Abstract

As noted in the previous sections, some of the features of OTC derivatives contracts and markets that provide benefits and enhance efficiency either separately or jointly embody risks to financial market stability. OTC derivatives activities are governed almost exclusively by decentralized private infrastructures (including risk management and control systems, private netting arrangements, and closeout procedures) and market-disciplining mechanisms. By comparison, the more formal centralized rules of exchanges protect the stability and financial integrity of the exchange. In addition, the major financial intermediaries in OTC derivatives markets have access to financial safety nets. Because this can affect their behavior, they are required to adhere to prudential regulations and standards in the form of minimum risk-adjusted capital requirements and accounting and disclosure standards that inform financial stakeholders and to some extent support market discipline. The financial industry also has its own standards and best practices promulgated by various industry groups.

As noted in the previous sections, some of the features of OTC derivatives contracts and markets that provide benefits and enhance efficiency either separately or jointly embody risks to financial market stability. OTC derivatives activities are governed almost exclusively by decentralized private infrastructures (including risk management and control systems, private netting arrangements, and closeout procedures) and market-disciplining mechanisms. By comparison, the more formal centralized rules of exchanges protect the stability and financial integrity of the exchange. In addition, the major financial intermediaries in OTC derivatives markets have access to financial safety nets. Because this can affect their behavior, they are required to adhere to prudential regulations and standards in the form of minimum risk-adjusted capital requirements and accounting and disclosure standards that inform financial stakeholders and to some extent support market discipline. The financial industry also has its own standards and best practices promulgated by various industry groups.

Private, decentralized mechanisms have so far safeguarded the soundness of the internationally active financial institutions, in part because many of them have been well capitalized. However, these mechanisms did not adequately protect market stability, and markets and countries only remotely related to derivatives activities experienced instability because of spillovers and contagion. For example, while no major institution failed during the mature markets turbulence of 1998 surrounding the near-collapse of LTCM. private, decentralized market-disciplining mechanisms failed to prevent the buildup and concentration of counterparty risk exposures within the internationally active financial institutions.

Sources of Instability in OTC Derivatives Activities and Markets

The features of OTC derivatives markets that can give rise to instability in institutions, markets, and the international financial system include the dynamic nature of gross credit exposures; information asymmetries; the effects of OTC derivatives activities on available aggregate credit; the high concentration of OTC derivatives activities in the major institutions; and the central role of OTC derivatives markets in the global financial system.

The first underlying source of market instability is the dynamic nature of gross credit exposures, which are sensitive to changes in information about counterparties and asset prices. This feature played an important role in most of the crises in the 1990s. A disruption that sharply raises credit exposures has the capacity to cause sudden and extreme liquidity demands (to meet margin calls, for example). Just as traditional banks were not always prepared for sudden abnormally large liquidity demands and withdrawals of deposits during hank runs, today’s derivatives market participants may not be prepared for sudden and abnormally large demands for cash that can and do arise in periods of market stress.

A second, well-known and related, source is information asymmetries, as in traditional banking.99 Not having sufficient information on borrowers complicates the assessment of counterparty risks. This problem is exaggerated for the credit exposures associated with OTC instruments because of the price-dependent, time-varying nature of these credit exposures. A counterparty’s risk profile can change very quickly in OTC derivatives markets. As a result, information asymmetries in OTC derivatives markets can be more destabilizing than in traditional banking markets because they can quickly lead intermediaries and market makers to radically scale back exposures, risk taking, and the amount of capital committed to intermediary and market-making functions.

Third, OTC derivatives activities contribute to the aggregate amount of credit available for financing, and also to market liquidity in underlying asset markets. The capacity for the internationally active institutions to expand and contract off-balance sheet credit depends on the amount of capital they jointly devote to intermediation and market making in derivatives markets. This capital can support more or less activity depending on several factors, including the risk tolerances (amount of leveraging) of the intermediaries and market makers; the underlying cost of internal capital or external financing; and financial-sector policies (for example, capital requirements). A determinant of the cost of capital for OTC derivatives activities is the risk-free interest rate (such as on 10–year U.S. Treasury bonds), which is also used for pricing contracts. When underlying financing conditions become favorable, the OTC-intermediation activities can become more profitable and more cheaply funded and the level of activity can expand relative to the base of equity capital in the financial system. This tendency for expansion (and, when conditions change, contraction) can become self-generating, and it can, and has, occasionally become hypersensitive to changes in market conditions.

