Progress report on the CCP work plan

CHAIRS OF THE FSB SRC, FSB RESG, BCBS,

CPMI AND IOSCO

22 September 2015

Progress Report on the CCP Workplan

1. Introduction

In 2009, the G20 Leaders committed to ensuring that all standardised OTC derivatives

contracts are cleared through central counterparties (“CCPs”). Fully realising the benefits of

CCPs requires CCPs to be subject to strong regulatory, oversight and supervisory

requirements. First, CCPs must be sufficiently resilient in the sense that risk management

standards and financial resources (including stress testing, margin requirements, pre-funded

default funds, and liquidity resources) allow CCPs to understand and mitigate risks, and to

withstand clearing member failures and other stress events to a very high probability. Second,

CCPs must have recovery plans that allow them to allocate excess losses and generate

additional liquidity to safeguard their own viability without endangering the stability of

clearing members and other financial institutions, many of whom are likely to be systemically

important in their own right. And third, there must be credible CCP resolution plans in place.

The Basel Committee on Banking Supervision (BCBS), the Committee on Payments and

Markets Infrastructures (CPMI), the Financial Stability Board (FSB), and the International

Organization of Securities Commissions (IOSCO), and together with the BCBS, CPMI, and

FSB (the “Committees”), agreed a workplan to coordinate their respective international policy

work aimed at enhancing the resilience, recovery planning and resolvability of CCPs, and to

work in close collaboration. To support these efforts, the Committees also agreed to establish

a joint study group to identify, quantify and analyse interdependencies between CCPs and

major clearing members and any resulting systemic implications. The agreed workplan

focuses on CCPs that are systemic across multiple jurisdictions, consistent with the Istanbul

Communiqué of the G20 Finance Ministers and Central Bank Governors.

A detailed timeline for completing this work is set out in Annex A.

2. CCP Resilience

A number of substantive priorities with respect to CCP resilience have been identified. These

priorities include reviewing existing stress testing policies and practices of CCPs and

considering the need for, and developing as appropriate, a framework for consistent and

comparable stress tests of the adequacy of CCPs’ financial resources (including capital) and

liquidity arrangements. This framework could involve supervisory stress tests. As a

complement to the internal stress tests that CCPs currently conduct, such a framework would

be intended to promote confidence in the adequacy of the financial resources of CCPs and to

support comparison of financial resources across CCPs. A framework for consistent and

comparable stress tests could also help authorities better understand the macro-prudential

risks that could materialise if one or more CCPs come under stress simultaneously. Further,

the adequacy of existing standards with respect to CCP loss absorption capacity and liquidity

should be evaluated, taking into account the implementation of the CPMI-IOSCO Principles

for Financial Market Infrastructures (PFMI).

This evaluation should, inter alia, assess

whether the standards contained in the PFMI for initial margin methodologies are sufficiently

granular and robust. The evaluation should also consider the adequacy of the PFMI’s Cover

1/Cover 2 standard, given the possibility that multiple clearing members could come under

stress during periods of extreme market turbulence.

CPMI-IOSCO serves as the primary forum for this work, regularly interacting with the FSB

SRC. To the extent that certain relevant activities were already initiated before the work plan

was agreed, the respective focus has been adjusted to fully capture the issues identified in the

CCP work plan.

2.1 Stress testing

The work on stress testing policies and practices is well advanced given that this work started

as part of the 2014-15 work programme of CPMI-IOSCO. CPMI-IOSCO held an industry

workshop on stress testing in March in Frankfurt, with representatives of CCPs, clearing

members and representatives from buy-side firms. The purpose of the workshop was to

identify the key areas of concern to the industry related to stress testing. This was used as an

input into the design of a stock-taking questionnaire by CPMI-IOSCO on CCP stress testing

practices.

