Thursday, March 25, 2010

On Clearinghouses

Now that the financial reform debate is heating up again, I want to caution people against viewing a wider clearing requirement for OTC derivatives as necessarily better. Clearinghouses are not a panacea by any means, and pushing instruments that aren't mature enough or sufficiently liquid for clearing onto clearinghouses would be a very bad idea.

In order to properly manage counterparty risk, a clearinghouse needs to be able to accurately price the instruments it clears. Clearinghouses manage counterparty exposure by requiring counterparties to post initial margin at the beginning of the trade, and — crucially — daily variation margin. As explained by Robert Bliss and Robert Steigerwald in a Chicago Fed paper:

Margining systems are designed to ensure that in the event that a clearing member fails to meet a margin call, sufficient funds remain readily available to close out the member’s positions without loss to the CCP in most market conditions. As a complementary risk-management mechanism, the gains and losses from open positions are posted to a clearing member’s margin account on a regular (usually daily) basis and result in calls for variation settlement (or variation margin). The variation settlement reflects periodic mark-to-market fluctuations and is an important mechanism for assuring the collateral held by the CCP is likely to be sufficient to meet the needs of the CCP in the event of a default.
Given the extent to which clearinghouses rely on market prices to mitigate counterparty risk (which is, after all, the main reason we're pushing central clearing in the OTC derivatives space), it's absolutely crucial that the mark-to-market prices be reasonably accurate. Reliable mark-to-market pricing, of course, requires a liquid market.

It seems that a lot of people are pushing for the government to "err on the safe side" by enacting a very wide clearing requirement for OTC derivatives, with exceptions only for truly bespoke deals. The more OTC derivatives that trade through clearinghouses, the safer the system, right? Well, not really — it's not at all clear that this approach would be "erring on the safe side."

In fact, we have a very good example of the potential dangers of this approach: AIGFP. Yes, I'm fully aware that AIG's CDSs weren't centrally cleared. But they were fully collateralized, requiring AIG to post collateral daily based on market prices — the equivalent of a clearinghouse collecting daily variation margin from counterparties to cleared trades.

Most people agree that it was the decision to collateralize their CDSs that ultimately doomed AIG. Since the contracts required AIG to post collateral based on the mark-to-market prices of the underlying CDOs, the decision to collateralize the trades meant that AIG was exposed to short-term fluctuations in the CDO market. AIG was fine with that, because they foolishly believed that the CDO market was deep enough and liquid enough that mark-to-market prices would remain stable.

As everyone knows by now, liquidity in the CDO market vanished, and the market prices of CDOs plunged. Because they had agreed to collateralize their CDSs, AIG was suddenly forced to post billions of dollars in collateral. The effect would've been the same had AIG been required to clear its CDSs through a clearinghouse. The clearinghouse would've required AIG to post daily variation margin based on market prices — this, again, is the primary way that clearinghouses mitigate counterparty risk — which means that AIG would've been forced to post the same amount of collateral when liquidity dried up in the CDO market.

The point is that forcing OTC derivatives that aren't sufficiently liquid onto clearinghouses is not necessarily "playing it safe" from a regulatory perspective. It greatly increases the chances that a clearinghouse will misprice its counterparty risk, and end up not having collected enough variation margin to cover the losses from a default. And I, for one, would rather not see what a clearinghouse failure looks like in my lifetime.

97 comments:

David Merkel said...

I've been thinking about this issue quite a bit, and I think I agree with your position. Exchanges aren't magic -- whatever they do for margin must be conservative if they want to survive. But that runs against the interests of speculators that don't want to have much capital trapped inside margin requirements.

To truly remain safe, with a clearinghouse where all the trades are with the clearinghouse, a participant would have to post some sizable fraction the "worst" result that he might have to pay on. I think of 50% on stocks, and say that if we size the risks off of that, we are probably okay, though I have heard rumors (Yves Smith's book, P. 299) that the NYSE and CME almost failed in 1987. So maybe we would need something more, but if we applied a higher standard, maybe few would want to use the clearinghouses.