Fourth, as noted, aggregate OTC derivatives activities are sizable and the trading activity ($1 trillion daily turnover) and counterparty exposures are highly concentrated in the internationally active financial institutions. This makes the institutions and global markets susceptible to a range of shocks and dynamics that impinge on one or more major counterparties. The reason for this concentration is clear. Profitability requires large-scale investments in information technologies (such as sophisticated risk management systems) and also requires a broad client base and the ability to deal in a wide variety of related cash products. Only the largest organizations with global reach and international networks of clients and distribution channels can effectively compete as the central players in OTC markets. As a result, intermediation and market making are performed by global institutions, who hold and manage the attendant risks through, among other methods, hedging and trading. The major intermediaries have access to financial safety nets, which may impart an element of subsidy in the pricing of credit and other risks. This is problematic because it could contribute to an overextension of credit. This concentration makes OTC derivatives markets and the institutions trading in them potentially vulnerable to sudden changes in market prices for underlying assets (for example, interest rates and exchange rates) and in the general market appetite for risk.

Fifth, OTC derivatives activities closely link institutions, markets, and financial centers. This makes them possible vehicles for spillovers and contagion. About half or more of OTC derivatives trading in the largest segments lakes place across national borders. Linkages arise from the contracts themselves (currency swaps mobilize liquidity across the major international financial centers) and also through the international institutions that make up these markets. In addition, hedging, pricing, and arbitrage activities link OTC derivatives markets to the major cash and exchange-traded derivatives markets; for example, hedging and arbitrage activities link the market for interest rate swaps and the markets for bonds, interest rate and bond futures, and interest rate options. The interlinkages and the opportunities for arbitrage that they provide add to the efficiency and complexity of the international financial system. At the same time, interlinkages also mean that disruptions in OTC activities necessarily entail spillovers and contagion to these other markets.

To summarize, certain features of OTC derivatives and how they are traded and managed make OTC derivatives markets subject to instability if the wrong combination of circumstances arises. This instability arises, in part, because OTC derivatives markets are centered around the internationally active financial institutions that each are counterparty to tens of thousands of bilateral, price-dependent, dynamic credit exposures embodied in OTC derivatives contracts. OTC derivatives contracts bind institutions together in an opaque network of credit exposures, the size and characteristics of which can change rapidly and, moreover, are arguably not fully understood with a high degree of accuracy even by market participants themselves. These institutions allocate specific amounts of capital to support their perceived current and potential future credit exposures in their OTC derivatives business. However, risk assessments and management of these exposures are seriously complicated by a lack of solid information and risk analyses about the riskiness of both their own positions and those of their counterparties. As a result, this market is characterized by informational imperfections about current and potential future credit exposures and market-wide financial conditions.

The potential for instability arises when information shocks, especially counterparty credit events and sharp movements in asset prices that underlie derivative contracts, cause significant changes in perceptions of current and potential future credit exposures. Changes in perceptions, in turn, can cause very large movements in derivatives positions of the major participants. When asset prices adjust rapidly, the size and configuration of counterparty exposures can become unsustainably large and provoke a rapid unwinding of positions. Recent experience strongly suggests that the ebb and flow of credit exposures among the large internationally active financial institutions can be severely affected by some events, which cannot be easily predicted and which can lead to potentially disruptive systemic consequences.

Weaknesses in the Infrastructure

There are also aspects of the infrastructure for OTC derivatives activities that can lead to a breakdown in the effectiveness of market discipline and ultimately produce unsustainable market conditions and affect market dynamics, including producing or exacerbating underlying instabilities through inadequate counterparty risk management; limited understandings of market dynamics and liquidity risk; and legal and regulatory uncertainty. All of these areas can be improved through efforts, separately or jointly, by financial institutions, supervisors, and market surveillance.

Inadequate Counterparty Risk Management

Although counterparty risk is now widely understood to be of primary importance, discussions with internationally active financial institutions and supervisory authorities suggest that limited progress has been made so far in improving the management of credit risk associated with OTC derivatives.100 Progress has been particularly slow in developing techniques for managing the interactions of credit and market risk. Even less well understood are the interactions with liquidity, operational, and legal risk.

Several factors explain this limited progress. First, counterparty disclosure has not improved significantly since 1998. The leading providers of intermediation and market-making services in OTC derivatives markets have serious concerns about the dearth of information supplied by clients. Second, the conceptual and measurement challenges involved in understanding counterparty risk and other risks are unlikely to be resolved soon. Even sophisticated institutions acknowledge that significant additional progress is necessary.

Widespread problems with ex-ante counterparty risk assessment and pricing produced turbulence in OTC derivatives markets, in part because incentives for prudent risk taking proved to be insufficient to prevent the buildup and concentration of counterparty risk exposures in the autumn of 1998. After the turbulence, however, some of these same incentives worked better, including the discipline from losses in shareholder value and the associated lower bonuses for managers, and the discipline imposed by senior management in determining the risk culture, in setting risk tolerances, and in implementing risk management and control systems. Thus, experience in the LTCM affair appears to have taught some valuable lessons. It remains to be seen, however, if corrections that are being implemented will prove adequate in the future.