At the end of April, that questionnaire was sent to over 30 CCPs, including all the major

CCPs and a number of smaller CCPs from different regions. The questionnaire covers six

main areas related to stress testing by CCPs:

(1) governance arrangements that underpin stress testing for credit and liquidity risk;

(2) how the CCP identifies the credit and liquidity risks to which it would be exposed

following the default of one or more members, including the sources of such risks;

(3) how the CCP models extreme but plausible market conditions, including both design

of stress scenarios, and translation of stress scenarios into discrete risk factor moves

(such as adverse price movements);

(4) how the CCP applies the risk factor moves to member/client portfolios to produce

estimates of stressed loss (credit risk) and stressed outflows (liquidity risk);

(5) how the CCP uses these estimates to determine its financial resource requirements

and to verify that it maintains adequate coverage against credit and liquidity risks,

even in extreme but plausible market conditions; and

(6) additional analysis the CCP performs to evaluate the strengths and weaknesses of its

stress-testing framework, including sensitivity analysis and reverse stress tests.

Survey responses were received by mid-June and have been examined with respect to data

quality and internal consistency. A detailed analysis of survey responses to establish the range

of stress-testing practices is currently in progress. The next steps will include:

(i) identification of any critical issues that should be addressed and (ii) drafting of any

http://www.bis.org/cpmi/publ/d101.html.

additional guidance, if needed. Given the very close linkages between stress-testing practices

and other areas of financial risk management by CCPs (for example, margin practices), any

guidance will be developed after a comprehensive analysis of other resilience topics

(discussed below).

A CPMI-IOSCO report for public consultation on all CCP resilience and recovery issues (see

section 2.2 and section 3 below) is expected to be published by mid-2016.

2.2 Other resilience topics

Work on the remaining CPMI-IOSCO work plan topics (namely CCP risk management and

financial resources) was initiated in March 2015. CPMI-IOSCO conducted a second industry

workshop, on 12 May in New York, on margin practices, the adequacy of the PFMI Cover 1/

Cover 2 requirement, and skin-in-the-game. This workshop also addressed CCP recovery

(discussed in section 3 below). The workshop benefited from the views of representatives of

CCPs, clearing members and representatives from buy-side firms.

The surveys were sent to CCPs on 8 July, with responses due on 4 September for the margin

survey, and 21 September for the other surveys. The next steps will include: (i) analysis of

survey responses; (ii) identification of critical issues; (iii) proposals to address the issues; and

(iv) drafting of the consultation report. Discussion on survey results will be held at the end of

2015 with input from the CPMI-IOSCO implementation monitoring work. Any guidance or

standards to be developed, including the consultation report, will follow the same timeline as

that for stress testing and recovery.

A CPMI-IOSCO report for public consultation on CCP resilience and recovery issues is

expected to be published by mid-2016.

2.3 CPMI-IOSCO Implementation Monitoring

The above work streams are complemented and informed by the ongoing CPMI-IOSCO

monitoring of full, timely and consistent implementation of the PFMI by FMIs and relevant

authorities. This entails evaluating the completeness and consistency of implementation

measures, including whether the outcomes at the level of CCPs are consistent principles

contained in the PFMI.

Following the publication of the PFMI in April 2012, the CPMI and IOSCO agreed to

monitor their implementation in the 28 CPMI and IOSCO member jurisdictions. They agreed

to a three-level monitoring framework that involves: Level 1 assessments of the status of the

implementation process; Level 2 assessments of the completeness of the implemented

framework and its consistency with the PFMI; and Level 3 assessments of the consistency in

outcomes of such frameworks and started the work.

The initial Level 1 assessments were conducted in 2013 and a report was published in August 2013 with update reports

published in May 2014 and in June 2015. Alongside the Level 1 assessments, CPMI and IOSCO are monitoring

jurisdictions’ progress at Level 2. The first detailed evaluations of the completeness and consistency of jurisdictions’

implementation measures for the Principles (Level 2) were published in February 2015 for the regulatory frameworks for

CCPs and TRs in the European Union, Japan and the United States. The next round of Level 2 assessments covers all

FMI types, and assesses a further group of jurisdictions sequentially, beginning with Australia in end-April 2015. The

work is in progress and the aim is to publish the assessment results for Australia by year-end 2015. Furthermore, CPMI

In July 2015, CPMI and IOSCO started the Level 3 assessments of the implementation of the

PFMI. This review examines consistency in the outcomes of PFMI Principles implementation

and is part of the CPMI-IOSCO’s monitoring of the implementation of the PFMI.

