As I’ve written repeatedly in the past years, the mandated move to central clearing will increase substantially demands for liquidity to fund variation margin payments, especially during periods of high volatility and high market stress. By definition, variation margin payments total zero–every dollar paid is received by somebody else–thus they don’t affect aggregate liquidity, but economic frictions preclude the development of a perfect pooling mechanism. As a result, market participants will need to pre-plan how to fund their margin payments.
Not surprisingly, banks are crafting funding mechanisms for their buy-side clients (“end users”). FTAlphaville quotes from a Risk story by Matt Cameron which describes some of the solutions dealer banks are peddling to their clients [emphasis provided by FTA]:
Clearing members say they have a solution. Most buy-side firms will have to access clearing services through these members – typically the large banks – due to strict membership criteria set by the CCPs. These clearing members are responsible for collecting margin from their clients and posting it to the clearing house, charging a fee for the privilege. As an additional service, however, a number of clearing members are also planning to offer collateral transformation facilities – essentially, enabling the client to post non-eligible instruments with the dealer, which will be switched into cash via the repo market and then posted with the CCP. Given the frequency of margin calls – there could be several per day in volatile markets – some also plan to extend credit lines, where they would meet intra-day margin calls, with the customer settling up in one go at the end of the day or start of the next.
It sounds a perfect solution, but the numbers involved are huge, raising the question of whether there is enough capacity and appetite among dealers to offer this service to the entire universe of end-users. According to research published by Morgan Stanley and Oliver Wyman on February 16, as much as 40–50% of the total annual traded volume of OTC contracts could be cleared by 2012/13 … creating an additional collateral requirement of between $2 trillion and $2.5 trillion … Most dealers say they would only have capacity to extend credit lines and provide collateral transformation services on a fraction of that.
Diving into the Risk article reveals more details–troubling ones. It notes that unlike dealers, whose books are typically close to matched, end users are likely to have one-way positions with commensurately greater exposure to margin calls. Which just provides just another reminder that clearing would not have been a panacea for AIG, which had huge directional positions, and was brought down by the need to fund margin calls–and would have been brought down by the need to fund margin calls in a cleared environment. Indeed, the expansion of clearing threatens to increase the population of potential AIGs.
The article also emphasizes that the contingent funding obligations on banks could be huge, and are likely to be huge precisely when funding market conditions are stressed. The various solutions proposed by the banks rely very heavily on repo markets, and in particular repo markets for lower quality, less-liquid instruments. In essence, banks will repo out lower quality assets and use the cash to fund margin calls. But repo markets for lower quality assets are the ones that are the most problematic during periods of market stress. Note that haircuts on everything but high quality sovereign paper increased dramatically when the financial crisis took hold. Companies that depended on the repo market for funding found this source cut off. The shadow banking system was built on repo, and runs on the repo market are what cratered that system. The death knell for Lehman was the decision by JP Morgan (JPM) and BNY Mellon (BK) –the clearing banks–to refuse to take low quality assets to collateralize tri-party repo.
So just why exactly is it a good idea to create a system that increases reliance on a fragile funding source? This creates exactly the kind of feedback mechanism that generates crises. Adverse shocks lead to price changes that result in big margin calls. These shocks also impair liquidity of the funding markets that participants rely on to obtain the cash they need to pay the margin calls. That’s how things spiral from bad to worse to worser yet.
And there are knock-on effects in the asset markets:
“We reserve the right not to fund clients on a unilateral basis. If we fall short and can’t fund the variation margin call, we will demand the cash from the client. If the client doesn’t have the cash, it will have to liquidate the assets it does have or we will be forced to close them out . . .” says one dealer.
Great. This is a perfect example of how individually rational behavior by banks can exacerbate market stress. The collateral liquidations and derivatives liquidations will both cause prices to move–generating more margin calls and reducing the value of the collateral available to secure funding of those calls. Positive feedback again. And since by design a lot of the collateral that is liquidated will be lower quality stuff traded in illiquid markets the price impacts will be large–and this will make it more difficult for others to use these assets to fund their positions, thereby creating a serious negative externality.
These problems are endemic in financial markets, including uncleared OTC derivatives markets. But clearing makes the mechanism more rigid and time sensitive. It increases the tightness of the coupling in the financial markets, and that makes them more vulnerable to chaotic breakdown and cascading failure.
Cameron’s article discusses other alternatives. One is that CCPs accept lower-quality collateral. But this merely passes the hot potato. CCPs are simply conduits that transfer margin monies from the losers to the winners. The winners won’t necessarily accept the collateral that the losers provide, or will place a lower value on it. Much of the collateral will be hard to value, during periods of market stress particularly. And if there is a delivery option on collateral, how do you even price collateralized derivatives trades?: the price of the collateralized trade depends on the value of the collateral, which adds an additional risk to the trade.
So if the CCP can’t just pass collateral along from loser to winner because the collateral isn’t fungible like cash, then the CCP has to fund the cash payments to the winners collateralized by the non-cash instruments posted by the losers. That puts the CCP in the position of a bank, and raises the question: just who is going to lend against that collateral?
