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But there is a better objection: for all our automatic protestations to the contrary, the ISDA is not ''really'' a bilateral contract, and it ''is'' often financing contract, in economic effect even if not in formal structure. Where there is a customer gaining exposure to a risk and a dealer providing delta-hedged exposure to that risk, a swap is a sort of “synthetic loan”. | But there is a better objection: for all our automatic protestations to the contrary, the ISDA is not ''really'' a bilateral contract, and it ''is'' often financing contract, in economic effect even if not in formal structure. Where there is a customer gaining exposure to a risk and a dealer providing delta-hedged exposure to that risk, a swap is a sort of “synthetic loan”. | ||
We should not let ourselves forget: beyond the cramped star system of inter-dealer relationships, there is a boundless universe where one party is a “dealer” and the other a “customer”. This is the great preponderance of all ISDA arrangements. The ''customer'' and a ''dealer'' roles are different. | We should not let ourselves forget: beyond the cramped star system of inter-dealer relationships, there is a boundless universe where one party is a “dealer” and the other a “customer”. This is the great preponderance of all ISDA arrangements. The ''customer'' and a ''dealer'' roles are different. The difference does not depend on who is “long” and who “short”, or who is the fixed rate payer and who is the floating rate payer. Hence the expressions “[[sell side|sell-side]]” — the dealers, who sell exposure — and “[[buy side|buy-side]]” — their customers, who buy it. | ||
For | For the buy-side, the object of trading a swap, or making any investment, is to ''change'' its market exposure: to get into a positions it did not have before. This sounds obvious. But, being a bilateral contract, its corollary ought to be that the sell side ought to be changing its position, too. But it is not. A dealer “sells” a swap to earn a commission ''without'' changing its market exposure. | ||
Now, a swap is a principal obligation, so being a party to one necessarily changes the dealer’s market exposure, so the dealer must then “[[Delta-hedging|delta hedge]]” that position away, by taking on an equal and offsetting position in the same asset somewhere else: by buying the underlying asset, or matching off its exposure under “long” position against another exposure under a “short” position in the same underlier. | |||
There are plenty of ways to delta hedge, but the basic economic principle is this: on the asset side of the swap the equity leg) the dealer has not changed its market position. It has not, over all, made an investment. It has not borrowed anything. | |||
Provided the dealer knows what it is about, its main risk in running a swap portfolio not market risk — there should not be any — but ''counterparty'' risk. Should a counterparty fail, suddenly the dealer might have a lot of market risk. Hence, having adequate collateral from its customers, to cover the eventuality that they should fail, is very important. | |||
But how does this | ==== Swaps are usually synthetic loans ==== | ||
But how does this make a swap into a synthetic loan? It is best illustrated by comparing a swap with an actual loan. Take this scenario: | |||
{{Quote|{{divhelvetica| | {{Quote|{{divhelvetica| | ||
[[Hackthorn Capital Partners]] owns USD10m of | [[Hackthorn Capital Partners]] owns USD10m of AUM. It wishes to buy USD10m of [[Cryptöagle]]. It can either: ''sell'' its existing AUM and use the proceeds to buy Cryptöagle, or ''keep'' its existing portfolio and borrow USD10m. | ||
'''Sale'''<br> | '''Sale'''<br> | ||
If it sells | If it sells its existing portfolio outright, the position is as follows: | ||
:Sold: | :Sold: USD10m. | ||
:Borrowed: | :Borrowed: Zero. | ||
:Amount owed: | :Amount owed: Zero. | ||
:Bought: 10m | :Bought: 10m Cryptöagle @ USD1 per share. | ||
:Amount due: [[total return swap|total return]] on 10m Cryptöagle | :Amount due: [[total return swap|total return]] on 10m Cryptöagle. | ||
'''Loan'''<br> | '''Loan'''<br> | ||
If it keeps | If it keeps its existing portfolio and borrows, the position is as follows: | ||
:Sold: | :Sold: Zero. | ||
:Borrowed: USD10m | :Borrowed: USD10m. | ||
:Amount owed: | :Amount owed: floating rate on USD10m. | ||
:Bought 10m of Cryptöagle | :Bought 10m of Cryptöagle @ USD1 per share. | ||
:Amount due: [[total return swap|total return]] on 10m | :Amount due: [[total return swap|total return]] on 10m existing portfolio and 10m Cryptöagle.}}}} | ||
Note the cashflows in the loan scenario: | Note the cashflows in the loan scenario: | ||
{{Quote|{{divhelvetica| | {{Quote|{{divhelvetica|During loan, Hackthorn pays floating rate on USD10m and is exposed to the market price of Cryptöagle. <br> | ||
On termination of the loan Hackthorn sells Cryptöagle. If sale proceeds exceed loan repayment, Hackthorn repays the loan and keeps the difference. If sale proceeds are less than loan repayment, Hackthorn must finance the shortfall from its existing portfolio, thereby booking a loss.<br> | |||
Therefore, Hackthorn’s net exposure is ''USD10m - Cryptöagle spot price''. | |||
}}}} | }}}} | ||
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{{Quote|{{divhelvetica| | {{Quote|{{divhelvetica| | ||
During swap, Hackthorn pays floating rate on USD10m and dealer pays total return on Cryptöagle. On termination, if the swap termination amount is negative, Hackthorn pays it to dealer. If it is positive, dealer pays Hackthorn. <br> | |||
The swap termination payment is ''USD10m - Cryptöagle spot price''. | |||
}}}} | }}}} | ||
