Tuesday, December 15, 2009

The Lynch Amendment: Bizarre and Confused

The Lynch amendment has to be one of the most bizarre pieces of legislation relating to derivatives I've ever seen—and that's saying something. Really, the amendment is just illogical. Introduced by Rep. Stephen Lynch, the amendment prohibits swap dealers and "major swap participants" from owning more than 20%, collectively, of a derivatives clearinghouse. Here's how Rep. Lynch justified his amendment on the House floor:

[T]he problem is—and in my view, this is a huge problem with the bill—the bill would allow these same big banks to purchase the clearinghouses that are being created to police the big banks in their derivatives trading. The big banks would be allowed to own and control the clearinghouses and to set the rules for how their own derivatives deals are handled. My amendment would prevent those big banks and major swap participants, like AIG, from taking over the police station—these new clearinghouses.
This makes absolutely no sense. Rep. Lynch appears to be deeply confused about both clearinghouses and the derivatives market. Unfortunately, the Lynch amendment has been cheered on by the blogosphere, which now reliably swoons at any mention of hurting "Wall Street," seemingly without regard for the merits of the proposal. Honestly, what do supporters of the Lynch amendment think clearinghouses are? The purpose of a clearinghouse is risk mutualization. If one clearing member defaults on a cleared contract, the other members—via the clearinghouse—will pick up the tab. That's why the clearinghouse, as the central counterparty (CCP), interposes itself between counterparties to contracts cleared through the clearinghouse, serving as the buyer to every seller and the seller to every buyer. The whole purpose of this set-up is to put all the clearing members on the hook for one clearing member's default. (If after applying a defaulting member's margin account, the money the other clearing members have contributed to the clearinghouse's guaranty fund still isn't sufficient to cover the losses from a member's default, the clearinghouse can generally force the other clearing members to make one-time contributions to cover the remaining losses.) Why on earth would we want to discourage the dealer banks—who, for better or worse, are the only ones capable of being market-makers in OTC derivatives—from mutualizing losses? That's what the Lynch amendment would do. The clearing members are the ones who are ultimately on the hook for a default in a clearinghouse model, so of course they're going to want to have a say in the kinds of contracts the clearinghouse accepts, and in the clearinghouse's risk management practices. A dealer is unlikely to trade through a clearinghouse if it's prohibited by law from having a say in the kinds of contracts that it—as a clearing member—is being put on the hook for. Clearing members should have a say in those kinds of matters—it's exactly the kind of aligning of economic interests that we're looking for! The Lynch amendment would effectively prevent a given clearinghouse from having more than 2 or 3 dealers as clearing members. This would make the clearinghouse much less effective in mitigating the systemic risk of OTC derivatives. When a clearing member defaults, the clearinghouse can generally transfer big chunks of the defaulting member's open positions to other clearing members—like the FDIC does when it resolves commercial banks—minimizing the disruption to counterparties and preventing contagion from spreading. If a clearinghouse only has 2 or 3 dealers as clearing members, and one of those dealers defaults, the clearinghouse wouldn't be able to transfer most of the defaulting member's open positions to other clearing members, because there would only be a couple other clearing members who, under the best of circumstances, have the balance sheet capacity to assume significant chunks of the defaulting member's derivatives book. This would greatly increase the strain on the clearinghouse's guaranty fund. By contrast, if all of the dealers are clearing members and one of the dealers defaults, there's a good chance the clearinghouse will be able to transfer most of the defaulting member's derivatives book to other clearing members, smoothing the resolution of the defaulting dealer and minimizing the strain on the guaranty fund. Another major problem with the Lynch amendment is its potential effect on the liquidity of cleared OTC derivatives. As the name implies, "swap dealers" are the market-makers in OTC derivatives. There's already a question as to whether a lot of standardized OTC derivatives are liquid enough to be centrally cleared. I personally think they are, but the Lynch amendment would make it a very close call. You have to think about why clearinghouses only accept liquid derivatives for clearing — in order to collect the right amount of collateral (or "variation margin") from counterparties, cleared derivatives need to be liquid enough to accurately mark-to-market every day. If mark-to-market prices aren't available, a clearinghouse won't be able accurately value the contract, and it won't know how much collateral to demand from counterparties. If a clearinghouse only has 2 or 3 dealers as clearing members — which, again, would be the ultimate effect of the Lynch amendment — then its access to the (real-time) pricing information it needs to accurately set mark-to-market values will be severely constrained. A clearinghouse needs several dealers to be clearing members (at least 7 or 8) in order to accurately mark-to-market standardized OTC derivatives on a daily basis. Finally, Rep. Lynch is wrong to say that the clearinghouses "are being created to police the big banks in their derivatives trading." Uh, no Congressman, they're not. There's a reason we often say that standardized derivatives should be forced onto "regulated clearinghouses" — it's because the clearinghouses would be "regulated" by the CFTC and SEC! The CFTC and SEC will be the ones policing the OTC derivatives markets, as they'll have nearly unfettered access to clearinghouse data, as well as the authority to impose pretty much whatever standards they want on the clearinghouses. A regulated clearinghouse can only make rules for its members within the confines of CFTC/SEC regulations. Warning that the big banks will be allowed to police themselves without the Lynch amendment is a pure straw man. Let's hope the Senate takes a second to think through the Lynch amendment before it takes up financial regulatory reform.


