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This was quite the disaster in the service of trying to please some imaginary people.
This was quite the disaster in the service of trying to please some imaginary people.


This “ecocide” theory, popularised by Jared Diamond a generation ago, is out of favour with hand-wringing [[snowflake]]y academic types nowadays. ISDA’s council of elders may feel the same way about the JC’s corresponding “swapicide” theory.<ref>Sunk without trace: [[2011 ISDA Equity Derivatives Definitions]], [[2022 ISDA Securities Financing Transactions Definitions]], [[2023 ISDA Digital Asset Transactions Definitions]]. Those that did bear fruit were no great scream of exhilarating clarity: the [[2014 ISDA Credit Derivatives Definitions]], [[2016 Credit Support Annex for Variation Margin (VM)|2016 ISDA Regulatory VM CSAs]] and [[2018 ISDA Credit Support Deed for Initial Margin|2018 ISDA Regulatory IM CSA]] being cases in point.</ref>  
This “ecocide” theory, popularised by Jared Diamond a generation ago, is out of favour with hand-wringing [[snowflake]]y academic types nowadays. ISDA’s council of elders may feel the same way about the JC’s corresponding “swapicide” theory<ref>Sunk without trace: [[2011 ISDA Equity Derivatives Definitions]], [[2022 ISDA Securities Financing Transactions Definitions]], [[2023 ISDA Digital Asset Transactions Definitions]]. Those that did bear fruit were no great scream of exhilarating clarity: the [[2014 ISDA Credit Derivatives Definitions]], [[2016 Credit Support Annex for Variation Margin (VM)|2016 ISDA Regulatory VM CSAs]] and [[2018 ISDA Credit Support Deed for Initial Margin|2018 ISDA Regulatory IM CSA]] being cases in point.</ref> in which a community of earnest toilers, meaning to vouchsafe everyone’s onward prosperity, but in the throes of a voguish collective delusion about what is required sets about wasting every tree in sight pursuing mad, hypercomplicated and illogical schemes for imaginary investors who no-one has seen, let alone heard expressing such an interest.


Is ISDA desperately trying to stay ''relevant''? Recent clumsy land-grabs of [[ICMA]]/[[ISLA]] territory and forays into [[2023 ISDA Digital Asset Transactions Definitions|crypto]] give that impression. In any case, the irony that ISDA’s latest foray into the new normal — “sustainability-linked derivatives” — should so resemble a notorious example of environmental disaster is rich:
What is ISDA up to? Is It trying to stay ''relevant''? Clumsy land-grabs of [[ICMA]]/[[ISLA]] territory and forays into [[2023 ISDA Digital Asset Transactions Definitions|crypto]] give that impression. In any case, the irony that ISDA’s latest foray into the new normal — “sustainability-linked derivatives” — should so resemble a notorious example of environmental disaster is rich.


A community of earnest toilers, supposedly there to vouchsafe the community’s onward prosperity, falls into the throes of a voguish collective delusion and sets about a wastes every tree in sight pursuing mad, hypercomplicated and illogical schemes for imaginary investors who no-one has seen, let alone heard expressing demand for such an offering.
Even so, this feels like a step further through the looking glass, a tumble deeper down the rabbit hole. Previous follies at least tried to cater to existing markets and regulatory imperatives, however cack-handedly.  


ISDA’s recent missteps Even so this feels like a step further through the looking glass, deeper down the rabbit hole.  ISDA’s previous follies at least tried to cater to existing markets and regulatory imperatives, however cack-handedly. Sustainability derivatives are an attempt to create a new one out of — ~cough~ — hot air.
Sustainability-linked derivatives feel like an attempt to create a new market out of — ~cough~ — hot air.
===How they are meant to work===
===How they are meant to work===
If its discussion paper is anything to go by, not even ISDA has a clear idea what a sustainability-linked derivative would look like. Their best suggestion is that it would be some kind of plug-in to a normal swap — say an interest rate swap — containing a ratchet device to adjust the parties’ respectively spreads dependent on their compliance (or not) with certain pre-agreed  [[ESG]] [[key performance indicators]].  
If its discussion paper is anything to go by, not even ISDA has a clear idea what a sustainability-linked derivative would look like. The best guess is that it would be a sort of plug-in to a normal swap — say an IRS — containing a ratchet device to adjust the parties’ respective spreads dependent on their own compliance (or not) with certain pre-agreed  [[ESG]] [[key performance indicators]].  


