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FEDERAL RESERVE BANK
OF CHICAGO
CAP IT.AL
Going! Going! Gone!
(Then again, maybe not)
T
he pricing and hedging of fixed-
income securities has become
infinitely more complex since the
on the run"' U .S. Treasury curve,
apparently decoupled from the funda-
mentals of economics and interest rate
theory, has begun to trade in a world of
it's own. Relative to that, market strategists
have opined on causes for the recent yield
curve inversion. Bulls rationalize a lack of
supply sparked by the Treasury
Department's buyback plans, shaky
equity markets, and a fully discounted
Federal Reserve monetary policy while
bears hang on to fundamentals and
contrarian technical indicators.
Through it all, the spectators to this
battle are beginning to question
whether Treasury securities can continue
to serve as a risk-free benchmark and
hedging tool for the fixed-income markets.
The role ofa benchmark is to act as an
indicator against which other related
segments of the financial markets can
determine relative value. In terms of
determining the value of interest rates
across a maturity spectrum, US Treasury
securities ("Treasuries") have been (as far
back as the current generation of traders
and money managers can remember)
the benchmark or the base interest rate
continuum. The prominent characteristics
of Treasuries that have afforded them
benchmark status are volume (in terms of
dollars outstanding), liquidity and,
because they are backed by the full faith
and credit ofthe US government, effectively
no credit risk. Additionally, the large size
of any single issue and a program of
MARKETS NEWS
regular borrowing with pre-announced
market dates have enhanced their bench-
mark status. Recently a number offactors,
directly related to those characteristics
that had previously supported Treasury
securities' benchmark status, have acted
to undermined their standing as a pricing
vehicle for other fixed income securities.
The Treasury Department announced
a suite ofchanges to its debt issuance and
buyback strategy, beginning with the
February refunding, that will affect the
supply ofTreasuries going forward. Large
budget surpluses are making it increas-
ingly difficult for the Treasury to manage
the average maturity of the debt while
maintaining auction liquidity. The
revised refunding announcement, as well
as statements from various officials, have
led the markets to believe that the
Treasury is preparing the market to let the
30-year benchmark bond go; whether
this becomes reality or not is currently
being debated, but perception is
nonetheless influencing market reaction.
June 2000
That perception of scarcity is one of the
factors causing Treasuries to trade more
like commodities, where prices increase
in anticipation of greater scarcity rather
than as an indicator of fundamentals in
interest rate movements.
Additional complications to the liquidity
of the 30-year bond result from changes
in the private debt issuance markets and
the trading patterns of the 30-year issue.
Private sector borrowing in the debt market
has increased significantly, and underwriters'
need for a hedging vehicle has increased
demand for Treasuries. What's more, the
placing and unwinding of large hedges
creates technical pressures that increase
volatility and further distort the prices of
these securities. Dealers who provide
liquidity by taking risk positions have
been very hesitant to short the Treasury
market since the emerging market crisis
in the autumn of 1998, a situation that
clearly revealed the frailties of this market
as an all-purpose hedging vehicle.
Additional liquidity was destroyed when
Capital Markets News is published quarterly by the Capital Markets Group of the
Supervision and Regulation Department. Its primary intention is to further
examiners' understanding of topical issues pertaining to derivatives and other
capital markets subjects. Articles are not intended as exhaustive commentaries of
the subject matter; rather, they are summaries meant to convey a basic under-
standing of the issue and to serve as a foundation for further analysis. Readers
who would like further information on any of the articles may contact the author
directly. For additional copies of back issues of the newsletter, please contact
Joe Cilia at 312-322-2368.
Any opinions expressed are the authors' alone and do not necessarily reflect
the views ofthe Federal Reserve Bank ofChicago or the Federal Reserve System.
CA p ITAL MARKETS N E W S - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
Going! Going! Gone! continued
the same market crisis reduced the number
ofproprietary trading desks that supported
market liquidity. The "riskless" status of
Treasuries also makes them the investment
of choice in a "flight to quality" hedge
against the equity market. This link has
caused unpredictable volatility and price
distortions, further prompting a cautious
stance on the part of dealers who would
normally be liquidity providers. All told,
these volatility and price distortions,
especially in the long end of the Treasury
curve, have called into question whether
the 30-year is an appropriate, risk-free
benchmark against which fixed-income
issuers should price their debt.
Alternate Benchmarks?
Government sponsored enterprises or
GSEs, specifically Fannie Mae and
Freddie Mac, have been quick to establish
themselves as the alternate benchmark by
increasing the size and regularity of their
debt issuance. While their actions may
address two prominent attributes of a
benchmark, volume and liquidity, at the
same time they introduce credit risk.
Fannie Mae came to market with "bench-
mark notes" in 19982
and Freddie Mac
quickly followed in 1999 with their issue
known as "reference notes".' Both GSE's
tout such attractive features as outstanding
supply, auction size, and regularity in their
attempt to replace the potential vacuum
being created in Treasuries. Skeptics
nonetheless question whether the GSE's
would truly be able to support the
issuance size necessary to be a benchmark
within the confines of their charters.
Chartered to support the mortgage markets,
it would be interesting to see how much
debt could be sustained by the entities in an
economic downturn that reduces mortgage
lending.' In terms ofcredit risk, what was
initially thought to be a viable alternative
for the risk free component of Treasuries
has been put to question with Treasury
Undersecretary Gensler's recent proposal
that government credit lines to the agencies be
reduced. Away from GSEs, comparable
corporate issues' ("corporates") are
another alternative that may be considered
as a benchmark for both corporate hedging
and pricing. Thirty years ago the corporate
bond market functioned without Treasury
benchmarks, and corporates were used to
hedge other corporates. Nonetheless,
liquidity constraints remain a concern for
this type ofhedge, and using corporates as
a pricing benchmark for other corporates
could introduce a new element of credit
induced volatility into the mix.
Credit markets have been built around
and out of the Treasury market, and
removing its inner structure will create a
variety ofvacuums and some dislocations.
The risk profile of the entire market will
increase, which in turn means greater
susceptibility all around during economic
downturns or in the face of unforeseen
events. While the market has adjusted to
other benchmarks and hedging vehicles
such as LIBOR6
along the short end ofthe
yield curve, it has had difficulty finding a
suitable substitute in the long end. As a
hedging vehicle, bond desks have been
utilizing swaps' to a large extent for at least
the last 12 months or so. However both
swaps and agencies, as they now stand, are
far from ideal substitutes for Treasury
bonds.
Although the supply of on-the-run
Treasury issues is certainly a factor in the
trading pattern of this sector, it is by no
means clear that it is the only or even
predominant component affecting its
performance. As painful as the trading
distortions resulting from the other elements
noted may be, the market will ultimately
sort them out. The supply-induced
2
portion of the Treasury market should be
carefully evaluated as an independent factor
to determine its actual effect. It is important
to remember that the advantage of US
sovereign debt as a benchmark is its risk
free component, and if the supply of
Treasuries is the overriding component
affecting the current yield curve inversion
and price volatility, the market will form
an agreement on appropriate substitutes,
bearing this fact in mind. Even if a deal
is officially priced off one benchmark, its
performance will be determined, by and
large, by its relationship with a variety of
markets.
-Donna M. Zagorski
'The "on-the-run" issue is the most recently auc-
tioned issue.
'Durfey, Steve, "There's a New Benchmark (Note)
in Town", Capital Markets News, March 1998, Federal
Reserve Bank ofChicago
3
Peterson, Michael, ''We're Dedicated Followers
of Fashion", Euromoney, February 2000, Issue 370, P.
60,
4
Baum, Caroline, "Public or Private?", Bloomberg
Commentary, March 23, 2000.
5
Clow, Robert, "The new national debt" ,
Instit11tio11a/ Investor 102 34, no.1 Qan.2000)
6
London Interbank Offered Rate
7
The large demand for this hedging vehicle has
produced its own demand distortions in the Svaps
market.
OpTech 2000
T
he annual FIA sponsored
OpTech conference offers a
forum for US futures exchanges,
FCMs, and industry vendors to come
together and exchange information on
new developments in the technology
and operations areas. The two-day
conference, held this past April in New
York, dealt with a number ofinformative
issues and prompted some valuable
debates.
US Exchange Leaders'
The conference opened with a high
level session as exchange leaders from
the CME, NYBOT, and NYMEX
discussed recent strategic initiatives.
