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Bloomberg & The Union of Arab Securities
Authorities Rountable
7 – 8 September 2016
What are CCPs and how do they operate
under new European regulations?
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
2
Agenda
• EMIR Mandatory OTC Clearing Timetable
• Role of CCP’s & Risk Management
• Client Asset Segregation & Protection
• OTC IRS & ETD Cross Margining Efficiencies
• ISA Direct Clearing Model – Direct Access for the Buy Side
• Securities Lending & Repo CCP
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
33© Oliver Wyman
Scope
Frontloading
The clearing obligation takes effect on:
• June 21, 2016 for Category 1
• December 21, 2016 for Category 2
• June 21, 2017 for Category 3
• December 21, 2018 for Category 4
Description Implementation status
Additional
Points
• The RTS includes a three-year phase-in mechanism to deal with intragroup transactions.
• It also allows funds to calculate the aggregate average outstanding gross notional amount of non-
centrally cleared derivatives individually at a fund level for calculating the threshold used to
determine the clearing category of such entity.
Regulatory update: EMIR Mandatory Clearing
• Interest Rate Swaps (fixed to float, basis, FRA’s and OIS
swaps phased in for 4 counterparty categories
• Category 1 entities have a phase-in period of six months;
• Category 2 entities a phase-in of 12 months;
• Category 3 entities a phase in of 18 months; and
• Category 4 entities a phase-in of 36 months.
The frontloading obligation takes effect:
• February 21, 2016 for Category 1
• May 21, 2016 for Category 2
• The frontloading obligation will only apply to Category 1
and Category 2 entities.
• Frontloading doesn’t apply to non-financial counterparties
(NFCs).
• the minimum remaining maturity for Category 3 entities
has been set at a level to exclude all trades from the
frontloading requirement.
3
EC published G4 rates clearing obligation in the Official Journal on 1st December 2015
– The RTS will come into force on 21 December 2015
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
4
Agenda
• EMIR Mandatory OTC Clearing Timetable
• Role of CCP’s & Risk Management
• Client Asset Segregation & Protection
• OTC IRS & ETD Cross Margining Efficiencies
• ISA Direct Clearing Model – Direct Access for the Buy Side
• Securities Lending & Repo CCP
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
5
CCP services improve soundness of market
infrastructure and strengthen market integrity
Reduced systemic risk
• CCP takes over counterparty risk through
trade novation
• CCP enforces strict risk control and
adequate collateralisation of open positions
• Automatic multilateral netting reduces
gross risk exposure
Benefits of multilateral clearing with Central Counterparty
1 Increased transparency
• Awareness of concentration risk
• Independent position valuation by neutral
institution
• Early warning function by daily mark-to-
market
Efficiency gains
• Full automation and straight-through
processing reduces manual errors
• Efficient use and
management of collateral
• Increased capital efficiency
by reduced balance sheet exposure
Bilateral trading & clearing
Current OTC market structure- 1:n relationship
Bilateral trading & multilateral clearing
CCP market structure - 1:1 relationships between CM and CCP
B
C
A
E
D
OTC
CCP
F
A
FD
C
B
E
2 3
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
There are two basic models to trade OTC derivatives
Bilateral
OTC model
Centrally cleared
OTC model
Description • Bilateral models are the traditional form of OTC
transactions and take place between two parties
• Two parties enter a OTC transaction and bear the
counterparty credit risk of each other
• During the life of the trade the parties exchange
variation margins (VM) to account for market
value changes
• In most instances initial margins (IM) to account
for potential future exposure (PFE) have to be
exchanged
• In a centrally cleared OTC transaction, a central
counterparty (CCP) steps in between the two
parties
• The initial arrangement between the two parties is
replaced by two agreements on identical
economic terms (“novation”), each with the CCP
and one of the parties
• As a result the CCP administers the transactions,
manages the collateral and also the counterparty
credit risk
• Both parties have to post initial and variation
margins to the CCP
6
Schematic
illustration
Party A Party B
Bilateral agreement
CCP
Bilateral
agreement
Party A Party BX
Bilateral
agreement
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Eurex Clearing Lines of Defence
Eurex Clearing’s guiding principle in a default situation is to minimize
the effect on the Lines of Defence and to stabilize the markets
7
• Eurex Clearing provides a multi-level security system
− First the collateral and the Clearing Fund contribution of the member in
default are utilized.
− After the defaulter’s contributions are exhausted, an assigned dedicated
amount of Eurex Clearing is applied, before non-defaulting clearing
members’ Clearing Fund contributions, and remaining capital of Eurex
Clearing are used.
• Each clearing member’s contribution to the Clearing Fund is based on
a minimum contribution and a dynamic component, accounting for the
individual clearing member’s risk situation.
• There is one segmented Clearing Fund for listed and OTC business.
• Following a realization of any Clearing Fund contributions of non-
defaulted clearing members, such clearing members are asked to
provide assessments to their contributions.
• Clearing members’ total liability is limited as they have to provide a
maximum of two assessments per capped period. Remaining Capital
of Eurex Clearing
Parental Guarantee
Max 2 Assessments per
Clearing Member
Eurex Clearing Lines of Defense
Clearing Fund Contribution of
Other Clearing Members
Dedicated Amount
of Eurex Clearing
Clearing Fund Contribution of
Clearing Member in Default
Collateral of Clearing
Member in Default
Position Netting
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Key focus of stress testing is sizing the Default Fund
Default Fund size is determined regularly based on a “cover 2” scenario
Default Fund contribution is the highest amount of:
• 7% of average IM requirements (30 days), or
• 7% of average IM requirements (250 days), or
• GCM: EUR 5 m, DCM: EUR 1 m
8
• The Default Fund contribution of a Clearing
Member is determined as a percentage of
the Initial Margin requirement
• A quarterly recalibration of the Default Fund
and a regular review of the adequacy of the
Default Fund size and methodology take
place
• Results are presented to senior
management and the Risk Committee
• Sufficiency of the Default Fund to cover the
2 largest defaulting Clearing Members
simultaneously with market stress is
validated daily
• Both historical and hypothetical scenarios
are used for Default Fund dimensioning
• If stress test results indicate that the Default
Fund is not sufficient then:
– Global percentage can be
recalibrated, or
– Member-specific actions can be
taken
-
500
1,000
1,500
2,000
2,500
3,000
3,500
4,000
Hypothetical scenarios Historical scenarios
Default Fund
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
9
Eurex Clearing’s guiding principle in a default situation is to
minimize the effect on the lines of defense and stabilize the
markets
Remaining Capital
of Eurex Clearing AG
Parental Guarantee
Max 2 assessments per CM
Clearing Fund Contribution of
Other Members
Dedicated amount
of Eurex Clearing AG
Clearing Fund Contribution of
Member in Default
Collateral of Member in Default
Position Netting
Eurex Clearing provides a multi-level safety system Lines of defense
• First the collaterals and the clearing fund contribution of the member in
default are utilized.
• After the defaulters contribution is exhausted assigned dedicated amount of Eurex Clearing AG is applied
before non-defaulting clearing members contribution and remaining capital of Eurex Clearing AG.
• The contribution to the Clearing Fund is based on a minimum contribution and a dynamic component
accounting for the individual clearing member’s risk situation.
• Following a realization of any contributions to the Clearing Fund of the non-defaulted clearing members,
such clearing members are asked to provide assessments to their contribution.
• Clearing members’ total liability is limited as they have to provide maximum two assessments per capped
period.
• The creation of liquidation group specific clearing fund segments (CFS), within the single common
clearing fund.
• CFS are determined for each liquidation group. A CFS is a partition of the single clearing fund according
to the relative weights of the initial margin of the Liquidation Groups.
• When liquidating a particular Liquidation Group, only the respective CFS can be used to cover losses,
unless there is a known surplus from other, already completed Liquidation Groups.
