T+2 POTENTIAL POST-TRANSITION WOES: CONFIRMATION / AFFIRMATION

The transition to T+2 settlement throughout the European Union (EU) is scheduled for January 2015. Some countries may transition before this date. Henceforth, from January 2015 equity and bond trades will settle two days after trade date across the EU. This is a major accomplishment as it’s the first region to reduce the time between trade and settlement date from T+3.

One unknown consequence of this change is the impact on Confirmation / Affirmation (C/A) rates.  The C/A process occur between institutional investors (buy-side) and their brokers (sell-side). Institutional trade volumes represent the largest number, and greatest value, most broker’s business. 

The C/A process is the presentation (confirmation) of trade details by the sell-side and approval (affirmation) from the buy-side. The current rate of successful affirmation on or before T+1 is between 60-70%. In a T+2 environment positive affirmation must be made on trade date.

Un-affirmed trades must be reconciled to ensure timely settlement and to avoid failed settlements. In the current T+3 environment manual work-arounds are used to identify and resolve un-affirmed trades. But  in a T+2 enviroment, with one less day, manual work-arounds will be less effective. As a result the industry must respond to this situation to ensure the success of T+2 settlement.

There are alternative responses that can address this situation; one is for the buy-side to review and respond to the confirmation on trade date. Another alternative is for the buy-side to empower their custodians to affirm trades on their behalf. Both will permit sufficient time for exceptions to be resolved and advise custodians of the pending settlements. Both alternatives can be implemented with minimal changes to buy-side internal worksflows and minor technology modifications.

These alternatives are short term solutions to the C/A process. The global industry needs an integrated model so that the C/A process is incorporated into the order-trade workflow. The C/A process should be automated with minimal touch-points required. There are systems in place today that come close to this model, but they have not been fully embraced by the community. The industry must determine why these systems aren’t  fully utilized. They must address these issues or commission development of a system that is acceptable to all order to trade lifecycle participants

What’s your opinion on this situation?

               Any idea why affirmation rates are so low?

                        Are  there other viable alternatives?                        

                        

CLEARING ENTITIES – WHEN ARE THERE TOO MANY?

It seems that every week there’s an announcement of a new clearing entity supporting a market or product. Clearing is critical and provides safety and risk mitigation for market participants. But I wonder if there can be too much of a good thing?

Granted, clearing is a basic requirement of a sound financial services industry, and should address trade matching, collection of initial and variation margin and the clearing entity acting as the Central CounterParty. But is forming a new clearing entity the most effective approach?

In a market without a clearing entity, one is needed to provide critical services. This often requires regulatory changes, perhaps on a national scale, to begin the process. The local infrastructure must be in a position to support this process. This includes funding and contributing the expertise to define the processing and control functions. This is a heavy burden for an emerging or pre-emerging market to undertake.

Perhaps leveraging the expertise of an existing clearing organization, rather than creating a new entity, is a better alternative. This would permit clearing services to be made available faster and potentially with less pain and expense usually associated with forming a new entity. The potential benefits of this approach are considerable as it would reduce the costs associated with development and encourage the use of clearing in new markets.

Further along this line, I question why new clearing entities are being formed in markets where there is an existing entity already providing clearing services.  Are clearing services for one product substantially different from another product?  Are there benefits of using an existing platform?

If there are legislative or regulatory issues that demand a new entity, the industry should appeal this situation as it results in a fragmented clearing process. Additionally it requires firms to join multiple entities, support redundant interfaces and holding positions and balances across multiple entities all which results in increased costs.

Perhaps some products can’t be co-mingled or require unique processing streams and / or reporting.  Or segmentation may be required to mitigate associated risks. This can be addressed via a holding company structure where different processing streams within a clearing entity would maintain the required segmentation.

The old approach of “cloning” an existing infrastructure, to support a new requirement, has been the “go to” approach for financial services firms for far too long. As seen many times, this seemingly simple approach is costly in the long run with multiple interfaces, maintenance of different but similar applications and processing multiple processing streams.

Once in-place these cloned systems are almost impossible to replace or eliminate due to the ever evolving demands for new products, faster processing or new markets.

Fewer clearing entities will flatten the landscape and reduce fragmented processing streams. It will also support cross-margining and improved collateral management. In the future fewer clearing entities will ease the transition to global interfaces among clearing entities.

So, when will we learn from the hard lessons and modify our approach to the never-

ending demands of the industry?

What is your opinion about this?

           Are there other viable approaches available?

                 How many clearing entities memberships does your firm have?

THE FUTURE OF THE MIDDLE OFFICE

The Middle Office evolved as a result of various issues facing Sell-side firms. Two issues, in common, to these firms were:

1.     a need for additional controls to improve the accuracy of the trade details at the beginning of the trade lifecycle

2.     the need to identify and resolve issues causing trade settlement delays

The response was to establish a function that would be closer to the front office, where client facing activities tak place, than the traditional back office. That’s how the name Middle Office came to be and has stuck.

Eventually buy-side firms, as well as other industry service organizations, also established a middle office function as well. This allowed each to functionally match-up to broker/dealers, custodians and prime brokers. Over time the focus of the Middle Office grew to include accounting, reporting and other control activities. The role of the Middle Office has improved operational efficiencies, reduced the cost of resolving delayed and failed trade settlements.

