|
|
The proposal would fundamentally change the landscape of collateral management. The EBF therefore welcomes the proposed quantitative impact study. Together with the impact of other regulatory reforms around the world, collateral would become scarcer and thus more expensive. Market participants will need time to make adjustments to existing collateral management systems and procedures or to implement new ones.
Any mandated bilateral exchange of Variation Margin by financial institutions in combination with capital requirements should be sufficient to satisfy the G20’s key objective of minimising credit risk and mitigating systemic spill-over risk. Mandating mandatory Initial Margin requirements would introduce liquidity risk and interfere with the normal course of credit underwriting, particularly for unsecured credit and credit collateralised by physical collateral.
The credit risk of prudentially regulated financial institutions can be managed in a variety of ways. Such institutions are already subject to comprehensive regulatory requirements and supervision. Accordingly, they should be permitted to individually negotiate the terms of margin, collateral, and price within this regulatory framework.
The FX markets should not be subject to punitive margin requirements that might interfere with a market that is already transparent, liquid, and has a well-functioning settlement process.