The CME and NYMEX have made
progress in their plans to change their
ownership and governance structure,
and have filed with the SEC to convert
to for-profit corporations. In re-assessing
the clearing house function based on
these changes taking place, exchanges
who view the clearinghouse as a strategic
asset are trying to leverage off those
operations that have proven successful
to both OTC products and the B2B
markets. They have plans to expand the
range of acceptable margin to OTC
commodities positions and, prompted
by new international developments, are
re-evaluating the existing model of
separate clearing for the cash market
and derivatives.
Although FCMs feel threatened by
the e-commerce revolution, the
exchange leaders reinforced the notion
that exchanges rely on the FCMs to
distribute their products, and reiterated
that the FCM relationship and clearing
function is a critical business feature of
the futures industry. The exchanges
have taken new initiatives aimed at a
more cost-effective structure; on the
operational side, one ofthese initiatives
is straight-through-processing, which
will offer a seamless routine from trade
entry,to clearing, eliminating human
intervention and providing cost effective
trade processing.
Online Customers
Two sessions were devoted to legal
and operational issues of online cus-
tomers. Many questions arose, but
answers often fell short of providing
satisfactory, direct, or comprehensive
solutions, highlighting the difficulties
the futures industry faces in devising a
comprehensive legal and regulatory
framework in the New Economy.
There was overwhelming consensus
that electronic trading will soon be the
predominant trading venue in the US,
analogous to the European model that
swiftly shifted to the electronic platform.
Online trading facilitates more partici-
pation, increases liquidity, and affords a
sufficient audit trail. It is, ofcourse, not
free ofchallenges, and the CFTC is still
in the process of devising a workable
framework to address the tremendous
changes and opportunities brought
about by technology.2
On the retail side, the futures industry
has yet to experience the same level of
direct online access witnessed in the
stock-trading arena. Single stock
futures may turn out to be the catalyst
for retail participation and the emergence
of a new trading behavior as already
experienced in the securities markets,
where participants trade four times as
frequently online as not. Clients already
demand real-time connectivity, and the
prospect of increased participation
makes it all the more necessary for systems
to be scalable and redundant to cope
with failure. Such direct access to
exchanges might disintermediate
FCMs. For example, online systems
can easily integrate middle office
management capabilities and provide a
direct (and in the future real-time) basis
for cash funding, functions that were
traditionally fulfilled by FCMs.
Inevitably, FCMs will need to focus on
value-added services to retain their
client base. They must cater more deci-
sively to the needs of their customers,
who increasingly demand real-time
connectivity, more transparency in
models used, and uniformity in reporting
across different brokers. A current trend
3
among FCMs is for differentiation
through research. To that end, FCMs
could continue to add value in the
credit decision making process, as
credit screening systems integrated into
online trading are only capable ofdiscrim-
inating rather than making judgement
calls.
Reliance on access, security, and
privacy are issues that the industry is
only beginning to address given the
persistence of open outcry among
exchanges in the US. Discussions
focused on speculation as to why cases
where online trading was the primary
issue against FCMs or exchanges have
been conspicuously absent within the
legal system. Given that within the
futures industry, electronic trading is
exchange-driven, reasons might be
attributed to the clarity oflimitation of
liability rules ofthe exchanges reinforced
by the CFTC posture that there would
be no medium-based exceptions in ·
enforcement action. 3
In the future,
more jurisdictional issues are expected
to arise, especially with regard to the
transnational aspects of electronic sys-
tems. In general, cyberspace law is not
expected to differ significantly from
current futures, securities and contract
law, and the consensus felt that as long
as cyberspace law is in the making,
FCMs should seek liability protection
through disclosure.
E-Clearing
E-clearing, leveraging off of new
and existing technologies, has two key
aspects: an adequate and scalable network
and accurate on-time delivery ofdata in
a standardized format. Exchanges have
developed and support protocols for
data and message transmission, with
some standardization already evident,
and have adopted set rules and policy
while they rely on industry vendors to
provide the networks. Clearinghouses
have made a strong commitment to
e-clearing, convinced that through the
use of technology neither location nor
physical proximity to the trading floor is
an issue, while at the same time recogniz-
CA P I T A L MA R K E T S N E W S - - - - - - - - - - - - - - - - - - - - - - - -
OpTech 2000 continued
ing that redundant systems and disaster
recovery plans have become more critical
than ever. Clearinghouses look to their
clearing firms for the necessary investments
in technology to make e-clearing possible,
with ongoing productive dialogue
between FCMs and exchanges an important
initiative at this juncture.
Frank Perrone of Deutsche Bank
Futures offered a perspective on e-clearing
from the FCM side. The FCMs expect
e-clearing to enhance risk management,
reduce costs, handle more volume, and
improve regulatory compliance. A difficulty
for FCMs lies in the fact that every
exchange solves clearing problems in a
different way. Standardization is imperative
and there is, therefore, a need for clearinghouses
to take a broad perspective on embracing
standards and to move towards centraliza-
tion in an effort to facilitate global clearing.
It is also anticipated that the CBOT-
Eurex alliance will provide a glpbal
clearing vision for derivatives and equities.
Cash Management
Global cash management and collateral
optimization are critical components of
the FCM business, and will become
increasingly important as electronic trading
facilitates transnational transactions.
Ronald Metcoff ofJP Morgan Futures
provided a useful overview of margin
accepted as collateral by international
futures exchanges. Constructing a collateral
matrix for initial and variation margin,
which tabulates accepted forms ofmargin
(cash in different currencies or securities)
by international exchanges and indicates
basis point spreads and haircuts, can help
organize information and facilitate cash
management decisions. Tim Doar of the
CME presented cash management initiatives
on the part ofCME. Clearing firm capital
and operating efficiencies, liquidity,
settlement characteristics, and custody
implications are the collateral philosophy
tenets ofthe CME. Following the success
of the IEF program,' the CME is con-
templating a similar program to allow
investment in the full range of Reg 1.255
securities with appropriate diversification,
credit, and concentration standards. The
benefits of such a managed portfolio
approach will result in a simplified
operational and risk environment from the
firm's prospective (the firm will simply deal
in cash). The exchange will offer professional
portfolio management with the benefits
ofsecurity analysis and screening, diversi-
fication ofrisk, and enhanced rate ofreturn.
Concluding Issues
The conference concluded with two
sessions on new initiatives and emerging
issues. Amidst a booming economy and
an emphasis on dot-com companies, the
exchanges have experienced considerable
employee turnover and retention issues in
the technology area, and have dealt with
the problem by resorting to outsourcing
and a shifting emphasis on consulting.
The exchanges themselves are increasingly
embracing the Internet as a public network;
Melba Cubillos and Asad Gilani of
NYMEX provided an overview of the
NYMEX migration from the current
batch-based data transmission environment
to a straight-through processing model of
real.:.time connectivity over the Internet
utilizing virtual private tunnel architecture.
Unlike what the name might imply,
the OpTech 2000 conference steered
away from technical terms and focused
decisively on recent trends and strategy.
Participants have accepted the impact that
technology has had in changing the face
ofthe industry as evidenced by the drastic
and decisive shift in Europe from pit to
screen-based trading. Exchanges have
resolved to use the Internet as a public
route network _in their plans to replace
current batch-based data transmission
with real-time connectivity. Although
retail participation in the futures market
has not yet reached the level witnessed in
the stock market, more involvement at
the retail level is anticipated. Electronic
trading and new technology will
empower the individual, and the industry
will need to meet a whole new array of
operational, compliance, security, privacy,
and risk management challenges. While,
for the time being, disclosure can shield
FCMs from legal liability, at the same
time technology offers new opportunities
for the exchanges, which are determined
to leverage off their proven expertise in
clearing to expand their services to other
products in the OTC and the B2B markets.
-Gloria Ikosi
4
The panel was .
. comprised of Ma k
President and CEO N r D. Fichte!
. . • ew York Board ofT •
E. Oliff, Vice Chairman B rade,Jarnes
, oard ofDire
Mercantile Exchan ctors, Chicago
. ge, and Daniel R.