My view is try to do interest rate swaps in a clearinghouse -- if that works, expand it. Gotta walk before you can run.

Anonymous said...

Dude, I would prefer you not tip off the congress and Simon Johnson that we could evilly engineer the takedown of a clearing house. - Lloyd

Anonymous said...

Your point is valid in that excess exposure causes systemic risk. One way around this that clearinghouses have adopted is imposing position limits to reduce the chance that any one participant brings down the clearinghouse. If AIG had had a cap on its CDO positions in a clearinghouse,the clearinghouse would have had early warning, and could have required collateral early. Now position limit exemptions do exist, but if they're properly managed, clearinghouses do have a braking mechanism.

Mike said...

I completely see the logic of your point, but AIG's position wouldn't be exogenous to being on a clearinghouse; ideally, as anon@5:33am mentions, they would have had some breaks applied to them earlier.

If AIGFP position wasn't collateralized, what would have happened? My knee-jerk reaction is the situation would have been far worse. They would have been more aggressive and been further in the hole at the end. But I think you could think through that counterfactual better than me.

Mike Sankowski said...

No way was the collaterization in any way like what a clearinghouse does.

the margin held against a position is the first line of defense in a clearinghouse. It is the last line of defense in bilateral contracts.

Clearinghouses typically have 3-5 levels of "panic" Not only do they have the collateral - they have the ability to just take more from you. then they have the ability to fall back on their own resources. then they have the ability to take collateral from other clearing members in several stages.

It is the last line of defense - the ability to take collateral from clearing members - that makes clearinghouses much more stable than any bilateral contract.

Why? because the people that are not part of the trade will start to complain when positions get too large. They don't want to be on the hook if the trade goes bad and someone cannot pay.

That dynamic is the magic of a clearinghouse. It is a natural oversight that the bilateral market does not have.

Additionally, at any time, you can see anyones position. At any time, systemic regulators can come in and say that an individual firm or group of firms have too much risk on and make them take it off.

This is impossible when JPM is the "clearinghouse"

And maybe the NYSE almost failed, but I doubt the CME was anywhere close.

Anonymous said...

What would prevent AIG or any other firm from clearing at multiple CCP's such as CME, ICE, LCH to avoid any potential maximum restrictions a clearinghouse may implement?

Secondly, the argument that clearinghouses could net out risk across various collateral classes could only help firms that trade CDO's as well as CDS, IRS and futures.

However it will be interesting to see if CCP's take off because it is obvious costs will increase due to needed collateral posted by clients clearing members.

Anonymous said...

I agree with Mike Sankowski, that demanding collateral is the last line of defence. But most clearing funds are structured around participant contributions, and squeezing AIG to full collateralization would probably have happened well before any other participant gets called for contributions.

As for spreading the risk across multiple clearinghouses, yes it can happen and given that CDOs aren't standardized contracts, would probably be easier. One way around this is to layer information sharing between houses on nominal asset class positions, but that is unrealistic given the multiple jurisdictions and competitive concerns.

Probably a better approach is to rely on tight position limits across houses, since there aren't THAT many houses. Couple that with mandatory disclosure when a firm wants to increase position limits and you have a more practical, self-limiting solution.

As for clearinghouses increasing the cost of transaction, that seems pretty much a feature and not a bug.

The original point about needing rock-solid, reliable marks still stands of course; and since almost all houses use a margin methodology based on historical volatility, surprises can and do happen.

On the plus side, at least there are now some decent vol numbers to play with... ;)

Sorry if i make any spelling/grammar errors; typing on a mobile isn't that easy.

csissoko said...

"And maybe the NYSE almost failed, but I doubt the CME was anywhere close."

The underlying source of this claim is MacKenzie's An Engine, not a Camera, which in turn in based on Leo Melamed's autobiography and interviews with participants. Melamed was chairman of the CME, where S&P futures were traded, in 1987. According to Donald MacKenzie:

At 20 minutes to opening, the Merc was still short $400 million in clearing funds -- and wouldn't be able to open on Tuesday -- which would undoubtedly have added dramatically to the panic set off by Monday's crash. Melamed begged the Merc's banker to guarantee the shortfall, but she said she couldn't do anything -- until the chairman of Continental Illinois walked into her office. The difference was covered at three minutes to opening.