Segmentation of the clearing fund
Remaining Capital
of Eurex Clearing AG
Parental Guarantee
Max 2 assessments per CM
Clearing Fund Contribution of
Other Members
Dedicated amount
of Eurex Clearing AG
Clearing Fund Contribution of
Member in Default
Collateral of Member in Default
Position Netting
Lines of defense
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Default Management Process reflects best practice and complies
with market requirements and regulatory guidelines
10
Overview of Default Management Process
•Preliminary
Measures
• Convention of Default
Management
Committees to support
Eurex Clearing
throughout the whole
DMP
• To protect client assets,
positions and collateral
are transferred
wherever possible
• Portfolio and market
evaluation in
preparation of
liquidation
• Handling positions that
expire shortly
•Hedging
• Hedging of the
defaulted clearing
member’s portfolio
is executed as early
as possible, to limit
losses immediately
• Hedged portfolio is
likely to receive
better prices in the
auction
•Independent
Sale
• If the portfolio is small
or only few clearing
members are active in
the involved products
then bilateral or on-
exchange trades can
ensure a timely
liquidation
• Mutual clearing fund
will not be utilised,
unless all clearing
members have the
chance to provide a
price in the auction
•Auction
• Participation in
auctions is
mandatory for those
clearing members
who are capable from
an operational and
risk perspective to
process the
respective portfolio
• Clients are allowed to
bid via their clearing
member
• Clearing fund
juniorisation and
penalty fee set
incentives for
competitive bidding
Holding period serves as basis for risk calculation within Eurex Clearing
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Overview of major areas within CCP Risk Management
11
Counterparty
Assessment
• Eurex Clearing has strict criteria for counterparties to guarantee that clearing members,
payment banks, treasury counterparts have sufficient credit quality and financial strength
• Credit assessments are repeated on a regular basis
Margining
Stress Testing
• Additional post-default backings are available to cover risks beyond the margin confidence level
• The adequacy of the Clearing Fund size, Eurex Clearing’s total financial resources and liquid
financial resources is verified by means of stress tests
• Margin requirements are aimed to cover potential losses arising during the default management
process according to the “defaulter pays” scheme
• Margin requirements are monitored and enforced intraday
Collateral and
Member
Monitoring
Default
Management
Process
• Eurex Clearing only accepts secure, liquid and accessible collateral with low credit risk
• A comprehensive risk management framework has been established in order to identify,
manage and control credit, concentration and wrong way risks
• When a Clearing Member goes into default, one of Eurex Clearing’s principle objectives is to
protect customers and minimize harm to clients and their positions
• Losses to the CCP’s lines of defense and the disruption of the wider market are minimized
Eurex Clearing’s Risk Management Framework
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
• Aligned default management process across a Clearing Member’s
positions
• Positions deemed suitable for simultaneous liquidation are
logically assigned to the same Liquidation Group
• Risk offsets are only granted within the same Liquidation Group
(e.g. Equity, Commodity or Fixed Income)
Consistency
4
2
3Central benefits
• Adjustments to enable stable margin requirements: concentration,
uncertainty in correlations, model adjustments if compression
is used
• Flooring for stability: Stressed period scenarios and dynamic volatility
scaling to at least long run volatility percentiles
Stability
• More accurate risk netting effects than legacy risk models
• Higher capital efficiency for customers through risk calculation on a
portfolio basis
Capital
Efficiency
• Reduced time-to-market for new productsFlexibility
1
5
• Cross-product scenarios enable consistent way to account for portfolio
correlation and diversification effects
• Risk covered at high confidence level through margin calculation
consisting of a
− Mark to market component
− Forward looking component
− Adequate liquidation time horizon
Accuracy
Eurex Clearing employs a state-of-the-art margin method
Several benefits are derived through the methodical cornerstones of Eurex Clearing’s
portfolio margining model methodology, PRISMA
12
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
1313© Oliver Wyman
Cost efficiencies may vary substantially across CCPs
along 3 key drivers
13
An integrated cross-product CCP with a large eligible collateral spectrum entails the
highest efficiency potential for customers
Netting
efficiency
Default
fund
efficiency
Collateral
efficiency
1
2
3
• Multilateral risk netting may be complemented by cross-
product exposure netting (& cross-margining) between
OTC, exchange-traded and cleared repo transactions
• Netting of positions in liquidation groups for initial margin
and balance sheet netting of exposure at default under a
single legal CCP construct
Higher netting efficiency
lowers capital and
funding requirements
Higher default fund
efficiency lowers capital
and funding
requirements
Higher collateral
efficiency lowers funding
requirements
• Required default fund contributions depend on the risk
characteristics of the CCP
• CCPs with significant existing exposures across
products under a single netting agreement and strong
segregation services tend to lead to lower default fund
contribution and capital requirements
• CCPs with a large spectrum of eligible collateral, re-use
of other assets (e.g. GC pooling) and central bank
access mitigate funding issues for clients
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Solutions: Optimising Transaction Economics
14
§ Single legal cross product netting set
§ Capital efficient clearing models across securities finance,
repo and derivatives
§ Advanced netting and compression reduce gross notional
and balance sheet usage
§ Eurex Clearing Prisma: Live cross-product margining
§ Full fixed income rates curve across listed and OTC
§ Most comprehensive equity/index derivatives coverage
§ Product innovation continuously complementing fixed
income and equity product range
§ Largest spectrum of eligible collateral
§ Collateral transformation tools to increase the effective
supply of collateral
§ Collateral enhancement tools enable additional returns
§ Superior client asset protection models
§ Robust default management process with strong lines of
defense, increased dedicated amount of ECAG
§ Central bank access for investment and liquidity purposes to
ECB and SNB
Integrated CCP model
Eurex Clearing AG is the only fully integrated QCCP maximising capital, margin and collateral
efficiencies across instruments
Safety &
robustness
Margin
efficiency
Capital
efficiency
Collateral
efficiency
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Key
Challenges
Component Cross-product netting benefit Derivatives Securities financing
Listed OTC Repo Sec lending
Capital
RWA
• Netting of exposure at default across
different products under a single
legal CCP construct
Leverage
Ratio
• Netting of LR exposure across
different derivatives and different
securities financing transactions
under single legal CCP construct
Collateral &
Liquidity
Demand
(Margin)
• Netting of positions in liquidation
groups for initial margin across
products
• Variation margin netting across all
cleared products
Cross-product netting: enables participants to reduce exposures
across derivatives and securities financing transactions
15
Standardized
EAD calculation
Standardized EAD
calculation
Internal EAD modelling approach
Derivatives
exposure
calculation
Sec financing
exposure
calculation
Margin netting across derivatives
Cross-product netting opportunity
Enabledby
EurexPrisma
Enabledbyanintegrated
legalCCPconstruct
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
16
Agenda
• EMIR Mandatory OTC Clearing Timetable
• Role of CCP’s & Risk Management
• Client Asset Segregation & Protection
• OTC IRS & ETD Cross Margining Efficiencies
• ISA Direct Clearing Model – Direct Access for the Buy Side
• Securities Lending & Repo CCP
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
17
Segregation and portability has become increasingly
important because of client demand & regulation
EMIR article 39 requires CCPs and Clearing Members to offer at a minimum omnibus and individual
segregation models.
After the Lehman and MF Global defaults, the demand for segregation increased as clients have faced issues
around uncertainty of porting, double funding, mutualisation of client and CM risks from co-mingling of assets and
potential misuse of client collateral.
Individual models are intended to secure the positions and the collateral assets at all times in the event of
default of a Clearing Member or other clients of the clearing member.
Some local investment laws require asset managers to segregate assets at the fund level to prevent co-mingling
of positions and assets between the clearing broker, other clients and funds of the same fund company.
Both buy-side and sell-side clients are requesting protection from additional risks including transit and
liquidation risk.
ESMA finally provided clarity that individual client segregation requires that the actual assets of the client are
segregated and available for porting. Models which merely segregate the value of collateral due to the accounts of
clients, 'do not meet the requirement to offer individual client segregation’ (ESMA Q&A 5 August 2013).
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
18
1818
Agency
position
accounts
CM
Prop
account
RC/NCM
position
accounts
Individual
Segregated
Accounts (ISA)OSA by Value
RC/NCM
position
accounts
RC/NCM collateral
pool
CCP MR
net for all
P & M
accounts
CCP MR
per A
account
CCP MR
per
RC/NCM
CCP MR per
RC/NCM
Position
accounts
Margin
calculation
Eurex
Clearing
Collateral
pools
A single collateral pool is
maintained which dynamically
records proprietary and OSA by
value client collateral
OSA by Asset
And /or OSA under CASS*
Multiple OSAs*
Requires OSA by asset and is available under CASS
Agency
position
accounts
RC/NCM
position
accounts
CCP MR
per A
account
CCP MR
per
RC/NCM
Collateral pool for OSA
by asset
Collateral pool for OSA
under CASS
Agency
position
accounts
CCP MR per A
account
CCP MR
per
RC/NCM
MOSA collateral pool
by asset
MOSA collateral pool
under CASS
MOSA collateral pool
by asset
MOSA collateral pool
under CASS
CCP MR per
A account
* Securities collateral under omnibus segregation is held under pledge whilst ISA collateral is full title transfer to Eurex Clearing
**The OSA by asset and OSA under CASS models are operationally identical. The only difference is the later affords clients CASS protection.
OSA by value is the default
segregation model at Eurex
Clearing. Segregation is
achieved through reporting on
the books and records of Eurex
Clearing rather than on the CSD
level
When OSA by asset is chosen, a
separate collateral pool is opened at
Eurex Clearing and an account on
the CSD level. Specific securities and
cash are designated to the collateral
pool for all OSA by asset clients
and/or OSA under CASS.
When OSA by asset is chosen, CMs have the
option to open multiple omnibus collateral pools
at Eurex Clearing. This enables CMs to group
clients together. It is possible to have multiple
collateral pools protected under UK Client
money rules (OSA under CASS) or not (OSA by
asset).
Full physical
segregation of
positions and
collateral per client.