Chairman, New York M . appapon,
ercannle Excha
M . Hersch , Senior M . nge. Ronald
anagmg o·
Stearns & Co., Inc. was th Irector, Bear,
2 e moderator
The CFTC Staff For .
ce report on th N
Regulatory Framework w I e ew
as re eased in F b
2000. The report presents a com . e ruary
prehens1ve set of
recommended changes to the re
. . gulatory struct
administered by th C ure
e FTC. See
http:// www.cftc.gov/opa/regulato f,
3
" ry ramework.ru!f
The Internet - Testing the limits fgl b0 o al reg-
ulation." Remarks byJohn Tull (with h .
t e assistance of
Andrea Corcoran) at the Swiss Commodi" FL1es, utures
and Options Association Meeting in B k•urgenstoc
September, 1996. See www cftc g /
1'· ._ov opa
speeches/tull-16.html. The first enforcement
proceedings brought by the CFTC based exclusively
on Internet activities date back to 1996 and were in
connection with the offer of advisory services to
Internet subscribers by a firm without CTA registration.
The CFTC has subsequently filed several actions
alleging fraudulent Internet promotion ofcommodiry
trading systems and issued a consumer advisory
against fraudulent Internet promoters this spring. In
March, the Commission brought its first action to
address "spamming;• the use of mass marketing via
e-mail to defraud retail customers.
4
Under the IEF program, performancebond cash
and settlement funds which participating clearing
firms deposit with the Clearing House are pooled and
invested in US Treasury securities and in reverse
repurchase agreements collateralized by Treasuries.
5 The regulation of the Commodity Exchange
Act which restricts the range ofinScrtllllents in which
FCMs and clearing houses may invest cuStOmer funds.
-
The Interest Rate Risk Focus Report'
Introduction and Overview
The Interest Rate Risk Focus Report
(Focus Report) uses quarterly Call
Report data reported by banks to measure
their interest rate risk (IRR) exposure.
The report was created by staff at the
Board of Governors to enhance off-site
analysis of financial institutions and to
support examiners charged with determining
the scope ofthe IRR portion ofcommercial
bank examinations. This article presents
an outline of the financial information
presented in the Focus Report and
explains the Federal Reserve Economic
Value Model (EVM), the engine that
generates the risk statistics contained in
the report.' The statistics produced by the
EVM are a unique feature of the Focus
Report. While all of the financial data in
the Focus Report is available from other
sources (the benefit of the Focus Report
is having it all in one place), the results of
the Economic Value Model are not available
anywhere else. The risk statistics generated
by the Economic Value Model highlight
the degree to which a bank's capital is
exposed to IRR
Data Sources and Important Caveats
IRR related data from various sources
(primarily the Call Report) are forged
into a single report, providing a readily
available and comprehensive analysis of
IRR. Statistics in the Focus Report have
been calculated in exactly the same way as
information contained in other reports
used by bank supervisors-the Uniform
Bank Performance Report (UBPR), for
example. As always, the integrity of the
data, ratios, and analysis provided within
the Focus Report are dependent upon
the accuracy ofthe Call Report submitted
by the bank. The meaningfulness and
accuracy of conclusions drawn from the
report are particularly vulnerable to
misreporting ofasset maturities as well as
management's ability to identify and
report structured securities-both key
parts of the Economic Value Model.
An important consideration is that the
Focus Report does not contain information
on how the institution manages its risk.
For example, the economic value calculation
does not incorporate any hedging positions
that the bank might use to decrease or
increase risk. Therefore, the report is best
used in conjunction with other sources
that may supplement or supersede its
analysis, including management's internal
risk reports, monthly board reports, policies
and procedures, findings from previous
reports of examination, or other relevant
information provided by the institution.
The economic value calculations
included in the Focus Report should be
used only as a broad indicator of risk,
although comparisons with banks' own
risk reports have shown the Focus
Report's Economic Value Model to be
remarkably accurate.
Structure ofthe Focus Report
Each page ofthe Focus Report provides
ratios and statistics for the subject bank
and compares those results with the
bank's UBPR peer group. The report
covers the latest period for which Call
Report data are available, the prior quarter,
and the year ago period.
The Focus summary page identifies
key IRR characteristics ofthe bank in terms
of earnings, asset/liability composition, and
economic value exposure. The summary
page also identifies whether the institution
appears on any IRR monitoring lists. On
page 1, the bank's major portfolios are
expressed as a percentage of assets and
placed in one ofthe six maturity/repricing
frequency time bands used in the Call
Report. Collateralized mortgage obligations
(CMOs)3 and mortgage derivatives are
reported in two time bands based on
weighted average life rather than final
maturity. Page 2 provides some detail on
balance sheet categories and product
complexity, which may in turn offer
insights on likely cash flow behavior. Page
3 details time deposits and borrowings by
stated contractual maturity or repricing
frequency. It reflects total interest bearing
liabilities and DDAs by type rather than
maturity, including insights regarding
nonmaturity deposits and the mix of
other funding.
Page 4 provides information on the
quality and stability of an institution's
net interest margins and other earnings
indicators. Page 5 presents the results of
the FRB economic value model in an
environment where interest rates have
risen 200bp. Page 5 also shows the potential
effect of an increase in interest rates on
5
the bank's capital adequacy. Page 6 details
the economic value model including
balances, risk-weights and resulting
estimated change in economic value for a
200 basis point shock, and shows the risk
weights applied to each balance sheet
grouping to generate the estimated
change in economic value under a
+200bp parallel shift in interest rates.
The Economic Hilue Model
The "net economic value" presented
in the Focus Report is the negative
change in market value of the bank's
assets offset by the positive change in the
market value ofthe bank's liabilities under
a +200 basis point parallel shift in interest
rates. This estimate is produced using
aggregated groups of similar balance sheet
items that are assumed to have similar
repricing characteristics; for example, all
mortgage related assets that
mature/reprice within 5 to 15 years or
nonamortizing loans that mature/ reprice
within 1 to 3 years. The use ofaggregation
is necessary because the EVM employs
data from published Call Reports, which
themselves aggregate individual balance
sheet items into broad categories and
repricing schedules.
The EVM uses proxy financial instru-
ments to calculate the change in economic
value.' The market sensitivity of each
proxy instrument is used as a " risk weight",
which is multiplied by the dollar amount
of the applicable balance sheet grouping.
Market data may suggest, for instance, that
for a 200 basis point increase in interest
rates, that proxy instrument would e.-q,erience
a decline in market value of 3.0%.
Therefore, the "risk weight" for that
grouping would be -3.0%. If a bank has
assets in this grouping totaling $10 million,
then the change in value would be $10
million x -3.0% or -$300,000.
Why does the EVM measure balance
sheet sensitivity only for increases in
interest rates? After all, wouldn't a 200
point decrease in rates cause interest rate
exposure as well? In general, banks fund
longer-term assets with shorter-term
liabilities. In a rising rate environment,
assets-because of their greater price
sensitivity-will change in value more
than liabilities, producing a net
negative impact.
CAPITAL MARKETS NEWS
The Interest Rate Risk Focus Report continued
The broad categories used in the
EVM are:
• 1-4 family mortgage products;
• CMOs, REMICs and strips
• Other amortizing assets;
• Nonamortizing assets;
• Nonmaturity deposits;
• CDs, time deposits and other
borrowings.
These categories are subdivided into
time bands that reflect the maturity or
repricing characteristics of the balance
sheet items:
• 0-3 months;
• 3-12 months;
• 1-3 years;
• 3-5 years;
• 5-15 years;
• over 15 years.
EVMCaveats
The EVM is a supervisory monitoring
tool intended to provide examiners with
a rough estimate of the interest rate risk
exposure of a financial institution. As
such, it is meant to be a starting point to
help Federal Reserve staffaddress potentially
significant interest rate exposures during
offsite monitoring and the examination
process. Examiners should not view the
EVM or its results as being the final word
in the level and source ofa bank's interest
rate risk. A bank's balance sheet sensitivity
may differ, perhaps materially, from the
level of risk suggested by the EVM. This
is most likely to occur when the actual
maturity and repricing characteristics
ofmortgage-related assets and nonmaturity
deposits differ from those used in the EVM.
Differences may also occur when
financial institutions use derivatives to
hedge interest rate exposure. The use of
interest rate derivatives is not captured
within the EVM. When banks successfully
use derivatives to hedge, the Net Change
in Economic Value statistic presented in
the Focus Report will not accurately
reflect the bank's interest rate sensitivity.
Ifexaminers encounter situations where a
bank's internal IRR model exhibits
material differences from the results of
the EVM, they should check to see ifthe
bank is hedging and investigate the
reasonableness ofthe assumptions used in
the bank's internal model.
-Cheryl Sulima, CFA and Craig West,
Ph.D.
