(I wrote this post a while ago, but for some reason I never got around to publishing it. I was reminded of it when I read Felix Salmon's post on derivatives reform from this morning, in which Felix gives a quick-and-dirty explanation of clearing vs. exchange-trading. I was going to write a take-down of Bob Litan's recent Brookings paper on derivatives reform, but it's honestly not even worth my time. Litan makes a compelling case for derivatives reform in a derivatives market that simply does not exist. The number of basic factual errors is overwhelming, and if Litan advocates for a reform you also endorse, it's likely by coincidence. Suffice to say, you rely on it at your own risk.)



Repeat after me: a clearing requirement and an exchange-trading requirement are NOT the same thing. They are very, very different. It is extremely important that people understand the difference between mandatory clearing and mandatory exchange-trading, because there's an incredible amount of confusion about this in the press — even journalists who cover financial reform constantly conflate clearing and exchange-trading.

A clearing requirement is a requirement that all eligible derivatives be cleared on a central clearinghouse (also known as a central counterparty, or CCP). A clearinghouse provides critical counterparty risk mitigation by mutualizing the losses from a clearing member's failure, netting clearing members' trades out every day, and requiring that parties post collateral every day. Clearinghouses also centralize trade reporting, and can provide any level of post-trade transparency to the OTC derivatives markets that your heart desires — same-day trade reporting, including prices, aggregate and counterparty-level position data, etc. Virtually all of the harmful opacity and murkiness of the current OTC derivatives markets can be ended with just a clearing requirement — that is, a clearing requirement is a prerequisite for getting rid of the harmful opacity in OTC derivatives; an exchange-trading requirement is not.

In sum, virtually all of the systemic risk mitigation in derivatives reform — reduced counterparty risk, the huge increase in transparency, the reduced complexity, regulatory access to the necessary data, etc. — comes from the clearing requirement.

An exchange-trading requirement, on the other hand, is simply a requirement that all eligible derivatives use a particular type of trade execution venue: exchanges (also known as "boards of trade"). It is important to remember that an exchange-trading requirement has nothing to do with clearing — they are completely separate issues. People tend to think of exchanges as synonymous with clearinghouses because, at least in the US, the big exchanges own their own "captive clearinghouses," so most exchange-traded derivatives are also cleared through the exchange's clearinghouse. But they are two separate functions entirely.

The exchange is just the trade execution venue (think NYSE vs. Nasdaq). The only thing that an exchange-trading requirement adds to the clearing requirement is "pre-trade price transparency." That's it. As I've explained before, pre-trade price transparency is not always and everywhere a good thing — and if mandated for all cleared derivatives, it would almost certainly be a bad thing on net. Mandating a particular form of trade execution venue (of which there are many, and among which the competition is fierce) for all cleared derivatives is incredibly short-sighted, and just bad policy.

But even if you accept the most optimistic view of the exchange-trading requirement, the benefit we're talking about is reducing the bid-ask spread that hedge funds and bond managers pay on OTC derivatives from 0.8 bps to 0.4 bps, or from 10 bps to 5 bps. This is what progressives are fighting for? Not knowingly, of course, but they've clearly been fooled into believing that the exchange-trading requirement is the same as the clearing requirement (something they actually should fight for). Arguing that exchange-trading would be a better deal for end-users is NOT an argument for why public policy should require exchange-trading; it's just your view on the relative merits of the various trade execution platforms — a view which most other end-users obviously do not share. There's absolutely no reason that we need to settle these disputes by legislation. It's also important to remember that not including an exchange-trading requirement would do nothing to prevent the market from migrating onto exchanges.

The ultimate difference, then, between the clearing requirement and an exchange-trading requirement is this:

  • The clearing requirement is what's important, and the fight over the scope of the clearing requirement is where ALL the action is in derivatives reform;
  • The exchange-trading requirement, on the other hand, is a pretty terrible idea, which even under the most optimistic assumptions would provide only minimal benefits to financial markets — it is, in other words, an extremely dangerous sideshow.

119 comments:

Anonymous said...

Thanks for the interesting post. What is your view on what types of derivatives should be cleared? all or some.

What happens in a clearing house when a counter party defaults? The other counter parties will have collateral but do they take a loss, or does the clearing house take care of it?