Like a loan, the equity swap gives | Like a loan, the equity swap gives Hackthorn exposure to [[Cryptöagle]] whilst keeping its existing portfolio, which Hackthorn uses to fund cashflows on its new capital asset. This is a form of ''[[leverage]]''. The floating rate Hackthorn pays is ''implied funding''. The dealer will only accept this if it is satisfied Hackthorn has enough capital to finance its swap payments and settle any differences at termination. This is the same risk calculation a bank lender would make.<ref>To keep it simple, I have ignored the scope for synthetic margin loan and rehypothecation.</ref> | ||
But | But, hang on: this is a bilateral swap arrangement, so isn’t the same also true of the dealer? Isn’t the dealer paying a rate to get exposure to the synthetic cashflow of an asset — the floating rate — in the same way, so is, in a sense “borrowing” by paying its total return? Is not a “short” equity derivative, for a dealer, exactly the same as a “long” equity derivative for a customer? | ||
Generally not, because the dealer | Generally not, because in providing these swap exposures to its customers, the dealer is not changing its own market position. It delta-hedges. At the same moment it puts on a swap, it executes an offsetting hedge. The dealer’s net position on its derivative book will generally be flat. You don’t need to borrow money to take no position.<ref>The dealer may need to borrow money to fund its hedge, but this is exactly what the customer’s floating rate pays for. This is “borrowing on the customer’s behalf”.</ref> | ||
==== On the case for one-way margin ==== | |||
In recent years — ironically, just as the “dealer” vs “customer” dynamic has become more pronounced<ref>After the [[GFC]], bank proprietary trading fell away to almost nothing.</ref> — the global regulatory-industrial complex,<ref>This label is not just sardonic: there really is a cottage industry of of “regulatory change management professionals” who owe their last decade’s livelihood to ''accommodating'' quixotic regulatory initiatives like this. They are a powerful lobby with a direct interest in maintaining the rate of regulatory churn.</ref> still fighting last decade’s war, has forged rules which overlook this. Notably, the coordinated worldwide approach to bilateral regulatory margin. As swap positions move in and out of the market, daily, the parties must post each other the cash value of the net market movements. This is a little like closing out your positions at the end of every day and settling up, with a key difference: you ''don’t'' close out your positions. You cash collateralise on the basis of open positions. | |||
This makes a lot of sense in one direction — customer to dealer — but none whatsoever in the other. Customers should absolutely cash settle the net losing value of their positions to their dealers (and more). Dealers absolutely should not post “losing values” on customer positions to their customers. For several reasons: | |||
Banks are capitalised and regulated for systemic risk | |||
Banks are not losing value on the customer positions: as per the above, they are delta-hedged. Banks have no market exposure unless their clients go bust. | |||
Banks generally go bust because their clients go bust. They don’t go bust by themselves—I know, I know, Silicon Valley Bank did, but it is an honourable exception that proves the rule. | |||
If we are worried about bank solvency, then forcing the bank to cash settle unrealised gains on derivatives portfolios is a bad idea. | |||
“settling to market” every day with an important distinction: you don0147 | |||
Banks are independently capital regulated for solvency. | Banks are independently capital regulated for solvency. | ||
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Daily mark to market moves are mainly noise. Yet this is what we collateralise. The signal emerges over a prolonged duration. Over the short run posted collateral can, as we know a system effect: if I double down on an illiquid position, it will tend to rise, and I will get more margin, and — this is the story of [[Archegos]]. | Daily mark to market moves are mainly noise. Yet this is what we collateralise. The signal emerges over a prolonged duration. Over the short run posted collateral can, as we know a system effect: if I double down on an illiquid position, it will tend to rise, and I will get more margin, and — this is the story of [[Archegos]]. | ||
The increased systemic exposure of banks failing — which is what the margin regs were designed to address — is not caused by the banks themselves, but by their client exposures. Client exposures in turn are a function of client failures, which are in turn a function of leverage | The increased systemic exposure of banks failing — which is what the margin regs were designed to address — is not caused by the banks themselves, but by their client exposures. Client exposures in turn are a function of client failures, which are in turn a function of leverage | ||
Their failure shouldn't, typically, be a systemic risk unless their unusually size, interconnectedness or unintended system effects ''make'' them systematically important, in which case they should be regulated if they are systemically important, and made to hold capital, and (b) they have the market position and bargaining power to negotiate margin terms. | Their failure shouldn't, typically, be a systemic risk unless their unusually size, interconnectedness or unintended system effects ''make'' them systematically important, in which case they should be regulated if they are systemically important, and made to hold capital, and (b) they have the market position and bargaining power to negotiate margin terms. |