Beyond the aim of fostering full and consistent implementation of the PFMI, the Level 3

assessment is also expected to inform CPMI and IOSCO about the nature and potential causes

of variations in approaches or outcomes.

The first wave of the review is focusing on a subset of requirements under the PFMI that

relate to financial risk management by CCPs including certain practices related to governance,

stress-testing, margin, liquidity, collateral, and recovery planning. It is considering outcomes

achieved in this area by examining a number of globally- and locally-active CCPs that clear

derivative products (both exchange traded and OTC).

A survey questionnaire was sent to CCPs in early July, with the deadline for responses as 4

September for governance, credit risk, and margins questions, and 21 September for the rest

(on collateral, liquidity risk, and recovery planning). The preliminary findings will be shared

with participating CCPs/authorities to get their feedback.

A CPMI-IOSCO report presenting the results of this Level 3 assessment is expected to be

published in mid-2016.

3. CCP recovery planning

The PFMI requires all systemically important FMIs to have a comprehensive and effective

recovery plan as the disorderly failure of such an FMI could lead to severe systemic

disruptions.

Complementing the PFMI, additional guidance for FMIs was issued in 2014 on both the

recovery planning process and the content of recovery plans.

The guidance provides an

overview of some of the tools that an FMI may include in its recovery plan, including a

discussion of scenarios that may trigger the use of recovery tools and characteristics of

appropriate recovery tools in the context of such scenarios. CCP default waterfalls typically

include the initial margin of the defaulting clearing member, guarantee fund contributions

provided by the defaulting clearing member, equity funds provided by the CCP and guarantee

fund contributions provided by surviving clearing members. Depending on the CCP,

additional losses may be allocated through various recovery tools, such as cash calls on

clearing members, variation margin haircutting, and, where legally permitted, initial margin

and IOSCO are currently examining the completeness and consistency of frameworks and outcomes (combined Level 2

and Level 3) arising from jurisdictions’ implementation of the Responsibilities for authorities included in the PFMI. This

exercise is well progressed and a report is expected to be published later in 2015.

haircutting. Tools for liquidating the positions of the defaulter and re-establishing a matched

book include voluntary auctions and juniorisation of contributions of mutualised resources, as

well as forced allocation of contracts, and partial or full tear-up of contracts

Recovery plans should be designed to maximise the probability of successful CCP recoveries,

while mitigating the risk that recovery actions undertaken by CCPs could result in contagion

to other parts of the financial system.

The Workplan includes two substantive priorities with respect to CCP recovery planning.

Consistent with Section 2, CPMI-IOSCO is serving as the primary forum for this work,

working in close cooperation with the FSB ReSG. First, a stock-take of existing CCP

recovery mechanisms, including loss allocation tools, is currently being conducted as part of

the survey described in section 2.2 above. The stock take will be used to compare recovery

mechanisms across CCPs. Second, CPMI-IOSCO will consider the need for, and develop as

appropriate, more granular standards or guidance for CCP recovery planning, taking into

account the implementation of the requirements for recovery planning in the CPMI-IOSCO

PFMI and the complementing guidance on the recovery of financial market infrastructures.

As mentioned in section 2.2, during the second industry workshop held on 12 May in New

York, CPMI-IOSCO also discussed the recovery planning by CCPs, and the stocktaking

survey on recovery planning was sent out to CCPs during the same time for a 21 September

deadline. The survey focuses on CCP plans for recovery and orderly wind-down, including

loss allocation tools. The survey results will be analysed and options considered for any

guidance or standard setting in early 2016 together with the stress testing and resilience work

streams. A CPMI-IOSCO report for public consultation on CCP resilience and recovery

issues is expected to be published by mid-2016.

Further, as mentioned in section 2.3, CPMI and IOSCO started the Level 3 assessment of the

implementation of the PFMI. The first part of the review is focusing on a subset of

requirements under the PFMI that relate to financial risk management by CCPs, and recovery

planning is included in the scope. The deadline for the survey questionnaire on the recovery

planning part is 21 September.

