DTCC’s 劳拉Klimpel Discusses Some of FICC’s 清算 Access Models Available to Clients
行业专家, regulators and senior market participants recently gathered at the ISDA/SIFMA AMG Derivatives Trading Forum on September 21 in New York City to discuss “The Path to Resilient Treasury Markets,，以及对美国经济的影响.S. 美国财政部的清算授权.S. Securities and Exchange Commission (SEC) would have on market participants, 市场结构, 弹性, 流动性, 抵押品, 以及其他金融市场, 包括国债期货和衍生品.
With a September 2022 proposal under consideration for expanded central clearing of certain cash U.S. 国库券和回购, the SEC has also proposed that clearing agencies like DTCC’s Fixed Income 清算 Corporation (FICC) take steps to facilitate access to client clearing. During the panel session, “Enabling Client Access and Links with Other Markets,” 劳拉Klimpel, General Manager of FICC and SIFMU业务发展负责人, discussed some of the client clearing access models that are available and how they might evolve if clearing increases.
Klimpel强调了DTCC最近的白皮书，“展望未来:评估a Potential Expansion of U.S. 库务署中央结算，并解释了这项研究和主要发现.
Related: 展望未来:评估a Potential Expansion of U.S. 库务署中央结算
“One of the surprising – or maybe not surprising – key findings in the paper is that the market is not all that familiar with the different flavors of access models that FICC has available today,克林佩尔说. “Survey respondents indicated in their feedback significant gaps in market awareness and understanding of FICC’s access models, 我们的风险工具和能力. With this proposal for central clearing moving so fast, it is critical that we ensure that there is a complete understanding of all the options – both direct, 全方位服务会员和间接会员 – and then what we might need to do to enhance them.”
FICC currently offers a variety of direct and indirect participation models for buy-side and sell-side market participants, 包括净会费, Centrally Cleared Institutional Tri-Party (CCIT™) Service Membership and sponsored membership. The different models are intended to be flexible to allow market participants to access FICC in the way that best meets their business and regulatory needs. Klimpel also described the differences in membership standards and risk profiles between the indirect and limited clearing models available – Sponsored Service, Prime Broker and 记者清算 – and why a firm might be inclined to choose one of these access models over another.
在报纸上, one of the data points was that a significant number of non-member respondents stated that they are ‘not familiar’ with the fact that Registered Investment Companies – also known as ‘40 Act Funds – can actually become direct members of FICC,克林佩尔说. “进一步, 根据研究, a majority of FICC members remain unsure which of FICC’s access models they want to use. This, I think, speaks to the level of uncertainty about the changes ahead for indirect participant activity if this proposal is implemented 作为写.”
With this proposal for central clearing moving so fast, it is critical that we ensure that there is a complete understanding of all the options – both direct, 全方位服务会员和间接会员
根据该提案，保证金抵消将如何发挥作用, and the requirement for physical segregation of margin, is one of the main policy issues related to expanded Treasury clearing still to be resolved, Klimpel说.
“Today, 直接会员须向FICC缴交保证金, 根据其风险管理计算. And the underlying client is permitted – but not required – to contribute to the margin,克林佩尔说. “Under the expanded proposal, will customers now be required to contribute to the margin? The CFTC required it as part of their derivatives mandate. But in this case, the SEC expanded clearing proposal does not – which is an interesting choice. For the time being, the way that FICC is set up, we permit, but we do not require it. 这个提议, 然而, 作为写, would require that FICC hold in segregated accounts any margin postings by indirect participants for which their broker/dealer clearing intermediary is seeking a debit in the SEC Rule 15c3-3 formula, and that such separately held margin also be excluded from FICC’s default loss waterfall.”
Related: CME Group and DTCC Receive 监管 Approval for Enhanced Treasury Cross-Margining Arrangement Launching January 2024
“我们刚刚获得了SEC和CFTC的批准, and we are very excited for the cross-margin agreement going live in January 2024,克林佩尔说. “The new cross-margining arrangement will permit eligible clearing members to cross-margin an expanded suite of products. And this is a great start, but we, of course, want it to go even further. 我们非常感激 that Commissioner Pham asked FICC and CME to co-lead a workstream of the Global Markets Advisory Committee (GMAC) Subcommittee on Global Market Structure, to consider what an end-user cross-margin arrangement could look like across the CFTC and SEC.”
新的白皮书, 是九月发行的吗, was developed to provide data and information to the industry, 利益相关者, and the broader community about the potential impacts of the proposal. 基于自愿的, 匿名, 对市场参与者进行深入调查, 买方和卖方都有, the survey responses collected were also combined with data that FICC has available on currently cleared Treasury activity.