RC/NCM
position
accounts
RC/NCM
position
accounts
CM calls each client on a gross basis and can either post net or gross to Eurex Clearing. For the CM, disclosed clients (RC/NCM) are gross margined
Standard Omnibus Segregated Accounts (OSA)
Overview of Segregation Models at Eurex Clearing
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
The Individual Segregated Account structure provides the
highest level of protection and porting likelihood
19
• No fellow customer risk
• Highly likely porting
• Actual assets protected
• Allows full segregation at sub-fund
• 2 percent risk weight for trade and collateral exposures
• Asset tagging (optional)
• Direct transfer of collateral (optional)
• Later cash withdrawals for EUR and CHF
• All actual assets provided to Eurex Clearing are protected against
the default of another market participant
• This differs from value-based models where only a value equivalent
is protected instead of the client‘s actual assets
• Should there be a default, clients can choose to port immediately to
a Replacement Clearing Member or become an Interim Participant,
directly facing Eurex Clearing until a Replacement Clearing
Member is identified and accepts the port.
• Alternatively, clients can elect to closeout and directly receive their
collateral back
SafetyEfficiency
Protection of assets
and portability
ensures
• No replacement risk
• No liquidity risk
• No liquidation risk in
case of a Clearing
Member default
Position
account
Collateral
account
Cl Client
Cl1
ISA
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
20
Agenda
• EMIR Mandatory OTC Clearing Timetable
• Role of CCP’s & Risk Management
• Client Asset Segregation & Protection
• OTC IRS & ETD Cross Margining Efficiencies
• ISA Direct Clearing Model – Direct Access for the Buy Side
• Securities Lending & Repo CCP
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
21
Conceptual working of portfolio and cross margining
Portfolio margining accounts for netting effects and cross margining determines the
optimal combination of listed fixed income products with OTC IRS
Portfolio margining Cross margining
Euro Stoxx 50 futures
(short)
DAX futures
(long)
Margin reduction by
portfolio margining:
Portfolio
margining
benefit
• Cross margining allows for offsets between products
with different holding periods
• Eurex Clearing offers cross margining for OTC IRS (5
day holding period) and listed fixed income (FI)
products (2 day holding period)
• Listed FI positions are transferred to the OTC IRS split
such that the reduced risk is reflected in lower margins
IRS + FI
Allocation of
FI listed products
that hedge IRS exposure
FI only
Listed FI OTC IRS
Total (without
cross margining)
Cross-margined
portfolio
Margin requirementsMargin requirements
• Portfolio margining is applied to products
within the same liquidation group and
with the same holding period, e.g. Euro
Stoxx 50 and DAX futures
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Lower costs through cross margining OTC and listed
positions
Without cross margining With cross margining
IRS and fixed income futures/futures-style options are margined
separately:
• IRS with a 5 day liquidation horizon
• Futures and futures-style options with a proposed two day liquidation
horizon
OTC IRSFI listed products
IR swaps
FI futures /
futures-style
options
2 day horizon 5 day horizon
Margin requirements:
Futures/future-style options OTC IRS
If IRS and futures positions are hedged:
• Futures are transferred to the IRS split such that the reduced risk is
reflected in lower margins*
IRS+FI
IR swaps
FI fut./options
Allocation of
FI listed
products
that hedge IR
exposure
FI-only
FI futures /
futures-style
options
2 day horizon 5 day horizon
Margin reduction by cross margining:
Cross margined portfolio
Overall initial margins for cross margined portfolios can be lower reflecting the overall risk reduction
* Depending on portfolio diversity
22
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
23
Agenda
• EMIR Mandatory OTC Clearing Timetable
• Role of CCP’s & Risk Management
• Client Asset Segregation & Protection
• OTC IRS & ETD Cross Margining Efficiencies
• ISA Direct Clearing Model – Direct Access for the Buy Side
• Securities Lending & Repo CCP
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Concentration of risk in the US OTC Derivatives Clearing Business 1
Challenges
TOP 5
~70%
TOP 10
~95%
1 Source: http://www.cftc.gov/MarketReports/FinancialDataforFCMs/index.htm - *as of 30.09.2015
• Concentration is increasing. US
market structure is likely to
arise in Europe as well
• Limited balance sheet capacity
of many clearing brokers and
poor economics for client
clearing
• Porting of clients in crisis
massively at risk given
constraints of clearing brokers
to pick up clients
Significant negative implications including domino effects can be expected in a crisis,
as long as neither the capital rules nor the market structure changes
Derivatives market structure shows a strong concentration of risk to
the Top 10 Clearing Brokers
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Credit Suisse
Morgan Stanley
J.P. Morgan
Citigroup Global
Barclays Capital
Wells Fargo Securities
Goldman Sachs
Merrill Lynch
Deutsche Bank
UBS
TOTAL Initial Margin: ~ 56 BN US $*
24
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
2525© Oliver Wyman
Overview of ISA Direct model
25
ISA Direct model combines elements of direct clearing membership and the traditional service
relationship in client clearing, tailored specifically for the buy side.
Transaction
management
Cash
management
Collateral
management
• Default fund contribution
• Default management obligation
Client
Clearing
Member
ISA Direct
client
Clearing
Agent
Traditional client clearing ISA direct model
Optional transaction processing services between
Client and Clearing Member resp.
ISA Direct client and Clearing Agent
Clearing agent and clearing member core tasks
Direct contractual
relationship
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
ISA Direct – Direct Access for Client Clearing
26
ISA Direct client
Clearing Agent
CCP
Direct contractual relationship
Provision of operational
services* by Clearing Agent to
ISA Direct client
• Default Fund contribution
• Bidding obligation
Transaction
Management
Cash
Management
Collateral
Management
The solution
ISA Direct delivers a framework that is
operationally similar to a traditional
segregated client clearing relationship
under a different legal relationship.
1. Client becomes principal to the CCP
and directly clears trades
2. Clearing Agent facilitates operational
services*, and specific default
obligations
3. ISA Direct clients have to meet
admission criteria equivalent to
regular Clearing Members
In addition to improving market safety and
integrity, this results in a number of key
benefits to both parties:
Benefits for Clearing Agent
• Capital costs substantially reduced (LR, RWA)
• Allows maintenance of client relationship and delivery of
a range of clearing services
• Increased default fund contributions for ISA Direct
Member and Eurex Clearing’s dedicated amount create
layers of protection before loss mutualisation
Benefits for ISA Direct Client
• No default fund contribution
• Assets are segregated, securities under pledge
• Collateral eligibility >17,000 ISINs
• Porting issues removed, appointment of new Clearing
Agent in default scenario
• Relieves concentration of CMs offering client clearing
New regulations are impacting costs and access to clearing for non members
*operational services can be performed by the Agent or the ISA Direct client
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Derivatives: Capital costs for providing (client) clearing services can
be substantially reduced via direct clearing models
Capital cost of clearing agent (bps of IM)
Clearing
agent
CCPClient
Exposure
IM
DF
IM
Exposure
~80%+
Capital costs for providing default fund
(only applies if clearing agent provides
default fund, otherwise this is a direct
costs for the client)
27
Client clearing
Direct clearing
Leverage
ratio
RWA
Leverage
ratio
RWA
Banks can take on a range of roles, enabling them to retain and service client relationships
CCPClient
Exposure
IM
DF
Trading activity
Clearing
agent
Derivatives clearing models and corresponding annual capital costs for a clearing agent
Example based on ~5 year duration, directional EUR IRS swap portfolio
~85%-95%+
~25-701
~14
~3
~3
1. Depends on final leverage ratio rule (use of SA-CCR with collateral offset leads to reduced costs of ~25 bps vs. ~70 bps based on current proposal with CEM
Note: Requirements are foreseen to only allow direct access for clients of high credit quality (requiring credit assessments required for each new clearing license, discussed within the
Eurex Clearing Credit Committee, signed-off by the Eurex Clearing Executive board)
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
28
Agenda
• EMIR Mandatory OTC Clearing Timetable
• Role of CCP’s & Risk Management
• Client Asset Segregation & Protection
• OTC IRS & ETD Cross Margining Efficiencies
• ISA Direct Clearing Model – Direct Access for the Buy Side
• Securities Lending & Repo CCP
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Lending CCP – our service for Securities Lending
The solution
Eurex Clearing offers a CCP service for the securities lending
market, strengthening our commitment to reducing systemic
risk and ensuring the safety of the market overall. By retaining
the bi-lateral trading relationship, existing market relationships
are preserved. It also delivers other key benefits:
• Efficient use of borrower’s capital (RWA, CVA, netting)
• Agency and Principal roles for Lenders
• Simplifies a multiple counterparty credit structure to a
single CCP relation
• Operational efficiency via CCP managed post-trade
services
• Enhanced default management protection by the CCP
• CCP risk management approved by regulatory authorities
• Re-use of existing infrastructure to allow for a wider
distribution of counterparts
• Flexible collateral schedules allowing for optimization of
collateral Post trade functionality
• Loan Deliveries, Mark-to-Marks, Re-rates, Recalls,
Returns, Buy-ins
• Corporate Actions, dividend payments
• Automated billing (lending fees & rebates)
Principal collateral > 30,000 ISINs
• Cash (EUR, USD),
• Bonds, Equities and ETFs
Markets > 25,000 ISINs
• Fixed income – European government, supra, corporate
bonds
• Equities – coverage of key European markets
• Exchange Traded Funds (ETFs)
Risk considerations and operational efficiencies are driving change
Securities lending market participants
Eurex Clearing Lending CCP
Bilateral market (OTC) Electronic SL trading platforms
Eurex Repo-SecLend MarketFlow Providers & Trade Capture Platforms
Central Securities Depositories
International Central Securities
Depositories
29
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
Lending CCP – Specific Lender License
30
The solution
The Specific Lender License facilitates lending only participants (beneficial owners) the ability to
remain as principal via a direct relationship with the CCP and the Agent Lender remains as an
account operator as agent. It also delivers other key benefits:
• No requirement to clear through a GCM, pay margin or default fund contribution
• Existing relationships with Lending Agents are maintained
• Agent Lender continues to arrange loans for CCP eligible transactions
• Operational links with flow provider and CCP maintained by Agent Lender
• Agent Lender reports loans and collateral through existing reporting set
• Simplifies multiple counterparty credit structure to a single CCP
• Transparent and standardized risk management and default procedures approved by
regulators
• Access a wider distribution of counterparts via one legal framework
• Flexible collateral schedules allow optimization of collateral
• Reduction of Agent Lender’s indemnification costs
Allowing Beneficial Owners to participate directly with a CCP
CCPs for Securities
Lending deliver:
• Effective use of capital
• Better terms
• Credit intermediation
• Risk mitigation
• Increased utilization
• Operational efficiency
• Collateral optimization
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
GC Pooling Select – Invest and Finance
31
Direct clearing models link supply with demand in a capital efficient way
The solution
Direct CCP clearing models are the
catalyst to eliminate exposure between
client and bank in existing bilateral and
tri-party models. As an integrated CCP,
Eurex Clearing offers tailored clearing
licenses for buy side customers to gain
direct access to the repo CCP markets.
