanding how Wall Street works and learning all of that was very important to me. I still think of Joseph today.

Q: What are some of your hobbies outside of work?

A: I am a big music fan. I like jazz, blues, rock and roll. I also love classical music.

Q: What was the last concert you went to?

A: Eric Clapton and Jeff Beck. Beck took over Eric Clapton’s role in the Yardbirds. All part of the original British invasion.


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Author: Gerry Murphy, former president, SunGard’s brokerage & clearance business

We at SunGard’s brokerage and clearance business are extremely proud to announce the launch of Cliq™, a Web-based service that we believe will revolutionize the derivatives industry. It will help increase transparency and efficiency and provide standardized electronic communication for all parties involved in the post-trade derivatives lifecycle.

You may have heard us encouraging you to “join the Cliq” as we worked to develop this innovative service over the past few months. Many of you have asked important questions and provided valuable and constructive feedback throughout this process, which has helped to shape our vision for Cliq.

In fact, our product development process was centered on speaking to numerous buy- and sell-side firms, whose comments were directly incorporated into Cliq’s product development plan. We recognized the key challenges you shared with us, including a lack of transparency; cumbersome manual processes; timeliness of allocations; managing counterparty and operational risk and streamlining communication between the buy- and sell-side, and we strived to create a service to help solve these industry issues. What I’m saying is: this is your Cliq.

This process reflects our commitment across all of our products to our customers. Your perspectives, interests and concerns help us make our services more effective and more relevant – and ultimately, help us do more for you.

What will Cliq mean for derivatives? Click on the brief video below and I’ll tell you:

Questions? Comments? We want to hear them. Please join the conversation and add your voice to this exciting new SaaS-based social network.  Leave a comment below, connect with us on Twitter by using the hashtag #theCliq, or contact us directly to learn more.

Welcome to the Cliq.


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Author: Scott Foster, executive vice president, SunGard’s brokerage & clearance business

Most people have heard of iTunes. From Apple’s “What is iTunes?” Web page:

iTunes is a free application for your Mac or PC. It organizes and plays your digital music and video on your computer. It syncs all your media with your iPod, iPhone, and Apple TV. And it’s a store on your computer, iPod touch, iPhone, and Apple TV that has everything you need to be entertained. Anywhere. Anytime.

Now, it may seem like a jump, but do your middle- and back-office technologies sound like this?  If the answer is no, you should be thinking of ways to change that.

A recent report by PricewaterhouseCoopers claims that Software-as-a-Service (SaaS) and similar applications will support growth in the financial industry in 2010.  The study revealed that technology vendors working within the financial sector can expect to benefit from greater levels of compliance, additional regulation and increased demand for risk management solutions.  The report also forecasts that organizations will expand their IT systems during the year as part as they seek to improve efficiency across their businesses.

We’re just starting off a new decade, and it’s time to think outside the box.  Efficiency and speed are a must, and so is adaptability.  In my opinion, technology vendors should be thinking that wherever it’s applicable, their customers will want and ultimately demand products and services to be more like iTunes and less like inflexible, decentralized legacy systems that no longer meet requirements.

Are you considering new technology models to create greater efficiency?  Do you believe that SaaS will be a driver in how the industry shifts this year?  Are there other successful models besides iTunes that you’d draw from?

deputy head of strategy, SunGard’s capital markets business


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Author: Tony Scianna, executive vice president, SunGard’s brokerage & clearance business

Last week, I spoke on a panel about operational efficiency at FIA Clearing 2010 – A Derivatives Forum in New York. I was joined by panel chair Brian Peldunas; Philippe Buhannic, chairman & CEO, TradingScreen; Edward Licciardo, vice president, Deutsche Bank Securities; and Lenny Musso, director, Futures Operations, Citigroup Global Markets, who all helped make the session dynamic and smart. I was glad to participate in this timely discussion.

The starting point for the conversation was this: The front office predicts that volume will double in the next two years. What would need to be fixed/standardized/automated to make handling additional volume effortless? What processes need to be improved or changed?

The five of us agreed on several ideas, including:

As I said on the panel, workflow and rules are key to better managing exceptions. The industry is in flux, and we need to accommodate the new regulatory climate. Transparency is important here. Real-time and on-demand data is important. Developing sound standards is important.