A CPMI-IOSCO report presenting the results of this first Level 3 assessment is expected to be

published by mid-2016.

4. CCP resolvability

The joint 2015 CCP workplan called for the FSB Resolution Steering Group (ReSG) (i) to

conduct a stock-take of existing CCP resolution regimes and resolution planning

arrangements; (ii) to consider the need for, and develop as appropriate, more granular

standards or guidance for CCP resolution planning, resolution strategies and resolution tools,

including cross-border coordination and recognition of resolution actions, taking into account

the requirements in the Key Attributes of Effective Resolution Regimes and its FMI Annex; and

See CPMI-IOSCO, Recovery of financial market infrastructures, October 2014 (http://www.bis.org/cpmi/publ/d121.pdf

and http://www.iosco.org/library/pubdocs/pdf/IOSCOPD455.pdf.)

(iii) to assess the need for additional prefunded financial resources (including capital) and

liquidity arrangements in resolution and to develop a proposal, as needed.

In June 2015 ReSG completed a survey amongst its members

on CCP resolution regimes and

resolution planning. The survey relied as reference on the Key Attributes and its FMI Annex,

which sets out how the Key Attributes should be implemented in relation to resolution regimes

for systemically important FMIs. Overall, the survey results indicated that resolution

frameworks for CCPs are not well developed. Systematic cross-border resolution planning

processes are not yet in place for any of the largest CCPs although efforts are underway to

establish such processes. The majority of respondents noted that their jurisdictions intend to

develop or are still in the process of developing resolution regimes or policies for CCPs.

There was broad agreement amongst respondents on the need for further work on CCP

resolution and resolution planning, and for a structured process of implementation

monitoring.

To conduct this work, ReSG agreed to establish by end 2015 a working group (Cross-border

Crisis Management Group for FMIs, the fmiCBCM) to provide a forum for authorities to

exchange views, share experiences and discuss challenges and obstacles that arise in relation

to the orderly resolution of CCPs, and to carry out further resolution-related work under the

joint CCP workplan. More specifically, this group will monitor progress in: (i) the

development of resolution strategies and operational resolution plans for CCPs and of

institution-specific cross-border cooperation agreements (COAGs) or other appropriate

agreements that underpin cooperation, coordination and information sharing for purposes

related to resolution planning between members of CMGs or equivalent arrangements; and

(ii) the establishment and composition of CMGs (or equivalent arrangements) for CCPs,

including the determination of the CCPs that would require such arrangements given their

systemic importance in more than one jurisdiction. The group will also liaise with the joint ad

hoc study group on interdependencies (see section 5 below) on potential spill-overs related to

resolution actions and assess how resolution strategies can be developed to mitigate such

spill-overs. It will analyse how the resolution powers specified in the Key Attributes and its

FMI Annex would be exercised in practice in relation to a CCP, and identify obstacles, if any,

to the resolvability of CCPs arising from (i) legal structures; (ii) the arrangement of clearing

activities or other services; (iii) relationships and interdependencies between the CCP and

participants; (iv) links with other FMIs; (v) CCP rules including default management and

recovery procedures; and (vi) financial resources including liquidity arrangements.

As set out in the joint work plan, the group will also, cooperating closely with CPMI-IOSCO

and the ad hoc study group, assess the need for additional prefunded financial resources

(including capital) and liquidity arrangements for CCPs in resolution. By end 2016, the group

will report on the need for and, as appropriate, develop proposals for further guidance to

support CCP resolvability and resolution planning and to enhance prefunded financial

resources and liquidity arrangements for CCPs in resolution.

The following jurisdictions responded to the survey: Australia, Canada, China, European Commission, France, Germany,

Hong Kong, India, Italy, Japan, Mexico, The Netherlands, Russia, Singapore, South Africa, South Korea, Spain, Sweden,

Switzerland, Turkey, UK, and the US.

5. Analysis of interdependencies

A joint BCBS, CPMI, FSB and IOSCO study group was established in July 2015 to identify,

quantify and analyse interdependencies between CCPs and major clearing members and any

resulting systemic implications. The group will primarily focus on interdependencies that may

have implications for global financial stability. This does not necessarily mean that only

interdependencies between the largest CCPs and largest banks are all that is in scope, since it

is likely that smaller market participants or CCPs will have interdependencies with larger

banks or CCPs. However, the aim of the study group is not to comprehensively map all of the

central clearing interdependencies around the globe.