Lind, a former CME chair, had pressured the board to open despite the shortfall: "The Fed just spent all these billions of dollars that you are about to demolish. If we don't open, we may never open again. You will have ruined everything they did. Closing the Merc will not help. If you're broke, you're broke."

Basically (as you can find in documents on the NY Fed's website), Greenspan and the NYFed engineered a bailout of the NYSE and the CME.

There's definitely a huge issue with the pressures on government to bailout bankrupt clearinghouses/exchanges.

Leon43 said...

EOC: I thought one of the issues was that AIG did not have to be fully collateralized, because of its credit rating. Then, after AIG was downgraded, the lower threshold was triggered and it did have to post full collateral, encountering the liquidity risk you discuss. I may be confusing the sequence of events and triggers here, though. Can you clarify? Thanks.

JCH said...

I think some of their swaps required additional collateral with a ratings downgrade, and some did not. All of them required collateral postings to cover market devaluations.

Don said...

"Why? because the people that are not part of the trade will start to complain when positions get too large. They don't want to be on the hook if the trade goes bad and someone cannot pay.

That dynamic is the magic of a clearinghouse. It is a natural oversight that the bilateral market does not have."

The question is would this work in a panic, and would there be a natural tendency to let things ride if times are good?

In other words, what level of resources does the Clearinghouse need to keep available? All you've done is transfer the bottom line defense to a common fund of sorts. Does that lead to vigilance or complacency?

Don the libertarian Democrat

JCH said...

OT:

Simon Johnson continues to insist resolution authority cannot work on systemically important entities that have significant cross-border complications.

Is not AIG currently undergoing a pseudo resolution?

Anonymous said...

Leon43: That is exactly what happened. Some of the AIG swaps were not collateralised at all (people didn't think it was needed - they were so highly rated, afterall..). After the ratings downgrade the counterparties could then demand collateral. (It's no different to the whole CDPC idea. No one has yet convinced me to take on one of them as a counterparty in anything. I doubt they will.)

The stupid thing is, these downgrades occurred because they were allowed to borrow money from a subsidiary. The minute that happened the collateral calls came and I'm sure those calls came in over and above the amount of money they had just borrowed from said subsidiary (just a guess - I can't prove this and not wanting to say anything contentious). Nice work.

The whole really just highlights what a ridiculous situation both AIG and their counterparties got themselves in to. Anyone who previously thought that buying super-senior protection from a monoline (or, frankly, anybody...:-), was a good idea soon realised the flaw in their carefully thought out plan.

Hindsight of course is a wonderful thing.

PPP Lusofonia said...

I agree, clearing houses are no panacea for the CDS credit swap problem, but it will help cut the market down to a proper size, and promote much needed credit re-intermediation.

A bank creditor who needs to lay off credit risk on basic credit products such as mortgages, consumer, small business and corporate loans hardly deserves to be called a bank.

Credit swaps and credit insurance should have a much place in the financial markets, just for the benefit those creditors whose core business is commercial, not financial.

Financial products have to be very homogeneous to be traded on a central exchange, to estabish the price, and centrally cleared, to limit counterparty risk.

And the gross nominal amounts should all be reflected on the balance sheet (on a liquidation basis, assume that incoming payments will be zero)

As Christine Lagarde says, the use of off-balance sheet credit swaps has to be sharply restricted.

Mike Furlan said...

Well kids, I'll spare you stories of when I was a boy, and we had defaults twice a day (three times on Sunday) and we liked it that way.

Anyone who is interested can read about Potato and Silver futures way back in the 1970s.

Short version is that yes, you need more than just a clearinghouse. Well designed trading rules that allow the "responsible adults" regulatory power up to and including the ability to limit or even shut down trading in problem markets are needed too.

If a clearing house is merely a method to more efficiently shovel money to the latest joker who has figured out how to manipulate a market, well yes that would be a bad idea.

Eliot said...