During the session, one of my fellow panelists, Lenny Musso, said something that really rings true when we are looking at how to tackle the challenges of operational efficiency: “The more we do at the root, the better the tree grows.”

So, what are you doing to make sure the tree grows strong? Are you re-examining your workflow and business rules? Would you support standardized communications? Could an industry utility contribute value?


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Author: Rich Hulit, executive vice president, SunGard’s brokerage & clearance business

If you submit a Web search for “are you paying too much?” you will find more than 41 million results, which would suggest that people and businesses may be overpaying for a wide variety of things. From life insurance to Google AdWords, property taxes to text messages, the search results run the gamut.

Now think about this in the context of your business. For Futures Commission Merchants in particular, do you know if, where, and how much you are overpaying in brokerage and exchange fees?

With the increasing complexity of fee schedules, regular modifications of fee rates and levels, and reduced time windows for claiming rebates, managing exchange and brokerage claims and fees presents a challenge to many FCMs. This is especially true for firms that split the creation and maintenance of exchange and clearing accounts among different departments and offices. What’s more, many FCMs do not have adequate internal control processes and procedures to help prevent miscalculations or miscommunication regarding fee schedules, rates and levels.

If the proper procedures don’t exist, then an error in the account set-up may not be caught, or an update in a fee rate may not be reflected in an existing account. As a result, your firm may pay unnecessary fees – and you may not realize it until it’s too late to claim a rebate and recoup your losses. It is this “oh no” or “we’re too late” moment you should strive to avoid.

To avoid paying too much, begin by asking yourself some key questions.

  • Do you know whether you are up-to-date with the latest fee schedules and rates?
  • Do you have a fee review procedure?
  • Do you manage fees on an enterprise-wide basis?
  • Do you always send in your rebate requests before the time window closes?

If you have answered “no” to any of these questions, what are you doing to solve these challenges?

deputy head of strategy, SunGard’s capital markets business


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Author: Tony Scianna, executive vice president, SunGard’s brokerage & clearance business

On Monday, the Senate Banking Committee quickly approved Senator Christopher Dodd’s sweeping financial reform bill, moving it forward to the Senate floor with a 13-10 vote.

The bill, which calls for the biggest overhaul of financial regulation since the Great Depression, met unanimous opposition from the 10 Republican Banking Committee members, yet news reports convey a willingness to come to a bipartisan agreement from both sides.

“We’re not going to the floor polarized. We’re going to the floor right now in a spirit of trying to work a consensus bill, a meaningful substantive bill,” said Senator Richard Shelby of Alabama, the top Republican on the committee.

While Shelby may be looking for a more substantive bill, Dodd’s is certainly substantial at 1,366 pages.  For those of us who may not be inclined to read through the bill in its entirety, there is an 11-page summary that offers insight into which proposals have legislators at odds.

The summary outlines eight main “highlights” of the bill. I would like to comment on three of these today.

  • Ending too big to fail: No matter your stance on Dodd’s proposal, I believe that looking at effective risk management is one of the most important lessons we’ve learned from the financial crisis.  The larger and more complex an organization becomes, the more difficult it is to manage the risk, and too big to fail can translate to “too big to manage risk.”  I will be paying close attention to how this portion of the bill evolves.  Have you taken a stance on this?
  • Creating transparency and accountability for derivatives: Across SunGard Financial Systems, we firmly believe that promoting and creating transparency is a high priority today, as our industry rebuilds from the crisis.  Mandating transparency poses new challenges to firms, however, as they will be required to report in new ways (see: real-time) and think differently about data.  What are your thoughts when it comes to bringing transparency and accountability to the derivatives market?
  • Establishing the Financial Stability Oversight Council: Addressing systemic risk is an important issue, and Dodd has proposed a too big to fail prevention strategy in the form of a council that will wield considerable power when it comes to responding to emerging risks throughout the financial system.  What’s your take on his approach to the systemic risk issue?

How do you feel about Dodd’s bill? Do you think we will see a completely new bill before all is said and done in the Senate?  What do you hope to see amended? This is an extremely timely and important conversation, so please make your voice heard and leave your comments below.