Operational Risk Management Issues
W
h_at e:pctly does operational
nsk rn~an? The core definition
reads aS' follows:
"Operational risk is the risk of direct
or indirect loss resulting from inade-
quate orfailed internal processes, peo-
ple, and systems, or from external
events."1
One school of thought states that
operational risk is anything that evades
traditional market and/or credit risk
definitions. A broader and more useful
definition would take into account th
tacit linkage between the trinity ofmarke:
credit, and operational risk. As borne ou~
by empirical evidence from the recent
~ussian debt crisis and accompanying
global contagion,' risks tend to converge
and blur during a systemic and widespread
market meltdown. As such, settlement,
collateral, and netting risks may not be
classified purely as operational risk, given
that they contain elements of more than
one risk,2
A more comprehensive definition
would also allow a subset of operational
risk management (ORM) to address the
component of model risk, given that
firms engaged in the use of non-vanilla
and· highly structured transactions
encounter ris_k of loss from inappropriate
use of modeling techniques.
Irrespective of its formal defi 't· ..
1
h m 100, 1t
i~ c ear t at ORM has been elevated to
e forefront ofrisk management initiatives
.or financial institutions, and is greatly
impacted by the following:
6
1
The Interest Rate Risk F
an examiner too[ A ocus Report is primarily
provided to bank · copy of the report should be
ers only in th
rate risk review a d h e context ofan interest
n s ould be ca full
the banker by an e . re Y explained to
. xanuner trained in its
circumstances should b use. Under no
a anker receive aF
for a bank other than hi /h ocus Report
2 s er own.
These issues are furth d .
. er eta1led in a publi .
entitled Interest Rate R•k F cation
IS ocus Report - A Us ' .
prepared by the Capital Mark . ersGuide
. . ets Umt. Copies of this
gmde are available upon request· 1. . ' p ease contact the
editor ofthis newsletter for m . r .
ore m1ormauon
3
For additional information O C II · .
n ° atenzed
Mortgage Obligations, see "Advanced CM .
OAnalyhcs
for Bank Examiners", a Product Summa
. . ry prepared by
the Fmanc1al Markets Unit of the F d Ie era Reserve
Bank ofChicago in May 1995.
4
For example, the proxy financi· I .a instrument
chosen for the grouping "1-4 family m rtgag 10 e oans
repricing in less than 3 months" is a 6.S% COFI
ARM.
• Basle Committee on Banking
Supervision3 - The Committee inter-
viewed roughly thirty large banks
from various member countnes on
ORM topics. The interviews reve~ed
. al . k 1u·ve to trading
that operaaon ns re a
. d b ' everal banks
activities was v1ewe ) s h. . . rressed t at
as high. A few mstttunons s
. k t confined to
operational ns was no . .
ffj
ctiv1ues but
typical back o ice a
ffi and essen-
enveloped the front O ice ' . s
. s operanon .
tially any facet of busmes . k.
' . thens ,n
The Committee, referencmg
h dealers 111aY
financial markets t at duct
. h ·tyorcon
exceed their aut on • ky
h' cal or ns
business in an unet 1
1 111ent
d the deveop
manner, has propose . 1 ·5k.uona n
of capital charges for opera
•if
----
operationalRiskManagementIssuescontinued
.I
Thenewcapitaladequacyframework
stressesthedevelopmentofaninternal
capitalassessmentprocessandthe
establishmentofcapitaltargetlevels
commensuratewiththeinstitution's
riskprofileandcontrolenvironment.
Theproces.swouldbesubjecttosupervisory
re~ewandintervention,asappropriate.'
"
•CapitalAttribution-Theincreasing
scopeandcomplexityofbusiness
initiativesatmanyorganizationswas
theimpetusforSR99-185
Assessing
CapitalAdequacyinRelationtoRiskat
l.ArgeBankingOrganizationsandOthers
withComplexRiskPrefiles.Theletter
promulgatesthatlarge,complexbanking
organizations(LCBOs)willbe
expectedto"takegreatereffortsto
assurethatcapitalisnotonlyadequate
tomeetformalregulatorystandards,
butalsoisfullysufficienttosupport
theirunderlyingriskpositions."
Further,theguidancestatesthatfor
organizationsactivelyinvolvedin
complexrisktransfers,examiners
shouldexpectasoundinternalcapital
adequacyanalysisframeworktobe
presentimmediatelyasamatterofsafe
andsoundbanking.Complexrisk
transfersincludeCLOs,creditderivatives,
andcredit-linkednotes.Institutions
areexpectedtohaverobustmethodologies
inplacetomanagethoserisks
incurred,allmaterialonandoffbalance
sheetrisksshouldbeadequately
addressed,andcontrolsshouldbe
establishedtoensureobjectivityand
consistency.
Industry-wide,riskandfinancial
managersarefacedwiththedilemmaof
howtomeasureoperationalrisk.Ina
recentspeechattheFederalReserve
BankofChicago,ChairmanGreenspan
expressedconcernthatoperationalrisk
cannotbepreciselyquantifiedand,further,
thatsomemarketsparticipantsdonot
quantifyoperationalriskatall,effectively
assumingittobezero.6
Thetwo-pronged
approachthatmanybanksemploytoaddress
ORMissuesiscomposedofday-to-day
ownershipatthebusinesslineandunit
...........___
levelcoupledwithobjectiveaccountability
forownership.Tofacilitateandenforce
thelatterpartoftheapproach,many
firmsareimplementingametrics-based
formattogaugebusinesslineperformance
sothat,say,MIStrackedperformancecan
betiedbacktomanagementandline
employeeperformancereviewaswellas
compensation.Whereasinternalaudithas
inthepastservedasthebarometertogauge
theidentifiedORMuniverse,business
linesandcentralizedORMdepartments
arenowexpectedtoproactivelydefine,
identify,monitor,andmanageORMlevels.
TheworkingsofORMareco"nverging
towardsanorganizationalstructureand
managementfr.uneworkwherebyenterprise-
wideORMleveragesoffofatwo-phase
foundationconsistingof
•Businesslinemanagementownership
(bottom-upapproach)thatspansthe
'frontline'and
•Centralizedmacro-managementand
supervisionwithinanORMdepartment
thatisresponsibleforacutelyand
attentivelymonitoringoperational
risklevels(thetop-downmethod).
Anemergingqualitativemeasurefor
ORMistheriskcontrolself-assessment
(RCSA).LCBOinternalauditdepartments
oftenutilizeriskcontrolassessments.For
ORMpurposeslinemanagementwould
performaRCSA,therebyreinforcingits
ownershipandaccountabilitythereof,
withtheprincipalroleofauditnow
envisionedtobeRCSAvalidation.An
ORMissueparticulartoLCBOsingeneral
andcapitalmarketsinparticularisthe
adventofstraightthroughprocessing
(STP).7
Ofteninthepast,separateand
distinctoperatingsystemsexistedforthe
fiontandbackofficeandwereindependently
reconciled,oftenmanually.Todaymany
institutionshaveestablishedseamless
fronttobackprocessingwhereincertain
casesnophysicalticket,onlyanelectronic
ticket,exists.STPaffordsanexcellent
audittrailbyeliminatingthephysical
pass-offsofitspredecessorenvironment.
Interestingly,though,operationalriskhas
nowbeentransferredfromareconciliation
7
controlpointtoonethatisnowreliant
upontheintegrityoftheoperatingsystem
anditsembeddedcoding.
Effectivemanagementandmitigation
ofoperationalriskrequiresactivebuy-in
andparticipationfromseniormanagement,
linemanagement,externalauditors,
internalauditors,andregulators.As
evidencedbythefactthatover$7billion
ofoperationalriskrelatedlosseswere
reportedin1999byfinancialservices
firms,'theconsensusremainsthatoperational
riskisindeedacrucialissue,tantamount
tocreditriskinitspropensitytoadversely
affectafirm'ssafetyandsoundness.
-KenSwensen
1
TaraMcLenaghenandKateLeibfried,
"DefiningtheProblem:'PriceWaterhouseCoopers
presentationattheOperationalRisk-TheNew
Frontierconference,NewYork,November15,1999.
2
OperationalRiskManagement.Basie
CommitteeonBankingSupervision,Basie,
September1998.
3
Ibid.
'http://www.bis.org/publ/bcbs50.htm.
5
http://fedweb.frb.gov/fedweb/bsr/srltrs/
sr9918.htm.
