在存年度亚太抵押品管理论坛上, a panel of industry experts examined the new challenges that will affect approximately 1,未清算保证金规则(UMR)最后阶段新增100家范围内实体.
概述了法规要求和提供的数据 国际掉期和衍生工具vnsr威尼斯城官网登入, Purtini Joshi, 存抵押品销售主管, 亚太地区, 第五和第六阶段将分别于2021年9月1日和2022年9月1日实施, 分别, 会产生惊人的9,000或更多独立的交易对手关系. The split of these relationships is roughly 35% in phase 5 and the remaining 65% in phase 6 – where each counterparty firm will have to review their operational, 法律和文件流程，以确保符合IM规则要求.
“The upcoming phases will bring many asset managers and their underlying clients into scope to exchange Initial Margin (IM),乔希说. “这项授权将扩大其在亚太地区的新市场, 包括马来西亚, 韩国, 台湾, 泰国, 和菲律宾.
“Domestic collateral givers in these markets will be looking to maximize the utilization of local securities and government bonds to meet the HQLA (stock of high-quality liquid assets) criteria,她补充道。. “从全球抵押品接受者的角度来看——通常是离岸全球交易商, 他们将考虑如何接受这些证券作为抵押品. Aside from domestic legal nuances concerning creation of security interest on local collateral, 还有一些运营方面的挑战需要解决.”
由乔希主持, the panel examined the operational issues for entities and their counterparties caught by the rules.
The upcoming phases will bring many asset managers and their underlying clients into scope to exchange Initial Margin.
将第五、六阶段与之前的阶段进行比较
O’delle Burke, J.P. 摩根亚太区担保服务/vnsr威尼斯城官网登入创新主管, noted that affected entitles in the final phases will have to find solutions for IM calculation whereas entitles in previous phases had in-house capability to calculate the margin to be 帖子ed. 他说, “We will be seeing more local custodians in markets like 台湾 – instead of European and US custodians which was the case in the past – getting involved. This essentially means that changes in areas like review process, operational set-up, etc.，必须在合规日期之前进行. Aside from Japanese Government Bonds (JGBs) which have been already been included as eligible collateral for exchange, more documentation work and operational mechanics will need to be established for usage of other local collateral increases.”
随着许多韩国市场参与者进入第五阶段的范围, it was highlighted that there will be strong need to use Korea Treasury Bonds (KTBs) for IM exchange. 邓肯•斯科特, 据顾问, MTUvnsr威尼斯城官网登入开发, explained that there may be a bottleneck in providing key services such as custodial management of collateral due to the sheer number of market participants affected.
偏离传统IM模式
伯克指出，根据UMR的第5和第6阶段, the operational framework needed is a deviation from previous phases where the exchange took place almost exclusively at triparty venues. “There will now be third party custodians involved in the operational framework supporting the buy-side firm as the pledgor and their counterparty as the secured party,他说. “另一方面, 第五阶段和第六阶段的公司大部分仍将在三方场地获得保障, 他们将成为抵押品的“接收者”.”
管理运营挑战
跨境证券交易也可能带来操作上的挑战. 以韩国为例, the panel mentioned that Korea Securities Depository (KSD) is working on its own framework for IM exchange, offshore counterparties will need to connect with an onshore local custodian to connect to KSD’s framework. 当交换变化余量时，这种交互通常是手动支持的. With IM exchange, these manual processes are not sustainable and may result in costly errors. While firms may explore different methods to leverage SWIFT messaging to connect to the onshore local custodian and hence KSD, 它本质上是一种变通方法.
也有人指出，在日本, 例如, collateral receivers will now be exposed to many new eligible securities in cross-border transactions. 办理合格新证券登记的业务事宜, firms could work with external vendors to develop a scalable solution to mass register securities.
Scott explained the immediate implication for Phases 5 and 6 in-scope firms is that custodians and tri-parties will need to be onboarded to help operationalize new eligible securities and the margin exchange process. “Instead of relying on time-consuming manual processes or an in-house portal to send and receive messages with offshore counterparties, an automated connectivity approach should be adopted to ensure efficient collateral settlement,他说. “Firms should leverage market utilities to help solve these operational challenges – to reduce operational complexity and risk. A good place to start is to review the solutions adopted by affected firms in previous phases.”
Because of the heavy operational and administrative burden involved in opening segregated account, 伯克观察到，企业正在从两个方面合理化保证金要求. First is to review how to spread their trades among the portfolio of counterparties that they have trading relationships and keep IM levels to below the threshold required to 帖子 margin. Second is to clear all OTC derivatives transactions via central clearing – if the products are generic.
Firms may consider centralizing certain processes across entities to ease the pre-set operational build. That said, the end decision on which route to take varies from counterparty to counterparty.
展望未来
在小组讨论结束之前, Joshi concluded that Asian securities will gain prominence in the margin exchange space as new markets in 亚太地区 come into the scope of UMR. “问题是，这些证券多久才能成为主流? 促进亚洲证券在跨境保证金交易市场的广泛接受, it follows from today’s discussion that firms should start to explore the services of market utility – to make margin exchange efficient and streamlined.”