2022年9月，美国将与俄罗斯达成协议.S. Securities and Exchange Commission (SEC) proposed expanding the scope of U.S. Treasury activity that must centrally clear through an SEC-regulated covered clearing agency. The proposal came in the wake of unprecedented Treasury market volatility in 2019 and 2020, 并寻求规范风险管理, 降低结算风险, centralize default management and increase transparency in the world’s largest and most liquid sovereign debt market.
相关内容:让美国经济复苏.S. Treasury Market Safer for All Participants: How FICC’s Open Access Model Promotes Central 清算
As the only SEC-regulated covered central counterparty for outright purchases, 美国的销售和回购交易.S. Treasury securities, 存’s Fixed Income 清算 Corporation (FICC), through its 政府证券科 (GSD), has been working to understand the implications – and to help market participants prepare.
作为这项工作的一部分，FICC最近 调查 a wide swath of market participants and trade associations from various market segments, 包括那些目前直接通过FICC进行清算的银行, those that clear indirectly through a sponsor and those that trade bilaterally. We learned that nearly 75% of FICC member respondents submit 50% or less of their indirect participant Treasury activity to FICC – suggesting the remainder clears and settles bilaterally.
基于此, FICC estimates SEC的提议 could potentially add $500 billion in indirect participant Treasury repo activity, $520 billion of indirect participant Treasury reverse repo activity and $605 billion of indirect participant Treasury cash activity – a total of some $1.每天63万亿美元.
对市场参与者的影响
The immediate effect of the expanded clearing proposal is that more firms will need to either become direct FICC members or clear their Treasury activity through a member, 谁将充当其清算中介.
调查, 然而, revealed that respondents do not understand FICC’s various access models and that most members are unsure which model to use for indirect participant activity. 具体地说, 52% said they were unsure which model to use for Treasury reverse repo and Treasury repo activity, while 58% said they were unsure which to use for indirect participant Treasury cash activity.
FICC currently offers a variety of different direct and indirect participation options for buy-side and sell-side market participants to allow firms to tailor access to FICC to the manner that best meets their business and regulatory needs. 符合其监管义务, FICC has established clear and objective membership requirements for each membership category. Its minimum membership standards are designed to provide fair and open access for firms but are also robust enough to allow FICC to manage the associated material risks.
会员模式包括净额会员、 中央清算机构三方 (CCIT™)服务会员和赞助会员. 由于他们与FICC的直接关系 网会员 and CCIT™ Memberships are considered direct participation models under SEC的提议. Sponsored membership, on the other hand, would be considered an indirect participation model. FICC also offers market participants that are not FICC / GSD members indirect access through an intermediary which participates in either its 主要经纪商结算 或通讯结算服务.
更改了边际收集和隔离
The proposal would also mean significant changes to margin collection and account segregation. 目前, FICC一般不要求会员的所有权, 或“房子,” activity be segregated from the cleared activity of the members’ customers. 然而, SEC的提议, 作为写, 需要FICC计算吗, 分别收集和保管房屋和客户保证金, although there would be an option to calculate and collect margin on a gross or net basis, 取决于成员选择的清除模型.
FICC also expects the increased indirect participant Treasury volume to correspondingly increase the Value at Risk (VaR) margin, 保守估计是26美元.在FICC / GSD会员中有60亿美元. This assumes all additional indirect participant activity clears through one of the FICC’s gross margin models, 但如果经济活动通过净利润率模式得到清理，这一比例可能会更低.
调查 revealed that respondents do not understand FICC’s various access models and that most members are unsure which model to use for indirect participant activity.
解决其他关注的问题
调查 also uncovered a variety of concerns by market participants, many of which can be addressed by existing FICC tools and service options. This indicates market participants are unaware of the range of resources FICC offers.
例如, the survey found that only 58% of FICC / GSD netting members use the FICC VaR calculator, 一个在线, 互动, 估算清算资金需求的网络工具. 在回应, FICC will develop and publicize additional educational tools to help members understand how to use the VaR calculator.
大多数(56%)的受访者还表示他们不熟悉 UST清算.com, a microsite the FICC launched in 2022 that serves as a central hub for information, 例如FICC的各种财政部活动服务, 其直接参与和间接参与模式, 其风险管理实践, 和治理. FICC will similarly increase industry outreach to raise microsite awareness to encourage greater use.
我们致力于与会员合作, 他们的客户, 整体市场, and public-sector stakeholders to understand the impact of and to prepare for expanded clearing requirements. 调查 underscores the need to redouble efforts to engage with the industry to ensure a smooth transition should the SEC implement its proposed changes.