Perhaps ISDA hasn’t followed the media coverage of greenwashing, but objectively measuring environmental impact is hard, and open to abuse.
Now objectively measuring environmental impact is hard, and open to abuse even when you aren’t talking your own book in the process. But greenwashing risk is the least of the problems here.  


Nor is this a ''[[derivative]]'' in the sense normally understood, but rather more a random [[penalty clause]]: a payment derived not from some observable third party indicator, but an internal metric entirely within the counterparty’s gift to game: I know what targets I can plausibly meet; my counterparty has no idea at all.  
Nor is this a ''[[derivative]]'' in the sense normally understood. It is more like a random [[penalty clause]]: a payment derived not from some observable third party indicator, but an internal metric entirely within the counterparty’s gift to game: it knows what targets it can and cannot plausibly meet; its counterparty has — short of due diligence no-one will be bothered to do (seeing as it will bugger up your marginal carbon footprint) —no idea at all.  


This becomes an open invitation to systematic insider dealing on ones own operations, especially since swaps are by their nature bilateral. What is to stop buisnesses [[Short sale|''shorting'']] their own sustainability credentials, and incentivise their own transition ''towards'' carbon and modern slavery?
So this becomes an open invitation to systematic insider dealing on ones own operations. And that is assuming a wily trader stays long only. But swaps are by their nature bilateral. What is to stop buisnesses [[Short sale|''shorting'']] their own sustainability credentials, incentivising their own transition ''towards'' carbon and modern slavery? Why should another swaps trader care?


And what has any of this to do with my counterparty? Why is paying, or not paying, cash away to a random stranger any kind of benefit to the environment? Why would a counterparty make itself hostage to my compliance effort? What incentive does it have to offer a discount just because I have cracked my own gender pay gap? Just by way of applause for its moral aspiration? That is not how commerce works. Besides, how is it supposed to ''hedge'' that?
Speaking of whom, what has any of this to do with one’s trading counterparties? What benefit accrues to the environment when one swaps desk does, or does not, pay, cash away to another? Why would someone else’s swaps desk make itself hostage to my compliance effort? Why should it suffer a discount — a penalty — just because I have cracked my gender pay gap? (Isn't there reward enough in just ''doing'' that?) Commerce does not work by offering emoluments to virtuous strangers. Swaps traders certainly don’t. Besides, how are you supposed to ''hedge'' that?


The sustainability a counterparty should really care about is that of its counterparties’ solvency. Good corporate governance — and sorry, millennials, the [[JC]] is with Milton Friedman on this: that means focus solely on shareholder return — is after all reflected in my [[credit spread]]s: how likely does the market regard my bankruptcy. This is coded into my spreads when I trade swaps. But once traded, these are not then adjusted during the life of the trade — hence a rich lifetime of employment for [[credit value adjustment]] traders. But in any case, my incentive is to manage my business as best I can so that ''when I trade I achieve the tightest spreads''.  That is all the incentive the market has needed, until now, to promote sustainability. Hardcore [[Libtard]]s may differ — we are all libtards now — but nothing has changed.
The sustainability a counterparty should really care about is that of its counterparties’ ''solvency''. Good corporate governance — and sorry, millennials, the [[JC]] is with Milton Friedman on this: that means focus solely on [[shareholder capitalism|shareholder return]] — is after all reflected in my [[credit spread]]s: how likely does the market regard my bankruptcy. This is coded into my spreads when I trade swaps. But once traded, these are not then adjusted during the life of the trade — hence a rich lifetime of employment for [[credit value adjustment]] traders. But in any case, my incentive is to manage my business as best I can so that ''when I trade I achieve the tightest spreads''.  That is all the incentive the market has needed, until now, to promote sustainability. Hardcore [[Libtard]]s may differ — we are all libtards now — but nothing has changed.


There is force in the idea that carbon credits are derivatives not so much of environmental damage as much as of regulatory fashion.  SLDs aren’t event that. These aren’t even derivative at all. They penalise, and reward, innocent parties.
There is force in the idea that carbon credits are derivatives not so much of environmental damage as much as of regulatory fashion.  SLDs aren’t event that. These aren’t even derivative at all. They penalise, and reward, innocent parties.