Eurex Clearing’s integrated securities
financing service enables collateral
availability, liquidity and fluidity for all
market participants.
GC Pooling Select Finance
• Accommodates access to CCP cleared secured funding
and investments for buy side
• By leveraging proven GC Pooling infrastructure buy side
clients are enabled to perform collateral transformation
for cash margin coverage, specifically VM funding for
pension funds and asset managers
• Delivered via the ISA Direct clearing membership, buy
side participants can gain access via a Clearing Agent
GC Pooling Select Invest
• Facilitates secured deposits and delivers a substantial
reduction in the credit and liquidity risks of lending
unsecured
• is available for non-banks, such as corporates or
insurance companies, wishing to invest cash on a
secured basis with a CCP
• No default fund or initial margin
• No access to clearing systems required
GC Pooling and Repo market: benchmark for secured funding and financing
GC Pooling and Repo
Sell Side
GC Pooling
Buy Side
EUR USDGBP*
Select Invest
(EUR)
Select Finance
(CHF, EUR, GBP**, USD)
Cash provider and cash taker
Banks, brokers, central banks, finance agencies,
supranational organisations
Corporates, pension funds, asset managers, insurance
companies
Net cash provider
Cash provider and cash
taker
Fully comply with Eurex Clearing’s
clearing conditions
Unique set up:
• No default fund
• No initial margin
• No access to clearing
systems required
ISA Direct clients:
• Principal to CCP
• Must meet admission
criteria equivalent CM
• Clearing Agent
provides services
*GBP will be launched in Q216; ** GBP will be available under Select Finance in Q316
CHF
GC Pooling and Repo
Buy Side
www.eurexclearing.com
Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016
32
© Eurex 2016
Deutsche Börse AG (DBAG), Clearstream Banking AG (Clearstream), Eurex Frankfurt AG, Eurex Clearing AG (Eurex Clearing) as well as Eurex Bonds GmbH (Eurex Bonds) and Eurex
Repo GmbH (Eurex Repo) are corporate entities and are registered under German law. Eurex Zürich AG is a corporate entity and is registered under Swiss law. Clearstream Banking
S.A. is a corporate entity and is registered under Luxembourg law. U.S. Exchange Holdings, Inc. and International Securities Exchange Holdings, Inc. (ISE) are corporate entities and
are registered under U.S. American law. Eurex Frankfurt AG (Eurex) is the administrating and operating institution of Eurex Deutschland. Eurex Deutschland and Eurex Zürich AG are in
the following referred to as the “Eurex Exchanges”.
All intellectual property, proprietary and other rights and interests in this publication and the subject matter hereof (other than certain trademarks and service marks listed below) are
owned by DBAG and its affiliates and subsidiaries including, without limitation, all patent, registered design, copyright, trademark and service mark rights. While reasonable care has
been taken in the preparation of this publication to provide details that are accurate and not misleading at the time of publication DBAG, Clearstream, Eurex, Eurex Clearing, Eurex
Bonds, Eurex Repo as well as the Eurex Exchanges and their respective servants and agents (a) do not make any representations or warranties regarding the information contained
herein, whether express or implied, including without limitation any implied warranty of merchantability or fitness for a particular purpose or any warranty with respect to the accuracy,
correctness, quality, completeness or timeliness of such information, and (b) shall not be responsible or liable for any third party’s use of any information contained herein under any
circumstances, including, without limitation, in connection with actual trading or otherwise or for any errors or omissions contained in this publication.
This publication is published for information purposes only and shall not constitute investment advice respectively does not constitute an offer, solicitation or recommendation to acquire
or dispose of any investment or to engage in any other transaction. This publication is not intended for solicitation purposes but only for use as general information. All descriptions,
examples and calculations contained in this publication are for illustrative purposes only.
Eurex and Eurex Clearing offer services directly to members of the Eurex exchanges respectively to clearing members of Eurex Clearing. Those who desire to trade any products
available on the Eurex market or who desire to offer and sell any such products to others or who desire to possess a clearing license of Eurex Clearing in order to participate in the
clearing process provided by Eurex Clearing, should consider legal and regulatory requirements of those jurisdictions relevant to them, as well as the risks associated with such
products, before doing so.
Eurex derivatives are currently not available for offer, sale or trading in the United States or by United States persons (other than EURO STOXX 50® Index Futures, EURO STOXX 50®
ex Financials Index Futures, EURO STOXX® Select Dividend 30 Index Futures, EURO STOXX® Index Futures, EURO STOXX® Large/Mid/Small Index Futures, STOXX® Europe 50
Index Futures, STOXX® Europe 600 Index Futures, STOXX® Europe 600 Banks/Industrial Goods & Services/Insurance/Media/Travel & Leisure/Utilities Futures, STOXX® Europe
Large/Mid/Small 200 Index Futures, Dow Jones Global Titans 50 IndexSM Futures (EUR & USD), DAX®/MDAX®/TecDAX® Futures, SMIM® Futures, SLI Swiss Leader Index® Futures,
MSCI World/Europe/Japan/AC Asia Pacific ex Japan Index Futures and VSTOXX® Futures as well as Eurex inflation/commodity/weather/property and interest rate derivatives).
Trademarks and Service Marks
Buxl®, DAX®, DivDAX®, eb.rexx®, Eurex®, Eurex Bonds®, Eurex Repo®, Eurex Strategy WizardSM, Euro GC Pooling®, FDAX®, FWB®, GC Pooling®,,GCPI®, MDAX®, ODAX®, SDAX®,
TecDAX®, USD GC Pooling®, VDAX®, VDAX-NEW® and Xetra® are registered trademarks of DBAG. Phelix Base® and Phelix Peak® are registered trademarks of European Energy
Exchange AG (EEX). All MSCI indexes are service marks and the exclusive property of MSCI Barra. RDX® is a registered trademark of Vienna Stock Exchange AG.
IPD® UK Annual All Property Index is a registered trademark of Investment Property Databank Ltd. IPD and has been licensed for the use by Eurex for derivatives. SLI®, SMI® and
SMIM® are registered trademarks of SIX Swiss Exchange AG.
The STOXX® indexes, the data included therein and the trademarks used in the index names are the intellectual property of STOXX Limited and/or its licensors Eurex derivatives based
on the STOXX® indexes are in no way sponsored, endorsed, sold or promoted by STOXX and its licensors and neither STOXX nor its licensors shall have any liability with respect
thereto.
Dow Jones, Dow Jones Global Titans 50 IndexSM and Dow Jones Sector Titans IndexesSM are service marks of Dow Jones & Company, Inc. Dow Jones-UBS Commodity IndexSM and
any related sub-indexes are service marks of Dow Jones & Company, Inc. and UBS AG. All derivatives based on these indexes are not sponsored, endorsed, sold or promoted by Dow
Jones & Company, Inc. or UBS AG, and neither party makes any representation regarding the advisability of trading or of investing in such products.