Steve Randy Waldman said...

EoC — I've not studied the legal structure of clearinghouses to have a strong position, but you have, so maybe you can set me straight. I know that a strong counterparty via mutual risk is part and parcel to the theory of clearinghouses, as is the notion that clearing members will police one another because of that shared liability. (Relying on only CFTC to be the sole "policeman" is dumb. It is much better to have a regulatory scheme that is at least in part self-enforcing.)

But I've become cynical. I'd agree with you if (and, alas, only if) the clearing house is organized as an old-fashioned partnership, with liability joint, several, and unlimited. If it is a limited liability entity, then mutualization of risk is really just a charade: all that matters is capitalization, and if sufficient capital can be raised from non-big-bank sources, it's just as good a Goldman's. If the entity is limited liability, then mutual risk bearing becomes a collective option: the owners can choose to bear the risk and recapitalize if they view a troubled franchise as sufficiently valuable to save, or they can walk away and let the state mop up what would certainly be a TXTF institution. If that's the case, better to limit big-bank control as the Lynch-ites want and just insist on very high cap levels and a very watchful regulator.

I'd prefer to agree with you: I think mutual risk bearing and peer supervision by banks with their full balance sheets on the line is a better model than relying on regulators to enforce cap requirements and guard the henhouse.

But tell it straight and true: as they are or would be constituted post-reg, does running a clearinghouse represent a firm commitment by all owners to bear house risk come what may, or does mutual risk-bearing become an option to support or walk away from a limited liability entity in extremis?

derivado said...

You’re correct. You’ve not studied the legal structure of clearinghouses. In your attempt to show how easily clearing members could walk away from losses you miss two very large hurdles legal and economic.

First, in the clearinghouse model all client accounts are segregated. Clearing members that permit client losses to be larger than client margin deposits in their segregated accounts are liable because the firm operated their business poorly. Notice the losses are of two types: the client losses due to adverse valuation of positions and the clearing member losses due to poor business operations (not collecting sufficient margin deposit from the client).

If a clearing member fails to meet its margin requirements, which is the aggregate of all its client segregated accounts, its own capital is used. If the clearing member doesn’t have sufficient capital the clearing member is sold to other clearing members. Why would any of the other clearing members want to buy the failed member? All of those segregated accounts that are in good standing!

I think the idea you’re missing is fundamental and important. You think people need to be legally committed to taking the losses others will generate – mutually sharing losses – before trading begins. I think people will do deals that have nothing to do with me and some of those deals will generate losses. I want nothing to do with the losses that are not mine.

Steve Randy Waldman said...

derivado — I'm glad at least that we can agree about my ignorance. We must find common ground where we can.

Nevertheless, your remarks, while I am sure they are accurate, do not address the point at issue.

Despite the yawning chasms in my cortex, I am aware that individual members bear the losses of their own clients, and that members are responsible for the aggregate collateralization of the clients they clear.

But the issue we are concerned about is not that one clearing member would do a poor job of managing its operations or its clients' risktaking. I'm with you, the clearinghouse model can handle that just fine.