6
Speechdeliveredatthe36thAnnualConference
onBankStructureandCompetitionoftheFed;ral
ReserveBankofChicago,May4,2000.
7
ManythankstoGloriaIkosiforhereditorial
assistance.
8
"BackgroundonOperationalRisk",Price
WaterhouseCooperspresentationattheOperational
Risk-TheNewFrontierconference.
FEDERAL RESERVE BANK
OF CHICAGO
P.O. BOX834
CHICAGO, ILLINOIS 60690-0834
Rthm, Strvic, Rtq•tsttd
Publisher
Adrian D'Silva (312) 322-5904
Director, Capital Markets
Editors
Joe Cilia (312) 322-2368
Senior Capital Markets Analyst
Craig West (312) 322-2312
Senior Capital Markets Analyst
Capital Markets Group of
Supervision and Regulation
14th Floor
Federal Reserve Bank ofChicago
P.O. Box 834
Chicago, IL 60690-0834
PRESORTED
FIRST-CLASS MAIL
ZIP + 4 BARCODED
U.S. POSTAGE PAID
CHICAGO, IL
PERMIT NO. 1942

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Cap markets news jun2000

  • 1. FEDERAL RESERVE BANK OF CHICAGO CAP IT.AL Going! Going! Gone! (Then again, maybe not) T he pricing and hedging of fixed- income securities has become infinitely more complex since the on the run"' U .S. Treasury curve, apparently decoupled from the funda- mentals of economics and interest rate theory, has begun to trade in a world of it's own. Relative to that, market strategists have opined on causes for the recent yield curve inversion. Bulls rationalize a lack of supply sparked by the Treasury Department's buyback plans, shaky equity markets, and a fully discounted Federal Reserve monetary policy while bears hang on to fundamentals and contrarian technical indicators. Through it all, the spectators to this battle are beginning to question whether Treasury securities can continue to serve as a risk-free benchmark and hedging tool for the fixed-income markets. The role ofa benchmark is to act as an indicator against which other related segments of the financial markets can determine relative value. In terms of determining the value of interest rates across a maturity spectrum, US Treasury securities ("Treasuries") have been (as far back as the current generation of traders and money managers can remember) the benchmark or the base interest rate continuum. The prominent characteristics of Treasuries that have afforded them benchmark status are volume (in terms of dollars outstanding), liquidity and, because they are backed by the full faith and credit ofthe US government, effectively no credit risk. Additionally, the large size of any single issue and a program of MARKETS NEWS regular borrowing with pre-announced market dates have enhanced their bench- mark status. Recently a number offactors, directly related to those characteristics that had previously supported Treasury securities' benchmark status, have acted to undermined their standing as a pricing vehicle for other fixed income securities. The Treasury Department announced a suite ofchanges to its debt issuance and buyback strategy, beginning with the February refunding, that will affect the supply ofTreasuries going forward. Large budget surpluses are making it increas- ingly difficult for the Treasury to manage the average maturity of the debt while maintaining auction liquidity. The revised refunding announcement, as well as statements from various officials, have led the markets to believe that the Treasury is preparing the market to let the 30-year benchmark bond go; whether this becomes reality or not is currently being debated, but perception is nonetheless influencing market reaction. June 2000 That perception of scarcity is one of the factors causing Treasuries to trade more like commodities, where prices increase in anticipation of greater scarcity rather than as an indicator of fundamentals in interest rate movements. Additional complications to the liquidity of the 30-year bond result from changes in the private debt issuance markets and the trading patterns of the 30-year issue. Private sector borrowing in the debt market has increased significantly, and underwriters' need for a hedging vehicle has increased demand for Treasuries. What's more, the placing and unwinding of large hedges creates technical pressures that increase volatility and further distort the prices of these securities. Dealers who provide liquidity by taking risk positions have been very hesitant to short the Treasury market since the emerging market crisis in the autumn of 1998, a situation that clearly revealed the frailties of this market as an all-purpose hedging vehicle. Additional liquidity was destroyed when Capital Markets News is published quarterly by the Capital Markets Group of the Supervision and Regulation Department. Its primary intention is to further examiners' understanding of topical issues pertaining to derivatives and other capital markets subjects. Articles are not intended as exhaustive commentaries of the subject matter; rather, they are summaries meant to convey a basic under- standing of the issue and to serve as a foundation for further analysis. Readers who would like further information on any of the articles may contact the author directly. For additional copies of back issues of the newsletter, please contact Joe Cilia at 312-322-2368. Any opinions expressed are the authors' alone and do not necessarily reflect the views ofthe Federal Reserve Bank ofChicago or the Federal Reserve System.
  • 2. CA p ITAL MARKETS N E W S - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Going! Going! Gone! continued the same market crisis reduced the number ofproprietary trading desks that supported market liquidity. The "riskless" status of Treasuries also makes them the investment of choice in a "flight to quality" hedge against the equity market. This link has caused unpredictable volatility and price distortions, further prompting a cautious stance on the part of dealers who would normally be liquidity providers. All told, these volatility and price distortions, especially in the long end of the Treasury curve, have called into question whether the 30-year is an appropriate, risk-free benchmark against which fixed-income issuers should price their debt. Alternate Benchmarks? Government sponsored enterprises or GSEs, specifically Fannie Mae and Freddie Mac, have been quick to establish themselves as the alternate benchmark by increasing the size and regularity of their debt issuance. While their actions may address two prominent attributes of a benchmark, volume and liquidity, at the same time they introduce credit risk. Fannie Mae came to market with "bench- mark notes" in 19982 and Freddie Mac quickly followed in 1999 with their issue known as "reference notes".' Both GSE's tout such attractive features as outstanding supply, auction size, and regularity in their attempt to replace the potential vacuum being created in Treasuries. Skeptics nonetheless question whether the GSE's would truly be able to support the issuance size necessary to be a benchmark within the confines of their charters. Chartered to support the mortgage markets, it would be interesting to see how much debt could be sustained by the entities in an economic downturn that reduces mortgage lending.' In terms ofcredit risk, what was initially thought to be a viable alternative for the risk free component of Treasuries has been put to question with Treasury Undersecretary Gensler's recent proposal that government credit lines to the agencies be reduced. Away from GSEs, comparable corporate issues' ("corporates") are another alternative that may be considered as a benchmark for both corporate hedging and pricing. Thirty years ago the corporate bond market functioned without Treasury benchmarks, and corporates were used to hedge other corporates. Nonetheless, liquidity constraints remain a concern for this type ofhedge, and using corporates as a pricing benchmark for other corporates could introduce a new element of credit induced volatility into the mix. Credit markets have been built around and out of the Treasury market, and removing its inner structure will create a variety ofvacuums and some dislocations. The risk profile of the entire market will increase, which in turn means greater susceptibility all around during economic downturns or in the face of unforeseen events. While the market has adjusted to other benchmarks and hedging vehicles such as LIBOR6 along the short end ofthe yield curve, it has had difficulty finding a suitable substitute in the long end. As a hedging vehicle, bond desks have been utilizing swaps' to a large extent for at least the last 12 months or so. However both swaps and agencies, as they now stand, are far from ideal substitutes for Treasury bonds. Although the supply of on-the-run Treasury issues is certainly a factor in the trading pattern of this sector, it is by no means clear that it is the only or even predominant component affecting its performance. As painful as the trading distortions resulting from the other elements noted may be, the market will ultimately sort them out. The supply-induced 2 portion of the Treasury market should be carefully evaluated as an independent factor to determine its actual effect. It is important to remember that the advantage of US sovereign debt as a benchmark is its risk free component, and if the supply of Treasuries is the overriding component affecting the current yield curve inversion and price volatility, the market will form an agreement on appropriate substitutes, bearing this fact in mind. Even if a deal is officially priced off one benchmark, its performance will be determined, by and large, by its relationship with a variety of markets. -Donna M. Zagorski 'The "on-the-run" issue is the most recently auc- tioned issue. 'Durfey, Steve, "There's a New Benchmark (Note) in Town", Capital Markets News, March 1998, Federal Reserve Bank ofChicago 3 Peterson, Michael, ''We're Dedicated Followers of Fashion", Euromoney, February 2000, Issue 370, P. 60, 4 Baum, Caroline, "Public or Private?", Bloomberg Commentary, March 23, 2000. 5 Clow, Robert, "The new national debt" , Instit11tio11a/ Investor 102 34, no.1 Qan.2000) 6 London Interbank Offered Rate 7 The large demand for this hedging vehicle has produced its own demand distortions in the Svaps market.