All references to London Gold and Silver Fixing prices are used with the permission of The London Gold Market Fixing Limited as well as The London Silver Market Fixing Limited,
which for the avoidance of doubt has no involvement with and accepts no responsibility whatsoever for the underlying product to which the Fixing prices may be referenced.
PCS® and Property Claim Services® are registered trademarks of ISO Services, Inc.
Korea Exchange, KRX, KOSPI and KOSPI 200 are registered trademarks of Korea Exchange Inc.
BSE and SENSEX are trademarks/service marks of Bombay Stock Exchange (BSE) and all rights accruing from the same, statutory or otherwise, wholly vest with BSE. Any violation of
the above would constitute an offence under the laws of India and international treaties governing the same.
The names of other companies and third party products may be trademarks or service marks of their respective owners.

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Bloomberg and the Union of Arab Securities Authorities Roundtable Dubai September 2016

  • 1. Bloomberg & The Union of Arab Securities Authorities Rountable 7 – 8 September 2016 What are CCPs and how do they operate under new European regulations?
  • 2. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 2 Agenda • EMIR Mandatory OTC Clearing Timetable • Role of CCP’s & Risk Management • Client Asset Segregation & Protection • OTC IRS & ETD Cross Margining Efficiencies • ISA Direct Clearing Model – Direct Access for the Buy Side • Securities Lending & Repo CCP
  • 3. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 33© Oliver Wyman Scope Frontloading The clearing obligation takes effect on: • June 21, 2016 for Category 1 • December 21, 2016 for Category 2 • June 21, 2017 for Category 3 • December 21, 2018 for Category 4 Description Implementation status Additional Points • The RTS includes a three-year phase-in mechanism to deal with intragroup transactions. • It also allows funds to calculate the aggregate average outstanding gross notional amount of non- centrally cleared derivatives individually at a fund level for calculating the threshold used to determine the clearing category of such entity. Regulatory update: EMIR Mandatory Clearing • Interest Rate Swaps (fixed to float, basis, FRA’s and OIS swaps phased in for 4 counterparty categories • Category 1 entities have a phase-in period of six months; • Category 2 entities a phase-in of 12 months; • Category 3 entities a phase in of 18 months; and • Category 4 entities a phase-in of 36 months. The frontloading obligation takes effect: • February 21, 2016 for Category 1 • May 21, 2016 for Category 2 • The frontloading obligation will only apply to Category 1 and Category 2 entities. • Frontloading doesn’t apply to non-financial counterparties (NFCs). • the minimum remaining maturity for Category 3 entities has been set at a level to exclude all trades from the frontloading requirement. 3 EC published G4 rates clearing obligation in the Official Journal on 1st December 2015 – The RTS will come into force on 21 December 2015
  • 4. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 4 Agenda • EMIR Mandatory OTC Clearing Timetable • Role of CCP’s & Risk Management • Client Asset Segregation & Protection • OTC IRS & ETD Cross Margining Efficiencies • ISA Direct Clearing Model – Direct Access for the Buy Side • Securities Lending & Repo CCP
  • 5. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 5 CCP services improve soundness of market infrastructure and strengthen market integrity Reduced systemic risk • CCP takes over counterparty risk through trade novation • CCP enforces strict risk control and adequate collateralisation of open positions • Automatic multilateral netting reduces gross risk exposure Benefits of multilateral clearing with Central Counterparty 1 Increased transparency • Awareness of concentration risk • Independent position valuation by neutral institution • Early warning function by daily mark-to- market Efficiency gains • Full automation and straight-through processing reduces manual errors • Efficient use and management of collateral • Increased capital efficiency by reduced balance sheet exposure Bilateral trading & clearing Current OTC market structure- 1:n relationship Bilateral trading & multilateral clearing CCP market structure - 1:1 relationships between CM and CCP B C A E D OTC CCP F A FD C B E 2 3
  • 6. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 There are two basic models to trade OTC derivatives Bilateral OTC model Centrally cleared OTC model Description • Bilateral models are the traditional form of OTC transactions and take place between two parties • Two parties enter a OTC transaction and bear the counterparty credit risk of each other • During the life of the trade the parties exchange variation margins (VM) to account for market value changes • In most instances initial margins (IM) to account for potential future exposure (PFE) have to be exchanged • In a centrally cleared OTC transaction, a central counterparty (CCP) steps in between the two parties • The initial arrangement between the two parties is replaced by two agreements on identical economic terms (“novation”), each with the CCP and one of the parties • As a result the CCP administers the transactions, manages the collateral and also the counterparty credit risk • Both parties have to post initial and variation margins to the CCP 6 Schematic illustration Party A Party B Bilateral agreement CCP Bilateral agreement Party A Party BX Bilateral agreement
  • 7. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Eurex Clearing Lines of Defence Eurex Clearing’s guiding principle in a default situation is to minimize the effect on the Lines of Defence and to stabilize the markets 7 • Eurex Clearing provides a multi-level security system − First the collateral and the Clearing Fund contribution of the member in default are utilized. − After the defaulter’s contributions are exhausted, an assigned dedicated amount of Eurex Clearing is applied, before non-defaulting clearing members’ Clearing Fund contributions, and remaining capital of Eurex Clearing are used. • Each clearing member’s contribution to the Clearing Fund is based on a minimum contribution and a dynamic component, accounting for the individual clearing member’s risk situation. • There is one segmented Clearing Fund for listed and OTC business. • Following a realization of any Clearing Fund contributions of non- defaulted clearing members, such clearing members are asked to provide assessments to their contributions. • Clearing members’ total liability is limited as they have to provide a maximum of two assessments per capped period. Remaining Capital of Eurex Clearing Parental Guarantee Max 2 Assessments per Clearing Member Eurex Clearing Lines of Defense Clearing Fund Contribution of Other Clearing Members Dedicated Amount of Eurex Clearing Clearing Fund Contribution of Clearing Member in Default Collateral of Clearing Member in Default Position Netting
  • 8. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Key focus of stress testing is sizing the Default Fund Default Fund size is determined regularly based on a “cover 2” scenario Default Fund contribution is the highest amount of: • 7% of average IM requirements (30 days), or • 7% of average IM requirements (250 days), or • GCM: EUR 5 m, DCM: EUR 1 m 8 • The Default Fund contribution of a Clearing Member is determined as a percentage of the Initial Margin requirement • A quarterly recalibration of the Default Fund and a regular review of the adequacy of the Default Fund size and methodology take place • Results are presented to senior management and the Risk Committee • Sufficiency of the Default Fund to cover the 2 largest defaulting Clearing Members simultaneously with market stress is validated daily • Both historical and hypothetical scenarios are used for Default Fund dimensioning • If stress test results indicate that the Default Fund is not sufficient then: – Global percentage can be recalibrated, or – Member-specific actions can be taken - 500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 Hypothetical scenarios Historical scenarios Default Fund
  • 9. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 9 Eurex Clearing’s guiding principle in a default situation is to minimize the effect on the lines of defense and stabilize the markets Remaining Capital of Eurex Clearing AG Parental Guarantee Max 2 assessments per CM Clearing Fund Contribution of Other Members Dedicated amount of Eurex Clearing AG Clearing Fund Contribution of Member in Default Collateral of Member in Default Position Netting Eurex Clearing provides a multi-level safety system Lines of defense • First the collaterals and the clearing fund contribution of the member in default are utilized. • After the defaulters contribution is exhausted assigned dedicated amount of Eurex Clearing AG is applied before non-defaulting clearing members contribution and remaining capital of Eurex Clearing AG. • The contribution to the Clearing Fund is based on a minimum contribution and a dynamic component accounting for the individual clearing member’s risk situation. • Following a realization of any contributions to the Clearing Fund of the non-defaulted clearing members, such clearing members are asked to provide assessments to their contribution. • Clearing members’ total liability is limited as they have to provide maximum two assessments per capped period. • The creation of liquidation group specific clearing fund segments (CFS), within the single common clearing fund. • CFS are determined for each liquidation group. A CFS is a partition of the single clearing fund according to the relative weights of the initial margin of the Liquidation Groups. • When liquidating a particular Liquidation Group, only the respective CFS can be used to cover losses, unless there is a known surplus from other, already completed Liquidation Groups. Segmentation of the clearing fund Remaining Capital of Eurex Clearing AG Parental Guarantee Max 2 assessments per CM Clearing Fund Contribution of Other Members Dedicated amount of Eurex Clearing AG Clearing Fund Contribution of Member in Default Collateral of Member in Default Position Netting Lines of defense