The risk that we are concerned about is systemic. What if, despite operational excellence at enforcing margin requirements by all members, the exchange's collateral policies turn out to be inadequate following price moves and gaps unanticipated by the clearing members? That is, what if David Vinier is struck once again with several days worth of six-sigma events? How much private capital is genuinely at risk before the state has to step in to manage the losses, despite your concern about the terrible injustice of having anything to do with losses that aren't yours?

The concern the Lynch amendment seeks to address is real: all private stakeholders, banks and traders on both sides of the market, have every incentive to make collateral requirements de minimis, if clearing members in aggregate put of relatively little capital and can put the costs of a failure back to the state. I'm overstating this some — obviously, there is a franchise value to clearinghouses, this is a repeated game, bailouts and failures are traumatic and costly for firms, etc. But, nevertheless, a cursory familiarity with the history of banking suggests that, whatever their intentions or however sincere their optimism, when there is an implicit state guarantee behind financial arrangements sooner or later it gets used unless there is both a large bulwark of capital and a lot of adversarial supervision in place to prevent.

I stand by my original claim: If the clearing members are jointly and severally liable without limitation, if they are willing to stand by the exchanges with their all of own capital, then maybe they should be free to control the exchanges, despite the fact that the particular entities that would likely dominate have a clear history of misjudging their exposures, overlevering, and then relying on the state to assume their risks and alter the environment in order to ratify those risks ex post. The motivation behind the Lynch amendment is sound: why should recidivists control critical and highly leveraged public infrastructure?

EoC makes a solid argument: because control is the price of backing. We want capable, well-capitalized institutions to jointly share the risk, so that before the state is called upon to intervene, clearing members have a deep incentive to police one another, and the public has the aggregate lossbearing capacity of all clearing members protecting it from ransom extraction. But the gains of mutualization depend upon the those institutions actually standing behind the exchange. You haven't answered the question of whether or not they do.

derivado said...

I don’t think you realize it but you are arguing against what you say you want. Perhaps you want to make rules that will guarantee market participants never fail to deliver on their contracted obligations 24/7. There is no set of marco level rules that can protect ‘the system’. The reason why is, once again simple; all transactions happen on a micro level. Let me restate this idea a little… the only macro level rules that perfectly protects the system make a system so constricted no micro level transactions occur.

It’s obvious by now I reject this approach. I reject it for the following reason: if a state, an industry, some organization, or anyone else, perceived to have sufficient capital available, actually makes such a claim to backstop, protect, and insure a system that claim will be tested and the claim will, given enough time, fail. History is replete with examples.

Your scenario – “the exchange's collateral policies turn out to be inadequate following price moves and gaps unanticipated by the clearing members?” – proves my point. Raising collateral and margin levels will decrease the economic viability of deals and hence reduce trading. Perhaps this is what you are after, I don’t know. There are several well know studies that shows how increasing margin on futures contracts decreases trading activity. So let’s consider, during times of market volatility and illiquidity market regulators consistently act to decrease liquidity. (A macro level rule that make micro level deals less economic)

I found the following statement especially confused and contradictory – “The motivation behind the Lynch amendment is sound: why should recidivists control critical and highly leveraged public infrastructure?” – Is the CME public infrastructure? Are OTC transactions part of some public infrastructure? If so, what public organization is making a claim? How does the claim arise? If I transact an options contract at CME or an Interest rate swap with JMP what public infrastructure am I using?

Finally, titled ownership is what controls regardless if the owners are recidivists or not. But why is it the recidivists keep attempting to test the Governments claim of backstop, protect, and insure the system. Could it be the system would be far stronger if everyone knew no one was going to backstop their contracts?

derivado said...
This comment has been removed by the author.
Anonymous said...

If you have 600 trillion notional, the only way to assure a systemic catastrophe would not wipe out the system would be to have 600 trillion in capital parked in a mattress.

Obviously, that is impossible. Such an economy would be dysfunctional as hades.

The best way to deal with a systemic crisis is to borrow a freaking ton of money from the Federal Reserve and the taxpayer. You would think this would be obvious by now, but apparently it's not.

Anonymous said...


I usually think your arguments have quite a bit of logic to them, but this time I find myself inclined to push back.

Why do you say that the Lynch amendment means that only 2 or 3 dealers can be clearing members? The CME must have at over 60 clearing members (more if you count inactive clearing members that join for trading fee reductions) yet they are a demutualized entity with public ownership.