As the time between trade and settlement date shrinks, the Middle office may again prove to be an essential function in maintaining operational efficiency.  The reduction of time between trade and settlement date results in less time to resolve problem trades. This loss of time will require firms to rethink existing internal practices to ensure that there is sufficient time to identity, analyze the cause and resolve the issues that may delay timely and accurate settlement.

Today resolution of problem trades often requires interaction across various front, middle and back office areas. This can take a considerable time and may result in settlement delays. A shortened trade-settlement schedule may result in an increase in unresolved trades. This will have a negative impact on settlement and post settlement activities plus increase operating costs.  One approach might be to reduce the number of departments or staff involved in trade and settlement processing.

Restructuring operational responsibilities is one alternative to consider. Perhaps moving the activities associated with pre-settlement and settlement, now performed by the Back Office, to the Middle Office may be worth a review.

A new infrastructure might include reassigning functions between the Middle ad Back Office areas as follows:

1.     Middle Office – all post order(trade) execution through settlement functions

2.     Back Office – all post settlement through to asset servicing functions

This change is a huge leap from the structure that has been in-place for years. It is similar it to the introduction to technology in the 1960’s which resulted in new work flows, new departments and procedures. Technology continues to support the business and the impact is the same, with slight variations and the evolving changes are accepted as (business as usual.  

This is one approach. There is sufficient time for the industry to ponder the impact of reducing the trade-settlement and explore appropriate responses.

         Do you agree that this is a situation we will face?
 

                Is splitting functions between Middle and Back Offices viable? 
      
                     Can you offer alternative responses?

MULTIPLE SYSTEMS = MAINTENANCE CHALLENGES

The approach broker / dealers adopted early on in the development of application technology was to develop product-centric systems. For example a, equity system fro equities, a government systems for Treasury and a MBS system for mortgage backed securities. As a result, today firm have multiple processing platforms, each supporting specific products. The driver behind this approach was to create a template system that could be cloned to support other product systems. For example if the base fixed income system was the Treasury bond system, it could be used as the foundation for corporate and municipal bonds. Extraneous or unneeded functionality would be stripped while new functionality unique to corporate and municipal bonds would be added. This allowed firms to avoid "reinventing the wheel" each time they introduced a new product and sped up the process as well.

The outcomes were many similar, but different processing systems, each requiring expertise, maintenance and support. For example some products settled one day after trade date, others five days after trade date while mortgage backed securities can settle up to six month after trade date. Differences were pervasive throughout the trade life-cycle as well as in reference data, trade entry, and asset servicing and reporting. This required systems developers and maintenance staff to have current and relevant expertise and knowledge of each product and the related processing functions. The bottom line is that this resulted in increased information technology costs and often delayed new functionality and updates to be applied, even today.

Firms are still struggling to find an approach to address this challenge.  In the past 30+ years have seen many innovations in database design, programming languages and other advances that can provide benefits to financial services firms processing systems. But first they must reduce the number of product-centric systems to facilitate an efficient future environment. There are various alternatives; one is to build a new multi-product system to replace the product-centric systems. But the alternatives require a major effort in cost and resources. And have to be done in the current environment of keeping costs down.

 

         What is your opinion about this?

          Does this cause firms to less competitive?

                                Are there other viable approaches available?

WHAT'S UP WITH THE LEGAL ENTITY IDENTIFIER?

It’s been a while since the need for recognizing legal organizations and their related entities has been identified. There have been a number of announcements on initiatives but little definitive movement on a coordinated global response to LEI.

Remember that it was difficult to determine their exposure of derivative trades especially for firms, like Lehman, that were facing a credit crisis. The initial drive for LEI was the Dodd Frank Act (DFA) and European Market Infrastructure Regulation (EMIR). Their focus was to reduce counter-party and systemic risk related to derivatives trading and settlement.

February 12^th was the date for SWAP trades to be processed with LEI. Problems were expected but the news about this event has been sparse.

What are your thoughts, good, bad or neutral, concerning global legal entity identifiers?

                        Are the regulators ready to respond to reported anomalies?

                                 Should a global identifier be extended to other assets?

SUPERVISORY COLLEGES FOR INTERNATIONAL CREDIT RATING AGENCIES

These organizations were established as a result of recommendations that the International Organization of Securities Commissions (IOSCO) made in their final report published in July 2013.  Supervisory Colleges for International Credit Rating Agencies creates a mechanism for sharing and discussing information regarding:

• Compliance with local or regional laws and regulations
• Implementation of, and adherence to, the IOSCO Code of Conduct for CRA
• Establishment and operation of rating models

•  Methodologies, internal controls, procedures to manage conflicts of interest
• Procedures for handling material non-public information
• With the goal of promoting better understanding of the risks faced or posed by international CRA and how relevant supervisors are addressing these risks

One lesson learned, was that credit rating agencies face conflicts. The Supervisory Colleges are a creative approach to avoiding similar missteps.

The colleges for S&P and Moody’s will be chaired by the Securities and Exchange Commission (SEC) and the college for Fitch will be chaired by the European Securities Markets Authority (ESMA. The SEC

              What’s your opinion about the need for supervision of credit rating agencies?

     Is this an appropriate response?

What are the critical best practices for the CRA?