Editor's note: This article and the next are adapted from discussions that took place at J.P. Morgan's recent collateral
management conferences, "Perspectives on a Changing Reality: Managing Collateral in 2012 and Beyond," held in London and
New York. Buy-side and sell-side panelists included representatives from American Express, Credit Suisse, European Bank for
Reconstruction and Development, HSBC, IGNIS Asset Management, J.P. Morgan Investment Bank, J.P. Morgan Securities, Morgan
Stanley, Northcross Capital, PricewaterhouseCoopers, Royal Bank of Scotland, Société Générale, Standard Chartered and UBS
Global Asset Management.
Regulation has become the driving force for sell-side
institutions—looming in the background to influence every
key business decision. For the sell-side, the biggest impact
is likely to stem from the revised Basel regulations, which
define both stricter capital and liquidity requirements (e.g.,
the Liquidity Coverage Ratio or LCR), European Market
Infrastructure Regulation (EMIR) in Europe and Dodd-Frank
in the U.S.
Globally, regulatory changes are forcing the sell-side to
reconsider current activities and business models as riskweighted
assets (RWA) and balance sheet rationalization put
pressure on revenue generation and spending. The search
for funding drives the sell-side to complement old sources
with new alternatives (such as collateral transformation), to seek new counterparties or to expand the range of
acceptable collateral assets. At the same time, the need to
efficiently utilize all assets most effectively forces a shift to
enterprisewide collateral management.
Global regulatory pressures are supplanting traditional
market drivers and changing business behavior. Institutions
are faced with three categories of challenges:
- New pressures—on capital, liquidity, pricing and costs
- Changing variables—in terms of funding options and
sources (such as accessing new counterparties and market
participants) as well as how assets are employed
- Increased demands—for optimization, reuse and upgrades
as well as for enterprisewide collateral management
New pressures
Institutions must weigh the competing pressures that are
changing the environment in which they do business against
their own business priorities.
- Capital — The amount of capital required and the
composition of that capital are being driven by upcoming
regulations, particularly new Basel rules. Individually
and collectively, these set higher minimum standards for
the amount of capital held on balance sheets and, as a
result, create internal competition for available capital and
financing for existing business activities. Regulations are
also affecting how firms are pricing their services as they
become more granular in the internal allocation of capital
across their business activities.
- Liquidity — As the amount of high quality, highly liquid
assets on balance sheets increase to comply with regulatory
pressures, the ability for certain firms to lend or take on
other liabilities may decrease. For others, the increased
demand for high quality collateral may outrun supply.
Liquidity in certain products may also be challenged as
more business activities compete for the same assets to
meet the emerging requirements of central counterparties
(CCPs) for cleared derivatives trades (a hallmark of both
Dodd-Frank and EMIR).
- Pricing — Pricing discrepancies are emerging across the
markets as, in some instances, the asset is no longer the
primary determinant of the repo rate. Rather, greater
divergence between institutional credit ratings is driving
different rates, more strongly reflecting the perceived risk
of the transacting counterparty.
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- Concurrently, regulations increasingly require that
intracompany transactions be collateralized, limiting
historically favorable treatment of internal counterparties
versus external ones. As these pressures affect pricing,
the institution's underlying clients may be challenged to
understand the rationale behind different spreads for the
same product, or why spreads and rates don't reflect the
same market drivers today as they have historically (e.g.,
rates increase despite low interest rates).
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Challenges Presented by Evolving Global Regulations |
| Pressures |
Variables |
Demands |
| Liquidity |
Funding
Sources/Players |
Optimization
Reuse Upgrades |
|
Pricing |
Cash |
Enterprisewide
Collateral Structures |
|
Increased costs |
Equities |
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- Costs — Ultimately, increased prices and costs will have
to be absorbed within the organization or pushed out to
the end investor. The path chosen may largely depend on
the size of the institution. While larger institutions may
be able to absorb a little more of the cost internally, others
may more aggressively push the costs through to the end
investor. As a result, at the same time that fee structures
become more volatile, costs overall may increase. This
is exacerbated by the continued instability driven by
ongoing regulation and the uncertainty as to the timing
of its implementation. Although the market continually
prices in and absorbs changing market conditions, the
apparently endless stream of regulation has created a
choppy road to stability.