Furthermore, I don't agree with your claim that only dealer banks can be market makers in OTC derivatives. Certainly, there may be some products where their scale can help, but how do you explain the activities of someone like Donnie Wilson and DRW and their long standing tradition of being a big time market maker in options on Eurodollar Futures? Are these really that much easier to make a market than Interest Rate Swaps?

The Lynch amendment is necessary because the public utilities such as clearing houses should have an interest in transparencies, equality of access, price discovery, etc. which runs counter to the interest an OTC market maker who profits from opacity.

Anonymous said...

I hit the 4096 character limit, so this and the next post are a continuation

I have seen this time and time again. For instance, I managed a FX book as a prime brokerage client of large dealer. We traded almost exclusively in the spot market for a long time, mostly on platforms that traditionally were exclusively used by the dealers such as EBS. We decided to move into the forward market, but after getting quotes from many banks, realized that they were just marking up the inter-dealer spread, and tried to get primed into the inter-dealer voice market for FX forwards. The prime brokerage department at the dealer clearing our traders were progressive thinkers, and understanding the commissions we were generating on the spot side, agreed to provide us credit. By utilizing years of relationships, actually got the voice brokers to agree to it as well.

I did one trade, and then everything went awry. The guy running the prop desk at the dealer clearing our trades had a fit (even though we had almost never traded with him) claiming that once his other customers caught wind, they were going to ask for the same thing too (and he was not going to be able to make his spreads anymore). He also claimed that the other dealers would refuse to trade with him once they realized his firm had "broken ranks" by prime brokering a hedge fund into the interdealer market. The end result, was that the prime brokerage department had to convince us to break the trade, due to political pressure from the firm's prop desk. Then the voice broker, after breaking the trade, became worried that the street would catch on to what he allowed, vowed never to allow us to trade in the interbank market again -- a understandable position if you realize that matching a buyer and selling over the phone doesn't require any special market savvy, technology, or capital, and is more or less dependent on your relationships. And then end result -- we weren't able to access the best prices, even though credit was not an issue (our PB would still clear trades we did away with another bank, so long as it was bilateral and not in the interdealer market -- which acts as quasi-exchange).

The same story happens again and again. Brokertec decides to allow prime brokerage clients access to the their treasury repo market, then takes it away once the dealers complain.

EuroMTS comes out saying they will allow prop traders and hedge funds access to the European Gov't trading platform, then pulls away once they get pressured by the dealers.

The banks, upon pressure to centrally clear CDS, decide to partner with ICE because they get to control the market structure; they get a large percentage of revenues and you have to have billions of dollars or a top credit rating to play. (My belief is that you should be allowed to participate if you can pay margin, which should be based on the size of your position, so small firms should have the same ability to directly clear trades as the big dealers so long as their positions relative to their capital are proportionately smaller. It would even perhaps be reasonable to charge them a higher margin on a per contract basis, but to force them to go through a bank seems unfair). It wasn't until CME used their Chicago connections (through the Obama adminstration) that the banks agreed to adopt CME. Ask Jeff Sprecher (ICE CEO) about this -- I'm sure he is not happy that he committed tons of capital to CDS clearing and got run around by the politicians.

Honestly, it seems like a bit of a cartel -- not necessarily caused by collusion, but by the collective fear of economic retribution by going against the grain.

Anonymous said...

I'm not arguing that the Lynch amendment is perfect in its technical details, but I think it is spot-on in its intention.

For instances, take LCH's SwapClear for instance, in which very few firms can participate due to capital requirements that are imposed on potential partcipants (regardless of the size of the positions they wish to clear).

I think we would be better off if the regulatory structure called for access requirements that were more similar to those required to self clear equities through NSCC or those that are required to be a regulated FCM.

Do you disagree?

Steve Randy Waldman said...

derivado — I think we've found some common ground:

But why is it the recidivists keep attempting to test the Governments claim of backstop, protect, and insure the system. Could it be the system would be far stronger if everyone knew no one was going to backstop their contracts?

If we could design clearinghouses that would be credibly private concerns come hell or high water, there'd be no reason for any regulation at all. Unfortunately this is even harder for clearinghouses than for banks, since as EoC points out, their design depends upon always liquid contracts and continuous prices, which is hard to do without a single, central market. But a single, central market will be critical infrastructure that the state would rescue in a pinch, and private players anticipate that, and we're off to the races yet again.