Revision as of 18:18, 19 May 2023

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Sustainability-linked derivatives
/səsˌteɪnəˈbɪlɪti lɪŋkt dɪˈrɪvətɪvz/ (n.)

It is said that the ancient people of Easter Island felled every tree on the island while erecting statues to their Gods and ancestors. The decaying root systems compromised the soil, which accelerated erosion, in which nutrients were washed away, plants could not regrow and eventually the whole ecosystem was wrecked. The island became all but uninhabitable.

This was quite the disaster in the service of trying to please some imaginary people.

This “ecocide” theory, popularised by Jared Diamond a generation ago, is out of favour with hand-wringing snowflakey academic types nowadays. ISDA’s council of elders may feel the same way about the JC’s corresponding “swapicide” theory[1] in which a community of earnest toilers, meaning to vouchsafe everyone’s onward prosperity, but in the throes of a voguish collective delusion about what is required sets about wasting every tree in sight pursuing mad, hypercomplicated and illogical schemes for imaginary investors who no-one has seen, let alone heard expressing such an interest.

What is ISDA up to? Is It trying to stay relevant? Clumsy land-grabs of ICMA/ISLA territory and forays into crypto give that impression. In any case, the irony that ISDA’s latest foray into the new normal — “sustainability-linked derivatives” — should so resemble a notorious example of environmental disaster is rich.

Even so, this feels like a step further through the looking glass, a tumble deeper down the rabbit hole. Previous follies at least tried to cater to existing markets and regulatory imperatives, however cack-handedly.

Sustainability-linked derivatives feel like an attempt to create a new market out of — ~cough~ — hot air.

How they are meant to work

If its discussion paper is anything to go by, not even ISDA has a clear idea what a sustainability-linked derivative would look like. The best guess is that it would be a sort of plug-in to a normal swap — say an IRS — containing a ratchet device to adjust the parties’ respective spreads dependent on their own compliance (or not) with certain pre-agreed ESG key performance indicators.

Now objectively measuring environmental impact is hard, and open to abuse even when you aren’t talking your own book in the process. But greenwashing risk is the least of the problems here.

Nor is this a derivative in the sense normally understood. It is more like a random penalty clause: a payment derived not from some observable third party indicator, but an internal metric entirely within the counterparty’s gift to game: it knows what targets it can and cannot plausibly meet; its counterparty has — short of due diligence no-one will be bothered to do (seeing as it will bugger up your marginal carbon footprint) —no idea at all.

So this becomes an open invitation to systematic insider dealing on ones own operations. And that is assuming a wily trader stays long only. But swaps are by their nature bilateral. What is to stop buisnesses shorting their own sustainability credentials, incentivising their own transition towards carbon and modern slavery? Why should another swaps trader care?

Speaking of whom, what has any of this to do with one’s trading counterparties? What benefit accrues to the environment when one swaps desk does, or does not, pay, cash away to another? Why would someone else’s swaps desk make itself hostage to my compliance effort? Why should it suffer a discount — a penalty — just because I have cracked my gender pay gap? (Isn't there reward enough in just doing that?) Commerce does not work by offering emoluments to virtuous strangers. Swaps traders certainly don’t. Besides, how are you supposed to hedge that?

The sustainability a counterparty should really care about is that of its counterparties’ solvency. Good corporate governance — and sorry, millennials, the JC is with Milton Friedman on this: that means focus solely on shareholder return — is after all reflected in my credit spreads: how likely does the market regard my bankruptcy. This is coded into my spreads when I trade swaps. But once traded, these are not then adjusted during the life of the trade — hence a rich lifetime of employment for credit value adjustment traders. But in any case, my incentive is to manage my business as best I can so that when I trade I achieve the tightest spreads. That is all the incentive the market has needed, until now, to promote sustainability. Hardcore Libtards may differ — we are all libtards now — but nothing has changed.

There is force in the idea that carbon credits are derivatives not so much of environmental damage as much as of regulatory fashion. SLDs aren’t event that. These aren’t even derivative at all. They penalise, and reward, innocent parties.

See also

References