In the first instance, the study group will map key interconnections between CCPs (whether

clearing cash, derivatives, FX, repo, securities, etc.) and clearing members globally – in terms

of both memberships and multiple service provisions (such as reliance on particular banks for

lines of credit, etc.).

Interdependencies could include, for instance:

• financial obligations of clearing members, such as default fund contributions, initial

and variation margins, assessment rights, etc.

• financial interdependencies with other financial institutions, which can be clearing

members, stakeholders, such as investment counterparties, liquidity providers and

deposit banks; and

• operational interdependencies, such as links with investment counterparties,

custodians, settlement agents, etc.

Interdependencies to be explored include those that pose risks to CCPs and/or that pose risks

to participants or other stakeholders.

Once these key interconnections have been mapped, the potential for contagion effects within

this landscape will be explored. Contagion effects to be considered will include how any use

of default funds and recovery or resolution action taken with respect to one CCP might impact

banks and/or reverberate through to other CCPs. Similarly, the impact of the recovery or

resolution of a major bank participating in and/or providing services to multiple CCPs will

also be considered.

A final report will be prepared for publication by the end of 2016.

Annex A

Timeline for Implementing the CCP Workplan

Action

Expected Deliverable

Date

A. CCP Resilience

CPMI-IOSCO serve as the primary forum for this work

(i) Received survey responses on stress testing.

Jun 2015 (completed)

(ii) Sent surveys on margin practices, CCP loss absorption

capacity and liquidity, and the Cover 1/Cover 2 standard.

Jul 2015 (completed)

(iii) Receive responses to the surveys on margin practices, CCP

loss absorption capacity and liquidity, and the Cover 1/

Cover 2 standard.

Sep 2015

(iv) Discuss the need for, and develop as appropriate, more

granular standards or guidance for standards for stress

testing, margin practices, CCP loss absorption capacity and

liquidity, and the Cover 1/Cover 2 standard, as well as

comparable stress testing, including possible guidance and

standards taking into account the implementation of the

requirements in the PFMI.

Fall 2015 – Early 2016

(v) Publish report for public consultation on CCP resilience

and recovery issues (same as B (iii)).

Mid-2016

(vi) Publish report of the Level 3 assessment of CCP risk

management (same as B (iv)).

Mid-2016

B. CCP Recovery Planning

CPMI-IOSCO serve as the primary forum for this work

(i) Receive survey responses on existing CCP recovery

mechanisms, including loss allocation tools.

Sep 2015

(ii) Discuss the need for, and develop as appropriate, more

granular standards or guidance for CCP recovery planning,

taking into account the implementation of the requirements

in the PFMI and complementing CPMI-IOSCO guidance

on recovery.

Fall 2015 – Early 2016

(iii) Publish report for public consultation on CCP resilience

and recovery issues.

Mid-2016

(iv) Publish report of the Level 3 assessment of CCP risk

management.

Mid-2016

Action

Expected Deliverable

Date

C. CCP Resolvability

FSB ReSG serves as the primary forum for this work

(i) Conduct stock-take of existing CCP resolution regimes and

resolution planning arrangements.

Jun 2015 (completed)

(ii) Consider the need for, and develop as appropriate, more

granular standards or guidance for CCP resolution

planning, resolution strategies and resolution tools,

including cross-border coordination and recognition of

resolution actions, taking into account the requirements in

the FSB Key Attributes and complementing the FSB

guidance on FMI resolution.

End-2016

(iii) Assess the need for additional prefunded financial

resources (including capital) and liquidity arrangements in

resolution, and develop a proposal as needed.

End-2016

D. Analysis of interdependencies

Joint BCBS, CPMI, FSB and IOSCO study group

(i) Identify the information needed to better understand the

interconnections between CCPs and clearing members.

Dec 2015

(ii) Collect and analyse information.

H1 2016

(iii) Finalise and publish report.

Oct 2016