If information to assess creditworthiness is insufficient, the reliance on collateral is generally a reasonable counterparty-risk-mitigation technique. However, the assets held as collateral are subject to market risk and their value can decline precipitously when the protection they offer is most needed, namely, during periods of turbulence when the probability of counterparty default can rise significantly. This risk may not have been adequately accounted for in the management of OTC derivatives trading books.

Institutions acknowledge that there were inadequacies in collateral management and uncertainties about legal claims on collateral. Both contributed to market turbulence in the 1990s by encouraging financial institutions to liquidate collateral into declining markets. In addition, in the run-up to the turbulence of the autumn of 1998, counterparties tended to demand low or no haircuts on collateral, because of competitive pressures and the relatively low cost of funding at that time. These measures could have offered protection against declines in collateral values and helped to reduce pressures to liquidate collateral into declining markets.

According to internationally active financial institutions, globally integrated collateral management systems are being developed to overcome some of these difficulties. But only large institutions can afford, develop, and utilize them. Discussions with market participants suggest that it will most likely take some time (another 12 months from June 2000) before any of the leaders in this field have such systems up and running. Second-tier institutions, including most hedge funds, seem to have fallen further behind in the application of risk-management tools, which may partly explain why some hedge funds have recently withdrawn from some markets and scaled back highly leveraged activities.

Limited Understanding of Market Dynamics and Liquidity Risks

Market participants and officials acknowledge they have a limited understanding of market dynamics in OTC derivatives markets and their implications for related markets. Views diverge on whether OTC markets absorb financial shocks or whether they amplify shocks and contribute to volatility. Some believe derivatives markets dissipate shocks by facilitating hedging, while others see these markets as a channel of contagion. Market participants also disagree about how OTC derivatives markets affect the distribution and mix of credit, market, liquidity, operational, and legal risks. One view is that they redistribute risks to those most willing to hold them. Another is that they transform risks in ways that are inherently more difficult to manage because, while reducing market risk, they create credit, operational, and legal risk. Views on relationships between liquidity in derivatives, secondary, and money markets vary considerably. Finally, there is widespread uncertainty about how monetary conditions influence prices and liquidity in OTC derivatives markets.

Market participants acknowledge that they failed to realize the importance of liquidity risk in OTC derivatives, and that the capacity to manage it is still in an embryonic stage. One common mistake was that risk management systems assumed that markets would remain liquid and price changes would follow historical norms. Risk managers also failed to engage in stress testing that examined the implications of severe liquidity problems. Few firms were, for the purposes of risk management, marking credit exposures to estimated liquidation values instead of to current market values. Even these firms seemed to rely on stress tests that did not fully capture the dynamics that were revealed in 1998.

Marking positions to liquidation values is likely to become standard practice at sophisticated financial institutions. However, liquidation values may not be uniquely determined, because asset prices are widely seen as behaving in nonlinear ways at stress points. Thus, even sophisticated institutions will make modeling errors. Less sophisticated firms may rely on margining requirements and haircuts. But this too has its limitations in times of stress: reliance on margin calls to limit counterparty credit risk, normally an effective risk management tool, also can contribute to liquidity pressures in apparently unrelated markets and can raise the likelihood of default by financial institutions that would be solvent under normal market conditions. Likewise, over-reliance on VaR and mark-to-market accounting, and other rules that encourage frequent portfolio rebalancing, can induce large-scale selling of positions.101

To address the challenges posed by liquidity risks and market dynamics, sophisticated institutions are beginning to focus on the total risk they face rather than on the individual risks (market, credit, liquidity, operational, and legal risk) separately. Particularly challenging is the link between liquidity and counterparty risk, which may depend on the underlying trading, risk-mitigation, and legal infrastructure. Liquidity risk can become closely linked to credit risk, because a loss of liquidity can depress market prices and increase the credit exposure on OTC derivatives. Conversely, heightened concerns about counterparty credit risk can precipitate a loss of liquidity by causing market participants to pull back from markets. International financial institutions recognize the need to incorporate linkages into risk management systems, and the formidable challenges of measuring and modeling them. The September 1998 market turbulence may have been the first event that revealed the importance of these linkages, so institutions may still lack sufficient experience to incorporate them into their stress tests in a reliable way. Future improvements in the management of total risk should contribute to the smooth functioning of OTC derivatives markets.

