Streetwise Professor

October 24, 2011

Call Me Cassandra

There is an increasing drumbeat of stories warning about the systemic risks posed by CCPs.  This FTAlphaville article discusses several dangers I’ve discussed repeatedly, including the stresses put on liquidity, the concentration of risk resulting from the reconfiguration of the topology of the financial network that results from central clearing, and wrong way risks.  Several articles, including this one, report on the BOE’s Deputy Governor Paul Tucker warning about the lack of plans for resolving insolvent clearinghouses–a fear echoed by the ECB’s Peter Praet. Risk has a long article about various CCP risks; particularly interesting is the discussion of the contingent liability that clearing members face in the event of a “forced allocation” of a defaulting member’s portfolio.  The Risk article also reprises an SWP theme about the stupidity of limiting clearing member ownership and control of CCPs.

And the beat goes on.  Although not about clearing directly, this story on the downgrading of MF Global does have implications for clearing, given the CFTC’s decision to require admission of firms with as little as $50 million in capital to CCPs.  And speaking of the CFTC, its recently adopted clearinghouse rule requires CCPs to have enough capital to cover the failure of its single largest member, not the two largest: as I noted in my ISDA white paper, not only should a CCP have enough capital to cover two big defaults, it should have plan to replenish capital after even a single failure.  Although the CFTC may revisit the requirement later, pending negotiations with the Financial Stability Oversight Council, a failure of a single member–not even the largest one–of a CCP will likely require the services of Kevin Bacon do deal with the resulting run:

Needless to say, none of these stories are a surprise to me. I’ve been warning that CCPs could be Trojan Horses packed with systemic risk for a long time, to no avail. I hope that, unlike Cassandra, my warnings are mistaken. But it is becoming abundantly plain that these concerns are becoming far more widespread. It would have been better had that happened before politicians, regulators, and central bankers fallen victim to groupthink and seized on clearing as a “solution” before they had closely analyzed the problem in all its complexity. But the G-20 put its imprimatur on clearing, and the groupthinkers are not about to admit a mistake and start all over. So market participants and regulators are having to deal with the realities of a framework that poses dangers that may be different than, but just as threatening, as those clearing was intended to address.

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  1. […] Share this:EmailTwitterFacebookMoreDiggLike this:LikeBe the first to like this post. By Bill Hodgson 0 […]

    Pingback by Craig says “i told you so” | The OTC Space — October 25, 2011 @ 3:42 am

  2. Hello fellow Cassandra – one point – the change to the failure of the largest member might be driven by the fact that bundlers – large trust divisions of the usual suspects (BNY) are going to be bundling collateral for many of their customers who cannot or will not deal with the clearing software mechanisms available: Putting these in is REALLY painful for anyone not in the clearing business full time. The actual risk of these ops going under is pretty small – well smaller than a traditional merchant house – so the total size of the denovo operators themselves, rather than accepting more risk, might be behind the changes.

    Then again, the best laid pans of mice and men aft gang agley.

    Comment by Sotos — October 25, 2011 @ 6:33 am

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