Changing variables
Funding sources, new market participants and collateral
availability will be critical to future market operations. Given
the pressures above, where will funding come from, and will
non-traditional players emerge as collateral providers? Will
equities be more sought after as acceptable collateral, or will
"cash be king?"
- Funding sources — Challenged by regulations that increase
capital requirements, traditional sources such as unsecured
interbank financing are already on the retreat. This is not
only a reaction to the financial crisis but also anticipates
future liquidity and funding requirements under the new
Basel framework, which is designed to promote the shortterm
resiliency of a bank's liquidity position.
- Given the widely expected $2 trillion dollars needed
in collateral for CCP-cleared OTC derivatives, will nontraditional
but cash-rich lenders, such as corporations and
non-bank financial institutions, enter the market in greater
numbers? Likely not, as historically these institutions have
preferred the predictable yield and tenor of fixed income
securities. However, pensions and money market funds — which fall outside the scope of the Basel framework and
thus face fewer restrictions — could become a new source of
market liquidity.
- Equities — Will equities be more widely accepted as
collateral? Overall, although the use of equities as collateral
is on the rise, liquidity demands may stymie significant
growth unless equities are ultimately accepted as liquidity
buffers or counted against capital requirements. (Those
conversations are active and ongoing at the time of
publication.)

- Cash — Is cash "king" in margin maintenance? With
a market awash in cash, that's certainly one option,
particularly if equities are no longer "cheapest to deliver."
This is counterbalanced, however, by two simple facts.
First, although taking cash is often the least expensive
alternative, not all institutions are set up or able to accept
it for all transactions. Secondly, cash collateral received
may not help an institution to meet its LCR requirements
if such collateral has to be returned to the counterparty
within 30 days.
Once all the effects of new regulation are taken into
consideration, institutions must change how they manage
their balance sheets to use capital wisely for transactions that
meet their individual risk-reward profiles.
Increased demands
Although the questions posed above will be answered over
time, what's clear today is that these changing markets
demand sophisticated solutions for coping with new
requirements and increased complexity.
- Collateral optimization — To meet collateral and margin
requirements for cleared derivatives trades, institutions
will engage in more collateral transformation activities.
Collateral upgrade trades, along with short-term money
market trading, are likely to rise as institutions seek more
liquid assets and strive to lock in term liquidity. At the
same time, efficient processes that support collateral reuse
will be essential as institutions seek to utilize all assets to
their greatest advantage.
- The ability to optimize collateral will create a competitive
advantage for those institutions that can reduce their
funding costs and better allocate assets internally.
- Enterprisewide collateral management — Institutions will
have to assess how and where they hold collateral, along
with how they fund and manage activities. Replacing
separate desks (segregated today by region or asset
class) with a single global funding model may help them
mobilize a pool of assets efficiently in the post-regulation
environment.
Conclusion
One final factor to consider is the uneven playing field caused
by regulations that are not fully aligned. As institutions
comply with various regulations, which differ in terms of
region or scope and demand diverse levels of compliance
depending on the industry or type of business, the rules for
remaining competitive have changed.
Global institutions must nimbly navigate competing
challenges — managing cost alongside balance sheet,
maintaining liquidity while leveraging assets, and managing
risk on multiple fronts — and make key strategic decisions
without a clear view of the terrain that lies ahead. As the
sell-side faces increased complexity, the ability to seamlessly
operate across regions and asset classes becomes critical to
success — causing many institutions to seek expert support
from collateral agents with the global reach, expertise and
resources to provide essential support in changing markets.
Thought, Fall 2012
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