I think dealing with clearinghouse default is a sleeper issue that will come to be very important. Like a horse with a bad leg, we are increasing our reliance on everything that did not fail this time around, and arguably putting stress on our successes that will lead to future failures. In particular, I would like to see someone clearly state how margins will be determined and adjusted on centrally cleared CDS exchanges. CDS move smoothly and are liquid 98% of the time, but they are gappy and unpredictable when firms are in distress. Equities, though they are day-to-day more volatile, collapse more gracefully on the road to distress.

Steve Randy Waldman said...
This comment has been removed by the author.
Steve Randy Waldman said...

Anonymous @ 1:07 am —

Perhaps it'd be better not to have $600T notional in the first place. It'd certainly be better for those uninvolved in the market, but who nevertheless are asked to ratify other peoples' extensions of credit to parties who turned out to be unable to pay. Members of that general public might be forgiven for wanting to ensure that if there is $600T notional outstanding, the parties to those bets always have the wherewithal to cover their net obligations, or at least can be smoothly liquidated out before others are called upon to bear their losses.

(p.s. i say all this without purity: i actively trade futures and derivatives, and do no credit analysis on the exchanges and clearinghouses. i attend to my margins, and hope that the clearinghouses are competently managed. but i rely upon regulation and the possibility of a counterparty of last resort as well.)

derivado said...

As the conversation is bifurcating I’ll make some bullet points:
1) $600T notional is not equal to $600T of capital or to $600T of risk exposure. Most studies put the manageable risk at between 1% - 2% of notional for derivatives OTC or exchange. If, after a position value change, a client account doesn’t have sufficient balance then one of the clients choices may very well be to borrow money and deposit those funds into the account. But once again, this is an operational question for the clearing member that maintains the customer segregated account. No failure should escalate until the clearing member can’t meet its own margin requirement at the clearinghouse. No capital is ‘lost’ or ‘hidden’ anywhere because each set of losing positions has an equal but opposite set of winning positions. Value is transferred between micro players but never lost to the macro system.
2) All exchanges have a process and rule set for admitting and managing its members. All the prime brokers and dealers have their own process and rule set for opening and managing client trading accounts. Are you telling me you want the government to regulate this process more intimately than the government already does? Is the government in some way better at this business than the people in the business?
3) The long and ongoing fight between the clearinghouse model and the OTC model goes to extreme levels at times, and this is another one of those times. What needs to be understood is both business models are viable, both add value, both have strengths and weaknesses and both should be allowed to continue conducting business with as little government involvement as possible. The government needs to understand it shouldn’t attempt to be an insurance company to the risk taking, risk transferring, and risk mitigation part of the economy because the risk takers will transfer risk to the government and the government will never understand the risks it’s mitigating.
4) We already have clearinghouses that are ‘credibly private come hell or high water’. After all, when was the last time a clearinghouse failed? I’m not saying a clearinghouse failure can’t happen but like much of economics there is an optimization that must be calculated. What is the cost of having no risk a clearinghouse will fail? This is actually easy to calculate: all clients must deposit 100% cash for all net notional in their accounts. Of course that means very few, if any, derivatives will trade.
5) Who was it that asked the general public to get involved with funding losers? Oh yes… the government! And why did the government force the general public to get involved? Was the government coerced or blackmailed by the OTC dealers and investment banks? If so, where are the law suits. Did the government consider itself the insurer to some idea of a macro market? If so the government misunderstands markets.
6) There is an equitable order for determining equity responsibility for bearing losses. The owner of the losing account, first go after their assets, then the counterparty (the legal counterparty in the OTC model and the clearing member holding the client account in the exchange model). Then if parties can’t negotiate a solution it goes to the bankruptcy courts.
7) I want price transparency in markets without a question. But what we also need is transparency to losses and losers. This will allow analyst to understand when accounts are losing more value than margin on deposit. Ah yes… this is credit analysis and how well have the rating agencies performed in all this?

Anonymous said...

EoC - Janet Tavakoli is claiming a French bank accepted a 10 cent on the dollar settlement in a situation similar to the AIG bailout.

What does EoC think?

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These are the dangers of legislation, and with governmental solutions to problems.

Sigh :-(

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