  • 10. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Default Management Process reflects best practice and complies with market requirements and regulatory guidelines 10 Overview of Default Management Process •Preliminary Measures • Convention of Default Management Committees to support Eurex Clearing throughout the whole DMP • To protect client assets, positions and collateral are transferred wherever possible • Portfolio and market evaluation in preparation of liquidation • Handling positions that expire shortly •Hedging • Hedging of the defaulted clearing member’s portfolio is executed as early as possible, to limit losses immediately • Hedged portfolio is likely to receive better prices in the auction •Independent Sale • If the portfolio is small or only few clearing members are active in the involved products then bilateral or on- exchange trades can ensure a timely liquidation • Mutual clearing fund will not be utilised, unless all clearing members have the chance to provide a price in the auction •Auction • Participation in auctions is mandatory for those clearing members who are capable from an operational and risk perspective to process the respective portfolio • Clients are allowed to bid via their clearing member • Clearing fund juniorisation and penalty fee set incentives for competitive bidding Holding period serves as basis for risk calculation within Eurex Clearing
  • 11. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Overview of major areas within CCP Risk Management 11 Counterparty Assessment • Eurex Clearing has strict criteria for counterparties to guarantee that clearing members, payment banks, treasury counterparts have sufficient credit quality and financial strength • Credit assessments are repeated on a regular basis Margining Stress Testing • Additional post-default backings are available to cover risks beyond the margin confidence level • The adequacy of the Clearing Fund size, Eurex Clearing’s total financial resources and liquid financial resources is verified by means of stress tests • Margin requirements are aimed to cover potential losses arising during the default management process according to the “defaulter pays” scheme • Margin requirements are monitored and enforced intraday Collateral and Member Monitoring Default Management Process • Eurex Clearing only accepts secure, liquid and accessible collateral with low credit risk • A comprehensive risk management framework has been established in order to identify, manage and control credit, concentration and wrong way risks • When a Clearing Member goes into default, one of Eurex Clearing’s principle objectives is to protect customers and minimize harm to clients and their positions • Losses to the CCP’s lines of defense and the disruption of the wider market are minimized Eurex Clearing’s Risk Management Framework
  • 12. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 • Aligned default management process across a Clearing Member’s positions • Positions deemed suitable for simultaneous liquidation are logically assigned to the same Liquidation Group • Risk offsets are only granted within the same Liquidation Group (e.g. Equity, Commodity or Fixed Income) Consistency 4 2 3Central benefits • Adjustments to enable stable margin requirements: concentration, uncertainty in correlations, model adjustments if compression is used • Flooring for stability: Stressed period scenarios and dynamic volatility scaling to at least long run volatility percentiles Stability • More accurate risk netting effects than legacy risk models • Higher capital efficiency for customers through risk calculation on a portfolio basis Capital Efficiency • Reduced time-to-market for new productsFlexibility 1 5 • Cross-product scenarios enable consistent way to account for portfolio correlation and diversification effects • Risk covered at high confidence level through margin calculation consisting of a − Mark to market component − Forward looking component − Adequate liquidation time horizon Accuracy Eurex Clearing employs a state-of-the-art margin method Several benefits are derived through the methodical cornerstones of Eurex Clearing’s portfolio margining model methodology, PRISMA 12
  • 13. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 1313© Oliver Wyman Cost efficiencies may vary substantially across CCPs along 3 key drivers 13 An integrated cross-product CCP with a large eligible collateral spectrum entails the highest efficiency potential for customers Netting efficiency Default fund efficiency Collateral efficiency 1 2 3 • Multilateral risk netting may be complemented by cross- product exposure netting (& cross-margining) between OTC, exchange-traded and cleared repo transactions • Netting of positions in liquidation groups for initial margin and balance sheet netting of exposure at default under a single legal CCP construct Higher netting efficiency lowers capital and funding requirements Higher default fund efficiency lowers capital and funding requirements Higher collateral efficiency lowers funding requirements • Required default fund contributions depend on the risk characteristics of the CCP • CCPs with significant existing exposures across products under a single netting agreement and strong segregation services tend to lead to lower default fund contribution and capital requirements • CCPs with a large spectrum of eligible collateral, re-use of other assets (e.g. GC pooling) and central bank access mitigate funding issues for clients
  • 14. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Solutions: Optimising Transaction Economics 14 § Single legal cross product netting set § Capital efficient clearing models across securities finance, repo and derivatives § Advanced netting and compression reduce gross notional and balance sheet usage § Eurex Clearing Prisma: Live cross-product margining § Full fixed income rates curve across listed and OTC § Most comprehensive equity/index derivatives coverage § Product innovation continuously complementing fixed income and equity product range § Largest spectrum of eligible collateral § Collateral transformation tools to increase the effective supply of collateral § Collateral enhancement tools enable additional returns § Superior client asset protection models § Robust default management process with strong lines of defense, increased dedicated amount of ECAG § Central bank access for investment and liquidity purposes to ECB and SNB Integrated CCP model Eurex Clearing AG is the only fully integrated QCCP maximising capital, margin and collateral efficiencies across instruments Safety & robustness Margin efficiency Capital efficiency Collateral efficiency
  • 15. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Key Challenges Component Cross-product netting benefit Derivatives Securities financing Listed OTC Repo Sec lending Capital RWA • Netting of exposure at default across different products under a single legal CCP construct Leverage Ratio • Netting of LR exposure across different derivatives and different securities financing transactions under single legal CCP construct Collateral & Liquidity Demand (Margin) • Netting of positions in liquidation groups for initial margin across products • Variation margin netting across all cleared products Cross-product netting: enables participants to reduce exposures across derivatives and securities financing transactions 15 Standardized EAD calculation Standardized EAD calculation Internal EAD modelling approach Derivatives exposure calculation Sec financing exposure calculation Margin netting across derivatives Cross-product netting opportunity Enabledby EurexPrisma Enabledbyanintegrated legalCCPconstruct
  • 16. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 16 Agenda • EMIR Mandatory OTC Clearing Timetable • Role of CCP’s & Risk Management • Client Asset Segregation & Protection • OTC IRS & ETD Cross Margining Efficiencies • ISA Direct Clearing Model – Direct Access for the Buy Side • Securities Lending & Repo CCP
  • 17. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 17 Segregation and portability has become increasingly important because of client demand & regulation EMIR article 39 requires CCPs and Clearing Members to offer at a minimum omnibus and individual segregation models. After the Lehman and MF Global defaults, the demand for segregation increased as clients have faced issues around uncertainty of porting, double funding, mutualisation of client and CM risks from co-mingling of assets and potential misuse of client collateral. Individual models are intended to secure the positions and the collateral assets at all times in the event of default of a Clearing Member or other clients of the clearing member. Some local investment laws require asset managers to segregate assets at the fund level to prevent co-mingling of positions and assets between the clearing broker, other clients and funds of the same fund company. Both buy-side and sell-side clients are requesting protection from additional risks including transit and liquidation risk. ESMA finally provided clarity that individual client segregation requires that the actual assets of the client are segregated and available for porting. Models which merely segregate the value of collateral due to the accounts of clients, 'do not meet the requirement to offer individual client segregation’ (ESMA Q&A 5 August 2013).