  • 3. OpTech 2000 T he annual FIA sponsored OpTech conference offers a forum for US futures exchanges, FCMs, and industry vendors to come together and exchange information on new developments in the technology and operations areas. The two-day conference, held this past April in New York, dealt with a number ofinformative issues and prompted some valuable debates. US Exchange Leaders' The conference opened with a high level session as exchange leaders from the CME, NYBOT, and NYMEX discussed recent strategic initiatives. The CME and NYMEX have made progress in their plans to change their ownership and governance structure, and have filed with the SEC to convert to for-profit corporations. In re-assessing the clearing house function based on these changes taking place, exchanges who view the clearinghouse as a strategic asset are trying to leverage off those operations that have proven successful to both OTC products and the B2B markets. They have plans to expand the range of acceptable margin to OTC commodities positions and, prompted by new international developments, are re-evaluating the existing model of separate clearing for the cash market and derivatives. Although FCMs feel threatened by the e-commerce revolution, the exchange leaders reinforced the notion that exchanges rely on the FCMs to distribute their products, and reiterated that the FCM relationship and clearing function is a critical business feature of the futures industry. The exchanges have taken new initiatives aimed at a more cost-effective structure; on the operational side, one ofthese initiatives is straight-through-processing, which will offer a seamless routine from trade entry,to clearing, eliminating human intervention and providing cost effective trade processing. Online Customers Two sessions were devoted to legal and operational issues of online cus- tomers. Many questions arose, but answers often fell short of providing satisfactory, direct, or comprehensive solutions, highlighting the difficulties the futures industry faces in devising a comprehensive legal and regulatory framework in the New Economy. There was overwhelming consensus that electronic trading will soon be the predominant trading venue in the US, analogous to the European model that swiftly shifted to the electronic platform. Online trading facilitates more partici- pation, increases liquidity, and affords a sufficient audit trail. It is, ofcourse, not free ofchallenges, and the CFTC is still in the process of devising a workable framework to address the tremendous changes and opportunities brought about by technology.2 On the retail side, the futures industry has yet to experience the same level of direct online access witnessed in the stock-trading arena. Single stock futures may turn out to be the catalyst for retail participation and the emergence of a new trading behavior as already experienced in the securities markets, where participants trade four times as frequently online as not. Clients already demand real-time connectivity, and the prospect of increased participation makes it all the more necessary for systems to be scalable and redundant to cope with failure. Such direct access to exchanges might disintermediate FCMs. For example, online systems can easily integrate middle office management capabilities and provide a direct (and in the future real-time) basis for cash funding, functions that were traditionally fulfilled by FCMs. Inevitably, FCMs will need to focus on value-added services to retain their client base. They must cater more deci- sively to the needs of their customers, who increasingly demand real-time connectivity, more transparency in models used, and uniformity in reporting across different brokers. A current trend 3 among FCMs is for differentiation through research. To that end, FCMs could continue to add value in the credit decision making process, as credit screening systems integrated into online trading are only capable ofdiscrim- inating rather than making judgement calls. Reliance on access, security, and privacy are issues that the industry is only beginning to address given the persistence of open outcry among exchanges in the US. Discussions focused on speculation as to why cases where online trading was the primary issue against FCMs or exchanges have been conspicuously absent within the legal system. Given that within the futures industry, electronic trading is exchange-driven, reasons might be attributed to the clarity oflimitation of liability rules ofthe exchanges reinforced by the CFTC posture that there would be no medium-based exceptions in · enforcement action. 3 In the future, more jurisdictional issues are expected to arise, especially with regard to the transnational aspects of electronic sys- tems. In general, cyberspace law is not expected to differ significantly from current futures, securities and contract law, and the consensus felt that as long as cyberspace law is in the making, FCMs should seek liability protection through disclosure. E-Clearing E-clearing, leveraging off of new and existing technologies, has two key aspects: an adequate and scalable network and accurate on-time delivery ofdata in a standardized format. Exchanges have developed and support protocols for data and message transmission, with some standardization already evident, and have adopted set rules and policy while they rely on industry vendors to provide the networks. Clearinghouses have made a strong commitment to e-clearing, convinced that through the use of technology neither location nor physical proximity to the trading floor is an issue, while at the same time recogniz-
  • 4. CA P I T A L MA R K E T S N E W S - - - - - - - - - - - - - - - - - - - - - - - - OpTech 2000 continued ing that redundant systems and disaster recovery plans have become more critical than ever. Clearinghouses look to their clearing firms for the necessary investments in technology to make e-clearing possible, with ongoing productive dialogue between FCMs and exchanges an important initiative at this juncture. Frank Perrone of Deutsche Bank Futures offered a perspective on e-clearing from the FCM side. The FCMs expect e-clearing to enhance risk management, reduce costs, handle more volume, and improve regulatory compliance. A difficulty for FCMs lies in the fact that every exchange solves clearing problems in a different way. Standardization is imperative and there is, therefore, a need for clearinghouses to take a broad perspective on embracing standards and to move towards centraliza- tion in an effort to facilitate global clearing. It is also anticipated that the CBOT- Eurex alliance will provide a glpbal clearing vision for derivatives and equities. Cash Management Global cash management and collateral optimization are critical components of the FCM business, and will become increasingly important as electronic trading facilitates transnational transactions. Ronald Metcoff ofJP Morgan Futures provided a useful overview of margin accepted as collateral by international futures exchanges. Constructing a collateral matrix for initial and variation margin, which tabulates accepted forms ofmargin (cash in different currencies or securities) by international exchanges and indicates basis point spreads and haircuts, can help organize information and facilitate cash management decisions. Tim Doar of the CME presented cash management initiatives on the part ofCME. Clearing firm capital and operating efficiencies, liquidity, settlement characteristics, and custody implications are the collateral philosophy tenets ofthe CME. Following the success of the IEF program,' the CME is con- templating a similar program to allow investment in the full range of Reg 1.255 securities with appropriate diversification, credit, and concentration standards. The benefits of such a managed portfolio approach will result in a simplified operational and risk environment from the firm's prospective (the firm will simply deal in cash). The exchange will offer professional portfolio management with the benefits ofsecurity analysis and screening, diversi- fication ofrisk, and enhanced rate ofreturn. Concluding Issues The conference concluded with two sessions on new initiatives and emerging issues. Amidst a booming economy and an emphasis on dot-com companies, the exchanges have experienced considerable employee turnover and retention issues in the technology area, and have dealt with the problem by resorting to outsourcing and a shifting emphasis on consulting. The exchanges themselves are increasingly embracing the Internet as a public network; Melba Cubillos and Asad Gilani of NYMEX provided an overview of the NYMEX migration from the current batch-based data transmission environment to a straight-through processing model of real.:.time connectivity over the Internet utilizing virtual private tunnel architecture. Unlike what the name might imply, the OpTech 2000 conference steered away from technical terms and focused decisively on recent trends and strategy. Participants have accepted the impact that technology has had in changing the face ofthe industry as evidenced by the drastic and decisive shift in Europe from pit to screen-based trading. Exchanges have resolved to use the Internet as a public route network _in their plans to replace current batch-based data transmission with real-time connectivity. Although retail participation in the futures market has not yet reached the level witnessed in the stock market, more involvement at the retail level is anticipated. Electronic trading and new technology will empower the individual, and the industry will need to meet a whole new array of operational, compliance, security, privacy, and risk management challenges. While, for the time being, disclosure can shield FCMs from legal liability, at the same time technology offers new opportunities for the exchanges, which are determined to leverage off their proven expertise in clearing to expand their services to other products in the OTC and the B2B markets. -Gloria Ikosi 4 The panel was . . comprised of Ma k President and CEO N r D. Fichte! . . • ew York Board ofT • E. Oliff, Vice Chairman B rade,Jarnes , oard ofDire Mercantile Exchan ctors, Chicago . ge, and Daniel R. Chairman, New York M . appapon, ercannle Excha M . Hersch , Senior M . nge. Ronald anagmg o· Stearns & Co., Inc. was th Irector, Bear, 2 e moderator The CFTC Staff For . ce report on th N Regulatory Framework w I e ew as re eased in F b 2000. The report presents a com . e ruary prehens1ve set of recommended changes to the re . . gulatory struct administered by th C ure e FTC. See http:// www.cftc.gov/opa/regulato f, 3 " ry ramework.ru!f The Internet - Testing the limits fgl b0 o al reg- ulation." Remarks byJohn Tull (with h . t e assistance of Andrea Corcoran) at the Swiss Commodi" FL1es, utures and Options Association Meeting in B k•urgenstoc September, 1996. See www cftc g / 1'· ._ov opa speeches/tull-16.html. The first enforcement proceedings brought by the CFTC based exclusively on Internet activities date back to 1996 and were in connection with the offer of advisory services to Internet subscribers by a firm without CTA registration. The CFTC has subsequently filed several actions alleging fraudulent Internet promotion ofcommodiry trading systems and issued a consumer advisory against fraudulent Internet promoters this spring. In March, the Commission brought its first action to address "spamming;• the use of mass marketing via e-mail to defraud retail customers. 4 Under the IEF program, performancebond cash and settlement funds which participating clearing firms deposit with the Clearing House are pooled and invested in US Treasury securities and in reverse repurchase agreements collateralized by Treasuries. 5 The regulation of the Commodity Exchange Act which restricts the range ofinScrtllllents in which FCMs and clearing houses may invest cuStOmer funds.