Different people are coming up with a clearing houses for swaps and others. Does this fragmentation cause any problems? in terms of reporting the systemic risk to the system. (I'm new to finance so maybe they have a way of consolidating the reporting)

Been trying to understand what happening with reform and trying filter out the content and the noise.

Cheers

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Anonymous said...

I agree centralized clearing is the main issue as far as reducing systemic risk is concerned.

(Although I do think there are some "systemic risk reduction" benefits to the automated trade submissions that come with exchange trading. Have you ever tried to book OTC trades in even centrally cleared products? The trader passes you to someone in the back office who frequently has no idea what is going on. I certainly wouldn't have wanted to be wearing this daylight risk if I was trading with Lehman during the crisis. If something doesn't actually clear, it can be a huge problem, particuarly if you're doing a trade with multiple legs clearing different places).

I do think you are making the debate about exchange trading too binary. It's perfectly possible to have mandatory exchange trading with bona fide exemptions for non-exchange transactions (you could even allow them to be reported far after the fact).

While I get your point that the benefits of exchange trading are mostly confined to reduced bid/offer spreads rather than huge macroeconomic gains, I think there is a valid argument that increased regulation in favor of exchange trading has made many markets better. Would you rather equities and equity options look more like corporate bonds? Or try to as a retail customer to buy a long dated treasury bond through some brokers front end. I bet the spread you are quoted could easily be 25x or 50x as wide you will see for the TLT ETF.

I don't think that your argument that "exchange offered look-a-likes of OTC products have failed, therefore therefore transparency is a bad thing."

Having a lack of transparency definitely adds complexity to the financial system and increases overall risk. Just because consumers and producers may not be taking actions that increase transparency, doesn't mean it isn't in the public interest. I can think of plenty of things I've traded OTC that I am perfectly happy aren't transparent, but that doesn't mean I don't think it wouldn't make the market more efficient if they were more commonly known.

An analogy might be a tax on cigarettes. Certainly smokers and tobacco companies are both against this, that doesn't mean it's a bad idea. Certainly having huge sets of the population addicted to smoking and tobacco companies engaged in massive marketing campaigns (and medical research companies focused on smoking related illnesses over others) doesn't make the economy more efficient. To the extent a tax on smoking reduces this behavior, it can be in the public interest even if it goes against the interests of the users of the product.

Also, another point to note about the "exchange traded look-a-likes" is that just because they haven't been used extensively, doesn't mean there isn't demand for them. The initial adopters of these products definitely have to make investments of resources while they hope that these will attract sufficient liquidity to do business, and perhaps users have been hesitant to commit these resources. Mandated exchange trading (even with exemptions) might get them over the hump.

The comparison between exchange traded look-a-likes, and OTC products, is in many ways a false one, since the exchange traded products are centrall cleared and centrally cleared products have historically carried considerably higher margin requirements. If mandated central clearing "equalizes the playing field," there may be quite a bit more demand for
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Don said...

If you get a chance, please take a look at this post and the paper referenced:

http://www.creditslips.org/creditslips/2010/04/collateral-and-derivatives.html

http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1569627

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Allan said...

A good post on the differences and thanks for sharing. You may also want to see our viewpoint (CME Group) here: http://openmarkets.cmegroup.com/clearing/fia-boca-conference-makes-otc-clearing-a-top-issue-2/

I'd love to talk more about this if you have any follow up posts.

Mr Wiggles said...

A clearinghouse provides critical counterparty risk mitigation by mutualizing the losses from a clearing member's failure,

It does? Um, how? Seriously, I'm asking because I don't know.

Going back to the basics.
1) We've got standard credit risk: you might go under and not repay the principal I'm owed in 4 years time, or not be there if I want to exercise the Swaption we have on its exercise data in 2012.
2) We've also got settlement risk - we might be due to exchange two things today - eg me giving you 210 million NZD and you giving me 100 million GBP, and if you go under precisely today then I might pay and you might not.

A centralized clearinghouse fixes settlement risk. But while settlement risk is a big deal, it's not a very big deal. If we are both big players then my overall portfolio with you far outweighs todays trades. So standard credit risk is a much bigger deal for the credit derivative and interest derivative OTC markets, which are where the real money is.

So: does the centralized clearinghouse remove standard credit risk?

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