  • 18. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 18 1818 Agency position accounts CM Prop account RC/NCM position accounts Individual Segregated Accounts (ISA)OSA by Value RC/NCM position accounts RC/NCM collateral pool CCP MR net for all P & M accounts CCP MR per A account CCP MR per RC/NCM CCP MR per RC/NCM Position accounts Margin calculation Eurex Clearing Collateral pools A single collateral pool is maintained which dynamically records proprietary and OSA by value client collateral OSA by Asset And /or OSA under CASS* Multiple OSAs* Requires OSA by asset and is available under CASS Agency position accounts RC/NCM position accounts CCP MR per A account CCP MR per RC/NCM Collateral pool for OSA by asset Collateral pool for OSA under CASS Agency position accounts CCP MR per A account CCP MR per RC/NCM MOSA collateral pool by asset MOSA collateral pool under CASS MOSA collateral pool by asset MOSA collateral pool under CASS CCP MR per A account * Securities collateral under omnibus segregation is held under pledge whilst ISA collateral is full title transfer to Eurex Clearing **The OSA by asset and OSA under CASS models are operationally identical. The only difference is the later affords clients CASS protection. OSA by value is the default segregation model at Eurex Clearing. Segregation is achieved through reporting on the books and records of Eurex Clearing rather than on the CSD level When OSA by asset is chosen, a separate collateral pool is opened at Eurex Clearing and an account on the CSD level. Specific securities and cash are designated to the collateral pool for all OSA by asset clients and/or OSA under CASS. When OSA by asset is chosen, CMs have the option to open multiple omnibus collateral pools at Eurex Clearing. This enables CMs to group clients together. It is possible to have multiple collateral pools protected under UK Client money rules (OSA under CASS) or not (OSA by asset). Full physical segregation of positions and collateral per client. RC/NCM position accounts RC/NCM position accounts CM calls each client on a gross basis and can either post net or gross to Eurex Clearing. For the CM, disclosed clients (RC/NCM) are gross margined Standard Omnibus Segregated Accounts (OSA) Overview of Segregation Models at Eurex Clearing
  • 19. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 The Individual Segregated Account structure provides the highest level of protection and porting likelihood 19 • No fellow customer risk • Highly likely porting • Actual assets protected • Allows full segregation at sub-fund • 2 percent risk weight for trade and collateral exposures • Asset tagging (optional) • Direct transfer of collateral (optional) • Later cash withdrawals for EUR and CHF • All actual assets provided to Eurex Clearing are protected against the default of another market participant • This differs from value-based models where only a value equivalent is protected instead of the client‘s actual assets • Should there be a default, clients can choose to port immediately to a Replacement Clearing Member or become an Interim Participant, directly facing Eurex Clearing until a Replacement Clearing Member is identified and accepts the port. • Alternatively, clients can elect to closeout and directly receive their collateral back SafetyEfficiency Protection of assets and portability ensures • No replacement risk • No liquidity risk • No liquidation risk in case of a Clearing Member default Position account Collateral account Cl Client Cl1 ISA
  • 20. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 20 Agenda • EMIR Mandatory OTC Clearing Timetable • Role of CCP’s & Risk Management • Client Asset Segregation & Protection • OTC IRS & ETD Cross Margining Efficiencies • ISA Direct Clearing Model – Direct Access for the Buy Side • Securities Lending & Repo CCP
  • 21. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 21 Conceptual working of portfolio and cross margining Portfolio margining accounts for netting effects and cross margining determines the optimal combination of listed fixed income products with OTC IRS Portfolio margining Cross margining Euro Stoxx 50 futures (short) DAX futures (long) Margin reduction by portfolio margining: Portfolio margining benefit • Cross margining allows for offsets between products with different holding periods • Eurex Clearing offers cross margining for OTC IRS (5 day holding period) and listed fixed income (FI) products (2 day holding period) • Listed FI positions are transferred to the OTC IRS split such that the reduced risk is reflected in lower margins IRS + FI Allocation of FI listed products that hedge IRS exposure FI only Listed FI OTC IRS Total (without cross margining) Cross-margined portfolio Margin requirementsMargin requirements • Portfolio margining is applied to products within the same liquidation group and with the same holding period, e.g. Euro Stoxx 50 and DAX futures
  • 22. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Lower costs through cross margining OTC and listed positions Without cross margining With cross margining IRS and fixed income futures/futures-style options are margined separately: • IRS with a 5 day liquidation horizon • Futures and futures-style options with a proposed two day liquidation horizon OTC IRSFI listed products IR swaps FI futures / futures-style options 2 day horizon 5 day horizon Margin requirements: Futures/future-style options OTC IRS If IRS and futures positions are hedged: • Futures are transferred to the IRS split such that the reduced risk is reflected in lower margins* IRS+FI IR swaps FI fut./options Allocation of FI listed products that hedge IR exposure FI-only FI futures / futures-style options 2 day horizon 5 day horizon Margin reduction by cross margining: Cross margined portfolio Overall initial margins for cross margined portfolios can be lower reflecting the overall risk reduction * Depending on portfolio diversity 22
  • 23. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 23 Agenda • EMIR Mandatory OTC Clearing Timetable • Role of CCP’s & Risk Management • Client Asset Segregation & Protection • OTC IRS & ETD Cross Margining Efficiencies • ISA Direct Clearing Model – Direct Access for the Buy Side • Securities Lending & Repo CCP
  • 24. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Concentration of risk in the US OTC Derivatives Clearing Business 1 Challenges TOP 5 ~70% TOP 10 ~95% 1 Source: http://www.cftc.gov/MarketReports/FinancialDataforFCMs/index.htm - *as of 30.09.2015 • Concentration is increasing. US market structure is likely to arise in Europe as well • Limited balance sheet capacity of many clearing brokers and poor economics for client clearing • Porting of clients in crisis massively at risk given constraints of clearing brokers to pick up clients Significant negative implications including domino effects can be expected in a crisis, as long as neither the capital rules nor the market structure changes Derivatives market structure shows a strong concentration of risk to the Top 10 Clearing Brokers 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Credit Suisse Morgan Stanley J.P. Morgan Citigroup Global Barclays Capital Wells Fargo Securities Goldman Sachs Merrill Lynch Deutsche Bank UBS TOTAL Initial Margin: ~ 56 BN US $* 24
  • 25. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 2525© Oliver Wyman Overview of ISA Direct model 25 ISA Direct model combines elements of direct clearing membership and the traditional service relationship in client clearing, tailored specifically for the buy side. Transaction management Cash management Collateral management • Default fund contribution • Default management obligation Client Clearing Member ISA Direct client Clearing Agent Traditional client clearing ISA direct model Optional transaction processing services between Client and Clearing Member resp. ISA Direct client and Clearing Agent Clearing agent and clearing member core tasks Direct contractual relationship
  • 26. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 ISA Direct – Direct Access for Client Clearing 26 ISA Direct client Clearing Agent CCP Direct contractual relationship Provision of operational services* by Clearing Agent to ISA Direct client • Default Fund contribution • Bidding obligation Transaction Management Cash Management Collateral Management The solution ISA Direct delivers a framework that is operationally similar to a traditional segregated client clearing relationship under a different legal relationship. 1. Client becomes principal to the CCP and directly clears trades 2. Clearing Agent facilitates operational services*, and specific default obligations 3. ISA Direct clients have to meet admission criteria equivalent to regular Clearing Members In addition to improving market safety and integrity, this results in a number of key benefits to both parties: Benefits for Clearing Agent • Capital costs substantially reduced (LR, RWA) • Allows maintenance of client relationship and delivery of a range of clearing services • Increased default fund contributions for ISA Direct Member and Eurex Clearing’s dedicated amount create layers of protection before loss mutualisation Benefits for ISA Direct Client • No default fund contribution • Assets are segregated, securities under pledge • Collateral eligibility >17,000 ISINs • Porting issues removed, appointment of new Clearing Agent in default scenario • Relieves concentration of CMs offering client clearing New regulations are impacting costs and access to clearing for non members *operational services can be performed by the Agent or the ISA Direct client
  • 27. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Derivatives: Capital costs for providing (client) clearing services can be substantially reduced via direct clearing models Capital cost of clearing agent (bps of IM) Clearing agent CCPClient Exposure IM DF IM Exposure ~80%+ Capital costs for providing default fund (only applies if clearing agent provides default fund, otherwise this is a direct costs for the client) 27 Client clearing Direct clearing Leverage ratio RWA Leverage ratio RWA Banks can take on a range of roles, enabling them to retain and service client relationships CCPClient Exposure IM DF Trading activity Clearing agent Derivatives clearing models and corresponding annual capital costs for a clearing agent Example based on ~5 year duration, directional EUR IRS swap portfolio ~85%-95%+ ~25-701 ~14 ~3 ~3 1. Depends on final leverage ratio rule (use of SA-CCR with collateral offset leads to reduced costs of ~25 bps vs. ~70 bps based on current proposal with CEM Note: Requirements are foreseen to only allow direct access for clients of high credit quality (requiring credit assessments required for each new clearing license, discussed within the Eurex Clearing Credit Committee, signed-off by the Eurex Clearing Executive board)
  • 28. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 28 Agenda • EMIR Mandatory OTC Clearing Timetable • Role of CCP’s & Risk Management • Client Asset Segregation & Protection • OTC IRS & ETD Cross Margining Efficiencies • ISA Direct Clearing Model – Direct Access for the Buy Side • Securities Lending & Repo CCP