  • 5. - The Interest Rate Risk Focus Report' Introduction and Overview The Interest Rate Risk Focus Report (Focus Report) uses quarterly Call Report data reported by banks to measure their interest rate risk (IRR) exposure. The report was created by staff at the Board of Governors to enhance off-site analysis of financial institutions and to support examiners charged with determining the scope ofthe IRR portion ofcommercial bank examinations. This article presents an outline of the financial information presented in the Focus Report and explains the Federal Reserve Economic Value Model (EVM), the engine that generates the risk statistics contained in the report.' The statistics produced by the EVM are a unique feature of the Focus Report. While all of the financial data in the Focus Report is available from other sources (the benefit of the Focus Report is having it all in one place), the results of the Economic Value Model are not available anywhere else. The risk statistics generated by the Economic Value Model highlight the degree to which a bank's capital is exposed to IRR Data Sources and Important Caveats IRR related data from various sources (primarily the Call Report) are forged into a single report, providing a readily available and comprehensive analysis of IRR. Statistics in the Focus Report have been calculated in exactly the same way as information contained in other reports used by bank supervisors-the Uniform Bank Performance Report (UBPR), for example. As always, the integrity of the data, ratios, and analysis provided within the Focus Report are dependent upon the accuracy ofthe Call Report submitted by the bank. The meaningfulness and accuracy of conclusions drawn from the report are particularly vulnerable to misreporting ofasset maturities as well as management's ability to identify and report structured securities-both key parts of the Economic Value Model. An important consideration is that the Focus Report does not contain information on how the institution manages its risk. For example, the economic value calculation does not incorporate any hedging positions that the bank might use to decrease or increase risk. Therefore, the report is best used in conjunction with other sources that may supplement or supersede its analysis, including management's internal risk reports, monthly board reports, policies and procedures, findings from previous reports of examination, or other relevant information provided by the institution. The economic value calculations included in the Focus Report should be used only as a broad indicator of risk, although comparisons with banks' own risk reports have shown the Focus Report's Economic Value Model to be remarkably accurate. Structure ofthe Focus Report Each page ofthe Focus Report provides ratios and statistics for the subject bank and compares those results with the bank's UBPR peer group. The report covers the latest period for which Call Report data are available, the prior quarter, and the year ago period. The Focus summary page identifies key IRR characteristics ofthe bank in terms of earnings, asset/liability composition, and economic value exposure. The summary page also identifies whether the institution appears on any IRR monitoring lists. On page 1, the bank's major portfolios are expressed as a percentage of assets and placed in one ofthe six maturity/repricing frequency time bands used in the Call Report. Collateralized mortgage obligations (CMOs)3 and mortgage derivatives are reported in two time bands based on weighted average life rather than final maturity. Page 2 provides some detail on balance sheet categories and product complexity, which may in turn offer insights on likely cash flow behavior. Page 3 details time deposits and borrowings by stated contractual maturity or repricing frequency. It reflects total interest bearing liabilities and DDAs by type rather than maturity, including insights regarding nonmaturity deposits and the mix of other funding. Page 4 provides information on the quality and stability of an institution's net interest margins and other earnings indicators. Page 5 presents the results of the FRB economic value model in an environment where interest rates have risen 200bp. Page 5 also shows the potential effect of an increase in interest rates on 5 the bank's capital adequacy. Page 6 details the economic value model including balances, risk-weights and resulting estimated change in economic value for a 200 basis point shock, and shows the risk weights applied to each balance sheet grouping to generate the estimated change in economic value under a +200bp parallel shift in interest rates. The Economic Hilue Model The "net economic value" presented in the Focus Report is the negative change in market value of the bank's assets offset by the positive change in the market value ofthe bank's liabilities under a +200 basis point parallel shift in interest rates. This estimate is produced using aggregated groups of similar balance sheet items that are assumed to have similar repricing characteristics; for example, all mortgage related assets that mature/reprice within 5 to 15 years or nonamortizing loans that mature/ reprice within 1 to 3 years. The use ofaggregation is necessary because the EVM employs data from published Call Reports, which themselves aggregate individual balance sheet items into broad categories and repricing schedules. The EVM uses proxy financial instru- ments to calculate the change in economic value.' The market sensitivity of each proxy instrument is used as a " risk weight", which is multiplied by the dollar amount of the applicable balance sheet grouping. Market data may suggest, for instance, that for a 200 basis point increase in interest rates, that proxy instrument would e.-q,erience a decline in market value of 3.0%. Therefore, the "risk weight" for that grouping would be -3.0%. If a bank has assets in this grouping totaling $10 million, then the change in value would be $10 million x -3.0% or -$300,000. Why does the EVM measure balance sheet sensitivity only for increases in interest rates? After all, wouldn't a 200 point decrease in rates cause interest rate exposure as well? In general, banks fund longer-term assets with shorter-term liabilities. In a rising rate environment, assets-because of their greater price sensitivity-will change in value more than liabilities, producing a net negative impact.