Moreover, this undermines one of the main potential benefits of clearing: fungibility of trades across counterparties. Different counterparties may have different funding capabilities. Some may have access to high quality collateral, some may rely more heavily on low quality collateral. In an OTC market, those counterparties would trade derivatives at different prices reflecting their differing risks and the quality of the collateral that backs the trade. But in a cleared market in which all trades are fungible–with offsetting positions netted out, meaning that they are treated as perfect substitutes–this pricing mechanism doesn’t work. Economically important differences are not priced, which distorts incentives. This will tend to work to the advantage of low-quality counterparties and to the disadvantage of high-quality ones.
In other words, if the collateral really isn’t fungible–like cash is–how can the trades backed by this collateral be fungible?
One of the risks of clearing is that it treats the unequal equally. Widening the range of collateral that CCPs must accept only exacerbates that risk.
It also puts CCPs in a delicate position–exactly the position that JP Morgan and BNY Mellon found themselves with Lehman. A firm is in trouble, and is offering to post dodgy paper as collateral. If the CCP refuses, the firm is likely to default. That could jeopardize the CCP. Even if the CCP can absorb the default, it is at risk of being accused by the defaulter’s bankruptcy administrator of violating the bankruptcy laws–which is the situation Morgan and BNY found themselves in post-Lehman.
So maybe the CCP will decide to play European Central Bank for a day–or a week, or a month–and pretend that junk collateral is as good as gold or cash, thereby gambling on the resurrection of the troubled firm. That just increases the risk of the financial system–and may subject the CCP to a run by firms that are worried about the quality of the collateral it has taken on.
Contrary to the airy promises of their evangelists, clearing mandates therefore do not fundamentally alter the economic problem that must be addressed: how to fund variation margins in periods of market stress. Indeed, in my view mandates actually exacerbate the problem because they increase the rigidity and time-sensitivity of the system, require the clearing of more instruments less suitable to accurate valuation in short time frames, and reduce the ability to price risk in a discriminating way (because unequal entities and instruments are treated as interchangeable). What’s more, the mandates tie up vast amounts of high quality collateral in initial margin payments, forcing greater reliance on lower-quality collateral to keep the system running. And yet more–depending on the scope of the mandates, buy-side entities that pose no real default risks (e.g., pension funds) but do pose potentially serious funding and liquidity risks will be forced to clear. Since funding and liquidity risks are the Achilles heel of the clearing system, it is absolutely insane to increase funding needs.
No matter how many times you turn over this problem, I think you will conclude that clearing mandates will substantially increase the necessity of central banks to provide liquidity, and lend against dodgy collateral. Whether the central banks provide cash to CCPs collateralized by non-cash collateral paid by customers, or provide cash to dealer banks collateralized by low-quality collateral, or provide the cash to end-users similarly backed by low-quality collateral (although this alternative is least likely), to fund the vast margin payments during periods of stress they will be lending a lot to somebody.
Savor the irony. The rallying cry for clearing mandates was “No More Bailouts,” “bailouts” in this instance meaning central bank loans to troubled financial institutions, intended in part to prevent a meltdown in derivatives markets. But clearing mandates will only increase the demands on central banks to provide extraordinary funding to keep the derivatives markets going. The parable of the Indian village that brought in cats to rid itself of mice, dogs to rid itself of the cats, elephants to rid itself of the dogs, and then in the end mice to rid itself of the rampaging elephants is apt indeed.
In the Risk article, Matt Cameron notes that seven out of eight regulators he contacted about the story refused comment: “Most said not enough analysis had been conducted.” Read that again: “Not enough analysis had been conducted.” Pardon my French, but Jesus H. Christ, wouldn’t you want to do that analysis before embarking on this titanic reengineering of the largest, most complex financial markets the world has ever seen? ”Not enough analysis had been conducted.” Really? Really?
But I know it’s true–and you do too. And that’s the tragedy of it all.
I sometimes try to think of a rational reason for undertaking this huge experiment on a live patient. In my more cynical moments–pretty much all my moments are cynical, but some more than others–I wonder if this is just a part of the movement to “financial repression”, defined by Reinhart and Rogoff as follows:
Banks are vehicles that allow governments to squeeze more indirect tax revenue from citizens by monopolizing the entire savings and payment system. Governments force local residents to save in banks by giving them few, if any, other options.
They then stuff debt into the banks via reserve requirements and other devices. This allows the government to finance a part of its debt at a very low interest rate; financial repression thus constitutes a form of taxation. Governments frequently can and do make the financial repression tax even larger by maintaining interest rate caps while creating inflation.
Clearing mandates, mandates that non-cleared transactions be collateralized, limits on rehypothecation, segregation rules and on and are “other devices” that increase the demand for government paper. And just coincidentally, I’m sure, we’re living in an age where governments are desperate for buyers.
Maybe the dots don’t connect. But maybe they do. But I guess financial repression is better than financial insanity, which is the only other explanation that comes to mind.
Cold comfort, that.