NETTING is the key issue here. The advantages of a firm netting all its derivatives at one place... the clearing house.... would greatly reduce the chance of being bankrupted by collateral requirements. This is because any sensible derivatives desk would be trying to more or less hedge their exposures, with only a limited principal position. If a derivative can't be easily marked to market, its in the public interest to discourage that trade through the regulatory burdens.

Rajat said...

Hi EOC,
I am not familiar with exact workings of CDS or CDOs so I could be wrong here, but I am not sure your example of AIG exactly mimicks a clearinghouse.
A clearinghouse requires initial margin. I am not sure anybody checked that AIG had enough initial margin for its open positions. I would argue under a clearing house it would have never been able to underwrite so many CDS's
Secondly, AIG was posting collateral but after posting collateral it probably had less initial margin for other position so under a clearing house it would have had to close some of the other positions out.
My feeling is that under a clearing house AIG would have never had such large positions and it would have been forced to cuts its size immediatley as some of its positions soured.
I would appreciate your feedback.

Thanks

Anonymous said...

i will live in a world with hundreds of competing clearinghouses where assets will be netted against other assets with such precision that i will post nearly no margin, because even outside of the fact that competition between clearinghouses will seek this ideal margin level, there will have been years of clearinghouse failures and successes to determine such netting.

Anonymous said...

Rajat is right about how a clearinghouse would have damped AIGFP activity levels. And while EOC is right that a clearinghouse is not a panacea, he is wrong about collateralization. AIGFP had no collateralization obligation under AIG (parent guarantor) was downgraded; then it had a "cliff" collateralization requirement to post collateral in the full amount of its exposure (which it promptly fell off). If AIGFP had been posting variation margin right along, its positions never could have gotten as big as they did -- because even a small collateral posting requirement is a lot more than zero.

CJ said...

Executive Summary:
- Clearing/Margining does not remove risk, but rather transforms credit risk into liquidity risk and/or market risk.
- For many companies, credit risk is less volatile and easier to manage than liquidity risk
- Credit risk is almost always preferable to market risk

A key point is that forcing clearing/margining does not remove risk, rather it transforms risk. In particular, you are transforming credit risk into liquidity risk (in this case, the risk that a company cannot meet the required margin calls). To the extent that liquidity risk leads to less hedging, you may also transform credit risk into market risk (a terrible outcome, by the way).

Take energy utilities as an example. They commonly use basic derivatives (esp. fixed-float swaps) to hedge their portfolio (which helps keeps rates stable for customers and earnings stable for investors). Most of this is OTC. There are hundreds of counterparties to choose from, making credit risk relatively easy to manage simply through diversification. Some utilities augment diversification with margining, but not all. Those that do so generally margin based on collateral thresholds... meaning margin is only posted beyond certain predefined limits (as opposed to an exchange with margins for the full value of the forward contract plus some additional). In any case, each utility uses margining to the degree that it feels appropriate.

Now let's say you force all these utilities to post margin for 100% of the value of their derivative hedges. In contrast to credit risk, liquidity risk is hard for your average utility to manage via diversification, because the market hubs at which they transact tend to be highly correlated. So a utility that's naturally short (a common position), will find that margins calls across all of its purchases are highly correlated, making it very volatile and relatively difficult to manage liquidity risks. Utilities will be forced to carry literally billions in extra liquidity to meet these potential margin calls or simply decided to hedge less. Note that hedging less exposes customers and rate payers to rate and earnings volatility, respectively

Jeremy said...

It would be extremely irresponsible for Congress to force more OTC derivatives through centralized counterparties without also taking measures to ensure the stability of those CCPs. The House's bill, passed in December, would increase the proportion of volatile derivatives that are centrally cleared, yet it would effectively prevent the Fed from lending to a clearinghouse in a time of market crisis. Fortunately, the Senate draft would guarantee the stability of CCPs by allowing the Fed to treat clearinghouses as depository institutions for the purposes of discount window lending. If we're going to mandate central clearing, we also must protect clearinghouses with access to Fed liquidity.

For a thorough analysis of the central clearing mandate and the necessity of central bank liquidity, see http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1583912

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