  • 29. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Lending CCP – our service for Securities Lending The solution Eurex Clearing offers a CCP service for the securities lending market, strengthening our commitment to reducing systemic risk and ensuring the safety of the market overall. By retaining the bi-lateral trading relationship, existing market relationships are preserved. It also delivers other key benefits: • Efficient use of borrower’s capital (RWA, CVA, netting) • Agency and Principal roles for Lenders • Simplifies a multiple counterparty credit structure to a single CCP relation • Operational efficiency via CCP managed post-trade services • Enhanced default management protection by the CCP • CCP risk management approved by regulatory authorities • Re-use of existing infrastructure to allow for a wider distribution of counterparts • Flexible collateral schedules allowing for optimization of collateral Post trade functionality • Loan Deliveries, Mark-to-Marks, Re-rates, Recalls, Returns, Buy-ins • Corporate Actions, dividend payments • Automated billing (lending fees & rebates) Principal collateral > 30,000 ISINs • Cash (EUR, USD), • Bonds, Equities and ETFs Markets > 25,000 ISINs • Fixed income – European government, supra, corporate bonds • Equities – coverage of key European markets • Exchange Traded Funds (ETFs) Risk considerations and operational efficiencies are driving change Securities lending market participants Eurex Clearing Lending CCP Bilateral market (OTC) Electronic SL trading platforms Eurex Repo-SecLend MarketFlow Providers & Trade Capture Platforms Central Securities Depositories International Central Securities Depositories 29
  • 30. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 Lending CCP – Specific Lender License 30 The solution The Specific Lender License facilitates lending only participants (beneficial owners) the ability to remain as principal via a direct relationship with the CCP and the Agent Lender remains as an account operator as agent. It also delivers other key benefits: • No requirement to clear through a GCM, pay margin or default fund contribution • Existing relationships with Lending Agents are maintained • Agent Lender continues to arrange loans for CCP eligible transactions • Operational links with flow provider and CCP maintained by Agent Lender • Agent Lender reports loans and collateral through existing reporting set • Simplifies multiple counterparty credit structure to a single CCP • Transparent and standardized risk management and default procedures approved by regulators • Access a wider distribution of counterparts via one legal framework • Flexible collateral schedules allow optimization of collateral • Reduction of Agent Lender’s indemnification costs Allowing Beneficial Owners to participate directly with a CCP CCPs for Securities Lending deliver: • Effective use of capital • Better terms • Credit intermediation • Risk mitigation • Increased utilization • Operational efficiency • Collateral optimization
  • 31. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 GC Pooling Select – Invest and Finance 31 Direct clearing models link supply with demand in a capital efficient way The solution Direct CCP clearing models are the catalyst to eliminate exposure between client and bank in existing bilateral and tri-party models. As an integrated CCP, Eurex Clearing offers tailored clearing licenses for buy side customers to gain direct access to the repo CCP markets. Eurex Clearing’s integrated securities financing service enables collateral availability, liquidity and fluidity for all market participants. GC Pooling Select Finance • Accommodates access to CCP cleared secured funding and investments for buy side • By leveraging proven GC Pooling infrastructure buy side clients are enabled to perform collateral transformation for cash margin coverage, specifically VM funding for pension funds and asset managers • Delivered via the ISA Direct clearing membership, buy side participants can gain access via a Clearing Agent GC Pooling Select Invest • Facilitates secured deposits and delivers a substantial reduction in the credit and liquidity risks of lending unsecured • is available for non-banks, such as corporates or insurance companies, wishing to invest cash on a secured basis with a CCP • No default fund or initial margin • No access to clearing systems required GC Pooling and Repo market: benchmark for secured funding and financing GC Pooling and Repo Sell Side GC Pooling Buy Side EUR USDGBP* Select Invest (EUR) Select Finance (CHF, EUR, GBP**, USD) Cash provider and cash taker Banks, brokers, central banks, finance agencies, supranational organisations Corporates, pension funds, asset managers, insurance companies Net cash provider Cash provider and cash taker Fully comply with Eurex Clearing’s clearing conditions Unique set up: • No default fund • No initial margin • No access to clearing systems required ISA Direct clients: • Principal to CCP • Must meet admission criteria equivalent CM • Clearing Agent provides services *GBP will be launched in Q216; ** GBP will be available under Select Finance in Q316 CHF GC Pooling and Repo Buy Side
  • 32. www.eurexclearing.com Bloomberg & The Union of Arab Securities Authorities Rountable September, 2016 32 © Eurex 2016 Deutsche Börse AG (DBAG), Clearstream Banking AG (Clearstream), Eurex Frankfurt AG, Eurex Clearing AG (Eurex Clearing) as well as Eurex Bonds GmbH (Eurex Bonds) and Eurex Repo GmbH (Eurex Repo) are corporate entities and are registered under German law. Eurex Zürich AG is a corporate entity and is registered under Swiss law. Clearstream Banking S.A. is a corporate entity and is registered under Luxembourg law. U.S. Exchange Holdings, Inc. and International Securities Exchange Holdings, Inc. (ISE) are corporate entities and are registered under U.S. American law. Eurex Frankfurt AG (Eurex) is the administrating and operating institution of Eurex Deutschland. Eurex Deutschland and Eurex Zürich AG are in the following referred to as the “Eurex Exchanges”. All intellectual property, proprietary and other rights and interests in this publication and the subject matter hereof (other than certain trademarks and service marks listed below) are owned by DBAG and its affiliates and subsidiaries including, without limitation, all patent, registered design, copyright, trademark and service mark rights. While reasonable care has been taken in the preparation of this publication to provide details that are accurate and not misleading at the time of publication DBAG, Clearstream, Eurex, Eurex Clearing, Eurex Bonds, Eurex Repo as well as the Eurex Exchanges and their respective servants and agents (a) do not make any representations or warranties regarding the information contained herein, whether express or implied, including without limitation any implied warranty of merchantability or fitness for a particular purpose or any warranty with respect to the accuracy, correctness, quality, completeness or timeliness of such information, and (b) shall not be responsible or liable for any third party’s use of any information contained herein under any circumstances, including, without limitation, in connection with actual trading or otherwise or for any errors or omissions contained in this publication. This publication is published for information purposes only and shall not constitute investment advice respectively does not constitute an offer, solicitation or recommendation to acquire or dispose of any investment or to engage in any other transaction. This publication is not intended for solicitation purposes but only for use as general information. All descriptions, examples and calculations contained in this publication are for illustrative purposes only. Eurex and Eurex Clearing offer services directly to members of the Eurex exchanges respectively to clearing members of Eurex Clearing. Those who desire to trade any products available on the Eurex market or who desire to offer and sell any such products to others or who desire to possess a clearing license of Eurex Clearing in order to participate in the clearing process provided by Eurex Clearing, should consider legal and regulatory requirements of those jurisdictions relevant to them, as well as the risks associated with such products, before doing so. Eurex derivatives are currently not available for offer, sale or trading in the United States or by United States persons (other than EURO STOXX 50® Index Futures, EURO STOXX 50® ex Financials Index Futures, EURO STOXX® Select Dividend 30 Index Futures, EURO STOXX® Index Futures, EURO STOXX® Large/Mid/Small Index Futures, STOXX® Europe 50 Index Futures, STOXX® Europe 600 Index Futures, STOXX® Europe 600 Banks/Industrial Goods & Services/Insurance/Media/Travel & Leisure/Utilities Futures, STOXX® Europe Large/Mid/Small 200 Index Futures, Dow Jones Global Titans 50 IndexSM Futures (EUR & USD), DAX®/MDAX®/TecDAX® Futures, SMIM® Futures, SLI Swiss Leader Index® Futures, MSCI World/Europe/Japan/AC Asia Pacific ex Japan Index Futures and VSTOXX® Futures as well as Eurex inflation/commodity/weather/property and interest rate derivatives). Trademarks and Service Marks Buxl®, DAX®, DivDAX®, eb.rexx®, Eurex®, Eurex Bonds®, Eurex Repo®, Eurex Strategy WizardSM, Euro GC Pooling®, FDAX®, FWB®, GC Pooling®,,GCPI®, MDAX®, ODAX®, SDAX®, TecDAX®, USD GC Pooling®, VDAX®, VDAX-NEW® and Xetra® are registered trademarks of DBAG. Phelix Base® and Phelix Peak® are registered trademarks of European Energy Exchange AG (EEX). All MSCI indexes are service marks and the exclusive property of MSCI Barra. RDX® is a registered trademark of Vienna Stock Exchange AG. IPD® UK Annual All Property Index is a registered trademark of Investment Property Databank Ltd. IPD and has been licensed for the use by Eurex for derivatives. SLI®, SMI® and SMIM® are registered trademarks of SIX Swiss Exchange AG. The STOXX® indexes, the data included therein and the trademarks used in the index names are the intellectual property of STOXX Limited and/or its licensors Eurex derivatives based on the STOXX® indexes are in no way sponsored, endorsed, sold or promoted by STOXX and its licensors and neither STOXX nor its licensors shall have any liability with respect thereto. Dow Jones, Dow Jones Global Titans 50 IndexSM and Dow Jones Sector Titans IndexesSM are service marks of Dow Jones & Company, Inc. Dow Jones-UBS Commodity IndexSM and any related sub-indexes are service marks of Dow Jones & Company, Inc. and UBS AG. All derivatives based on these indexes are not sponsored, endorsed, sold or promoted by Dow Jones & Company, Inc. or UBS AG, and neither party makes any representation regarding the advisability of trading or of investing in such products. All references to London Gold and Silver Fixing prices are used with the permission of The London Gold Market Fixing Limited as well as The London Silver Market Fixing Limited, which for the avoidance of doubt has no involvement with and accepts no responsibility whatsoever for the underlying product to which the Fixing prices may be referenced. PCS® and Property Claim Services® are registered trademarks of ISO Services, Inc. Korea Exchange, KRX, KOSPI and KOSPI 200 are registered trademarks of Korea Exchange Inc. BSE and SENSEX are trademarks/service marks of Bombay Stock Exchange (BSE) and all rights accruing from the same, statutory or otherwise, wholly vest with BSE. Any violation of the above would constitute an offence under the laws of India and international treaties governing the same. The names of other companies and third party products may be trademarks or service marks of their respective owners.