  • 6. CAPITAL MARKETS NEWS The Interest Rate Risk Focus Report continued The broad categories used in the EVM are: • 1-4 family mortgage products; • CMOs, REMICs and strips • Other amortizing assets; • Nonamortizing assets; • Nonmaturity deposits; • CDs, time deposits and other borrowings. These categories are subdivided into time bands that reflect the maturity or repricing characteristics of the balance sheet items: • 0-3 months; • 3-12 months; • 1-3 years; • 3-5 years; • 5-15 years; • over 15 years. EVMCaveats The EVM is a supervisory monitoring tool intended to provide examiners with a rough estimate of the interest rate risk exposure of a financial institution. As such, it is meant to be a starting point to help Federal Reserve staffaddress potentially significant interest rate exposures during offsite monitoring and the examination process. Examiners should not view the EVM or its results as being the final word in the level and source ofa bank's interest rate risk. A bank's balance sheet sensitivity may differ, perhaps materially, from the level of risk suggested by the EVM. This is most likely to occur when the actual maturity and repricing characteristics ofmortgage-related assets and nonmaturity deposits differ from those used in the EVM. Differences may also occur when financial institutions use derivatives to hedge interest rate exposure. The use of interest rate derivatives is not captured within the EVM. When banks successfully use derivatives to hedge, the Net Change in Economic Value statistic presented in the Focus Report will not accurately reflect the bank's interest rate sensitivity. Ifexaminers encounter situations where a bank's internal IRR model exhibits material differences from the results of the EVM, they should check to see ifthe bank is hedging and investigate the reasonableness ofthe assumptions used in the bank's internal model. -Cheryl Sulima, CFA and Craig West, Ph.D. Operational Risk Management Issues W h_at e:pctly does operational nsk rn~an? The core definition reads aS' follows: "Operational risk is the risk of direct or indirect loss resulting from inade- quate orfailed internal processes, peo- ple, and systems, or from external events."1 One school of thought states that operational risk is anything that evades traditional market and/or credit risk definitions. A broader and more useful definition would take into account th tacit linkage between the trinity ofmarke: credit, and operational risk. As borne ou~ by empirical evidence from the recent ~ussian debt crisis and accompanying global contagion,' risks tend to converge and blur during a systemic and widespread market meltdown. As such, settlement, collateral, and netting risks may not be classified purely as operational risk, given that they contain elements of more than one risk,2 A more comprehensive definition would also allow a subset of operational risk management (ORM) to address the component of model risk, given that firms engaged in the use of non-vanilla and· highly structured transactions encounter ris_k of loss from inappropriate use of modeling techniques. Irrespective of its formal defi 't· .. 1 h m 100, 1t i~ c ear t at ORM has been elevated to e forefront ofrisk management initiatives .or financial institutions, and is greatly impacted by the following: 6 1 The Interest Rate Risk F an examiner too[ A ocus Report is primarily provided to bank · copy of the report should be ers only in th rate risk review a d h e context ofan interest n s ould be ca full the banker by an e . re Y explained to . xanuner trained in its circumstances should b use. Under no a anker receive aF for a bank other than hi /h ocus Report 2 s er own. These issues are furth d . . er eta1led in a publi . entitled Interest Rate R•k F cation IS ocus Report - A Us ' . prepared by the Capital Mark . ersGuide . . ets Umt. Copies of this gmde are available upon request· 1. . ' p ease contact the editor ofthis newsletter for m . r . ore m1ormauon 3 For additional information O C II · . n ° atenzed Mortgage Obligations, see "Advanced CM . OAnalyhcs for Bank Examiners", a Product Summa . . ry prepared by the Fmanc1al Markets Unit of the F d Ie era Reserve Bank ofChicago in May 1995. 4 For example, the proxy financi· I .a instrument chosen for the grouping "1-4 family m rtgag 10 e oans repricing in less than 3 months" is a 6.S% COFI ARM. • Basle Committee on Banking Supervision3 - The Committee inter- viewed roughly thirty large banks from various member countnes on ORM topics. The interviews reve~ed . al . k 1u·ve to trading that operaaon ns re a . d b ' everal banks activities was v1ewe ) s h. . . rressed t at as high. A few mstttunons s . k t confined to operational ns was no . . ffj ctiv1ues but typical back o ice a ffi and essen- enveloped the front O ice ' . s . s operanon . tially any facet of busmes . k. ' . thens ,n The Committee, referencmg h dealers 111aY financial markets t at duct . h ·tyorcon exceed their aut on • ky h' cal or ns business in an unet 1 1 111ent d the deveop manner, has propose . 1 ·5k.uona n of capital charges for opera
  • 7. •if ---- operationalRiskManagementIssuescontinued .I Thenewcapitaladequacyframework stressesthedevelopmentofaninternal capitalassessmentprocessandthe establishmentofcapitaltargetlevels commensuratewiththeinstitution's riskprofileandcontrolenvironment. Theproces.swouldbesubjecttosupervisory re~ewandintervention,asappropriate.' " •CapitalAttribution-Theincreasing scopeandcomplexityofbusiness initiativesatmanyorganizationswas theimpetusforSR99-185 Assessing CapitalAdequacyinRelationtoRiskat l.ArgeBankingOrganizationsandOthers withComplexRiskPrefiles.Theletter promulgatesthatlarge,complexbanking organizations(LCBOs)willbe expectedto"takegreatereffortsto assurethatcapitalisnotonlyadequate tomeetformalregulatorystandards, butalsoisfullysufficienttosupport theirunderlyingriskpositions." Further,theguidancestatesthatfor organizationsactivelyinvolvedin complexrisktransfers,examiners shouldexpectasoundinternalcapital adequacyanalysisframeworktobe presentimmediatelyasamatterofsafe andsoundbanking.Complexrisk transfersincludeCLOs,creditderivatives, andcredit-linkednotes.Institutions areexpectedtohaverobustmethodologies inplacetomanagethoserisks incurred,allmaterialonandoffbalance sheetrisksshouldbeadequately addressed,andcontrolsshouldbe establishedtoensureobjectivityand consistency. Industry-wide,riskandfinancial managersarefacedwiththedilemmaof howtomeasureoperationalrisk.Ina recentspeechattheFederalReserve BankofChicago,ChairmanGreenspan expressedconcernthatoperationalrisk cannotbepreciselyquantifiedand,further, thatsomemarketsparticipantsdonot quantifyoperationalriskatall,effectively assumingittobezero.6 Thetwo-pronged approachthatmanybanksemploytoaddress ORMissuesiscomposedofday-to-day ownershipatthebusinesslineandunit ...........___ levelcoupledwithobjectiveaccountability forownership.Tofacilitateandenforce thelatterpartoftheapproach,many firmsareimplementingametrics-based formattogaugebusinesslineperformance sothat,say,MIStrackedperformancecan betiedbacktomanagementandline employeeperformancereviewaswellas compensation.Whereasinternalaudithas inthepastservedasthebarometertogauge theidentifiedORMuniverse,business linesandcentralizedORMdepartments arenowexpectedtoproactivelydefine, identify,monitor,andmanageORMlevels. TheworkingsofORMareco"nverging towardsanorganizationalstructureand managementfr.uneworkwherebyenterprise- wideORMleveragesoffofatwo-phase foundationconsistingof •Businesslinemanagementownership (bottom-upapproach)thatspansthe 'frontline'and •Centralizedmacro-managementand supervisionwithinanORMdepartment thatisresponsibleforacutelyand attentivelymonitoringoperational risklevels(thetop-downmethod). Anemergingqualitativemeasurefor ORMistheriskcontrolself-assessment (RCSA).LCBOinternalauditdepartments oftenutilizeriskcontrolassessments.For ORMpurposeslinemanagementwould performaRCSA,therebyreinforcingits ownershipandaccountabilitythereof, withtheprincipalroleofauditnow envisionedtobeRCSAvalidation.An ORMissueparticulartoLCBOsingeneral andcapitalmarketsinparticularisthe adventofstraightthroughprocessing (STP).7 Ofteninthepast,separateand distinctoperatingsystemsexistedforthe fiontandbackofficeandwereindependently reconciled,oftenmanually.Todaymany institutionshaveestablishedseamless fronttobackprocessingwhereincertain casesnophysicalticket,onlyanelectronic ticket,exists.STPaffordsanexcellent audittrailbyeliminatingthephysical pass-offsofitspredecessorenvironment. Interestingly,though,operationalriskhas nowbeentransferredfromareconciliation 7 controlpointtoonethatisnowreliant upontheintegrityoftheoperatingsystem anditsembeddedcoding. Effectivemanagementandmitigation ofoperationalriskrequiresactivebuy-in andparticipationfromseniormanagement, linemanagement,externalauditors, internalauditors,andregulators.As evidencedbythefactthatover$7billion ofoperationalriskrelatedlosseswere reportedin1999byfinancialservices firms,'theconsensusremainsthatoperational riskisindeedacrucialissue,tantamount tocreditriskinitspropensitytoadversely affectafirm'ssafetyandsoundness. -KenSwensen 1 TaraMcLenaghenandKateLeibfried, "DefiningtheProblem:'PriceWaterhouseCoopers presentationattheOperationalRisk-TheNew Frontierconference,NewYork,November15,1999. 2 OperationalRiskManagement.Basie CommitteeonBankingSupervision,Basie, September1998. 3 Ibid. 'http://www.bis.org/publ/bcbs50.htm. 5 http://fedweb.frb.gov/fedweb/bsr/srltrs/ sr9918.htm. 6 Speechdeliveredatthe36thAnnualConference onBankStructureandCompetitionoftheFed;ral ReserveBankofChicago,May4,2000. 7 ManythankstoGloriaIkosiforhereditorial assistance. 8 "BackgroundonOperationalRisk",Price WaterhouseCooperspresentationattheOperational Risk-TheNewFrontierconference.
  • 8. FEDERAL RESERVE BANK OF CHICAGO P.O. BOX834 CHICAGO, ILLINOIS 60690-0834 Rthm, Strvic, Rtq•tsttd Publisher Adrian D'Silva (312) 322-5904 Director, Capital Markets Editors Joe Cilia (312) 322-2368 Senior Capital Markets Analyst Craig West (312) 322-2312 Senior Capital Markets Analyst Capital Markets Group of Supervision and Regulation 14th Floor Federal Reserve Bank ofChicago P.O. Box 834 Chicago, IL 60690-0834 PRESORTED FIRST-CLASS MAIL ZIP + 4 BARCODED U.S. POSTAGE PAID CHICAGO, IL PERMIT NO. 1942