Legal and Regulatory Uncertainties

Another important source of weakness in the financial infrastructure is legal and regulatory uncertainty. This type of uncertainly encompasses the possibility that private arrangements to mitigate risks (such as definitions of default and legality of close-out and netting arrangements) may turn out to be ineffective. To the extent that risk mitigation fails to work as designed, misperceptions, mispricing, and misallocation of financial risk can result. Legal and regulatory uncertainties can also be important sources of liquidity risk, because they can contribute to adverse market dynamics.

Cumbersome closeout procedures and uncertain enforcement of security interests in collateral can be impractical and ineffective in protecting firms against default. According to market participants, such concerns contributed to the rapid liquidation of collateral in the autumn of 1998. But closeout procedures are as legally uncertain now as they were then. The uncertainty arises because of important differences in bankruptcy laws among countries. Specifically, a number of countries do not allow the termination of contracts upon the initiation of insolvency proceedings, giving the trustee the opportunity to continue those contracts that are favorable to the estate (“cherry picking”). Moreover, even among countries that allow for the termination of contracts, some do not allow for the automatic set-off of contractual claims, which is necessary for netting and closeout. Regarding the enforceability of security interests in collateral, there is a growing convergence among national bankruptcy laws to allow for the stay on the enforcement of security interests. In these cases, the law will often provide that the interest of secured creditors will be protected during the stay (for example, by compensating for the depreciation of the value of the collateral). One uncertainly that arises in many countries is whether such protection will be provided and, if so, whether it will be adequate.

When market participants cannot close out positions or reclaim collateral as specified in private contracts, collateral does not give the expected protection against credit risk. When this is realized in “real time,” credit risk can quickly cross a threshold and is perceived as a default event. With this kind of uncertainty, firms holding collateral with creditor-stay exemptions (which allow counterparties to close out exempt OTC derivative transactions outside of bankruptcy procedures) have the incentive to exercise their legal right to sell collateral. Closeout valuations require three to five market quotes per contract, and a derivatives desk may have thousands of contracts with a single counterparty. A dealer attempting to close out roughly the number of swaps with LTCM might have had to collect 16,000 market quotes from other dealers at a time of market stress when every other major desk was attempting to do the same. It would be an improvement to permit alternative valuation procedures, including good-faith estimates, internal valuations, or replacement value, and this possibility was still under discussion two years after the near-collapse of LTCM.

Widely used netting agreements (such as the ISDA master agreement) have limitations in mitigating risk. Netting arrangements can reduce the credit exposures on a large number of transactions between two counterparties to a single net figure. As such they are a risk-mitigating technique with significant potential to reduce large gross credit exposures. If netting cannot be relied upon as legally enforceable, the hint of default can trigger the unwinding of gross exposures. The failure to recognize this possibility may be a source of misperceptions of risk. Several initiatives are currently under way to facilitate bilateral and multilateral netting, but they are typically only for specific instruments (for example, RepoClear).

Significant uncertainties also exist about the various legal and regulatory environments in which OTC derivatives transactions are conducted, owing to the high pace of innovation, the relatively limited extent of legal precedent, the cross-border nature of OTC derivatives markets, and the supervisory and regulatory framework. Legal risks include the possibility that a counterparty may “walk away” from obligations, or may cherry pick; it may dispute the terms of an agreement; it may claim that it did not understand the agreement; and it may claim that it did not have the authority to enter into the agreement.

In the United States, there is legal ambiguity about whether certain types of swaps are subject to CFTC approval and oversight. This has contributed to reluctance to standardize swap contracts and to centralize clearing.102 Some market participants believe there is also a need to modernize bankruptcy procedures to strengthen the legal certainty of risk-mitigation methods and the definitions of what constitutes a default, which is particularly relevant for the development of credit derivatives. For example, some see a need to extend creditor-slay exemptions under U.S. bankruptcy law beyond swaps and repurchase transactions to other OTC derivatives contracts.

Outside U.S. and U.K. laws, many jurisdictions are ill-suited for effective modern risk management. For example, collateral may afford limited protection in bankruptcy (unless the collateral is held in these two jurisdictions). Legal staffs at major dealer and market-making institutions see significant legal uncertainties associated with the use of collateral in advanced countries (Canada, Italy, and Japan). While the legal and regulatory environments for OTC derivatives are complex in the United States and the United Kingdom they are considerably more complicated elsewhere. The same instrument might be legally defined as a swap transaction in one country, an insurance contract in a second country, and a pari-mutuel-betting instrument in a third country. Market participants are making strong efforts to mitigate the legal risks, but there are limits to what the private sector can accomplish because contracts must ultimately be enforceable in a legal system.

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