Template:Csa Eligible Collateral summ: Difference between revisions

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[[Eligible Collateral (VM) - NY VM CSA Provision|The]] kinds of collateral that you may exchange under a {{nyvmcsa}}. It looks like you can choose what you like, right, but CFTC rules in practice restrict it to cash in certain currencies. This is broadly analogous to what happens in Europe under [[EMIR]] and the other major regulatory regimes imposing margin requirements. You may wonder why regulatory VM is cash and regulatory IM is not, and premium subscribers can find out.
{{{{{1}}}|Eligible Collateral}} — with or without the (VM) suffix, and finding it tremendously irritating as he does, JC will largely go without — describes the kinds of collateral that you may deliver under your CSA and expect to be recognised for it.
In the [[ancient CSA]]s this is all very contractual and cash and a variety of types of corporate and government bonds might be acceptable; in the [[modern CSA]]s even though it looks like you can choose what you like, right, regulators’ rules, market conventions mean in practice variation margin is limited to cash in certain currencies. This makes a lot of the erstwhile complication and ''[[Ballschmerzen]]'' of CSA operations goes away.
 
{| class="wikitable" style="font-family: Helvetica; font-size: 80%; vertical-align: top; text-align: left;"
|+ Comparison of Eligible Collateral Types Across CSAs
! CSA Year !! Margin !! Gov. Law !! Holder !! Eligible Collateral
{{aligntop}}
| 1994 || IM and VM || NY || Other party || Cash, Government Securities, Investment Grade Corporate Debt
{{aligntop}}
| 1995 || IM and VM || English || Other party || Cash, Government Securities, Investment Grade Corporate Debt, Equities
{{aligntop}}
| 2016 || Reg VM and optional IM || NY || Other party || Cash only (in practice)
{{aligntop}}
| 2016 || Reg VM and optional IM || English || Other party || Cash only (in practice)
{{aligntop}}
| 2018 || Reg IM only || NY || Custodian || Cash, government bonds, corporate bonds
{{aligntop}}
| 2018 || Reg IM only || English || Custodian || Cash, government bonds, corporate bonds
|}
 
 
You may wonder why regulatory VM is cash and regulatory IM is not, and premium subscribers can find out.
====Initial  margin====
====Initial  margin====
For reasons best known to themselves there are curious rules in the US relating to initial margin which lead counterparties to use different ISDA CSA forms on different occasions. The details and variegation at play here — are you an SBSD counterparty? Are you subject to EMIR too? Is the AANA threshold met? — are all too ghastly for the JC to presently get into, other than to say the tiny peripheral benefits you get from gaming the fractal edges of the system of rules are most likely not worth it and it is probably better to have a single, maximally conservative, theory of the game: all that being well and good, of course, if your counterparties have a different view of the world, or a different idea what is the maximally conservative theory of the game.
For reasons best known to themselves there are curious rules in the US relating to initial margin which lead counterparties to use different ISDA CSA forms on different occasions. The details and variegation at play here — are you an SBSD counterparty? Are you subject to EMIR too? Is the AANA threshold met? — are all too ghastly for the JC to presently get into, other than to say the tiny peripheral benefits you get from gaming the fractal edges of the system of rules are most likely not worth it and it is probably better to have a single, maximally conservative, theory of the game: all that being well and good, of course, if your counterparties have a different view of the world, or a different idea what is the maximally conservative theory of the game.

Revision as of 12:26, 3 May 2024

{{{{{1}}}|Eligible Collateral}} — with or without the (VM) suffix, and finding it tremendously irritating as he does, JC will largely go without — describes the kinds of collateral that you may deliver under your CSA and expect to be recognised for it. In the ancient CSAs this is all very contractual and cash and a variety of types of corporate and government bonds might be acceptable; in the modern CSAs even though it looks like you can choose what you like, right, regulators’ rules, market conventions mean in practice variation margin is limited to cash in certain currencies. This makes a lot of the erstwhile complication and Ballschmerzen of CSA operations goes away.

Comparison of Eligible Collateral Types Across CSAs
CSA Year Margin Gov. Law Holder Eligible Collateral
1994 IM and VM NY Other party Cash, Government Securities, Investment Grade Corporate Debt
1995 IM and VM English Other party Cash, Government Securities, Investment Grade Corporate Debt, Equities
2016 Reg VM and optional IM NY Other party Cash only (in practice)
2016 Reg VM and optional IM English Other party Cash only (in practice)
2018 Reg IM only NY Custodian Cash, government bonds, corporate bonds
2018 Reg IM only English Custodian Cash, government bonds, corporate bonds


You may wonder why regulatory VM is cash and regulatory IM is not, and premium subscribers can find out.

Initial margin

For reasons best known to themselves there are curious rules in the US relating to initial margin which lead counterparties to use different ISDA CSA forms on different occasions. The details and variegation at play here — are you an SBSD counterparty? Are you subject to EMIR too? Is the AANA threshold met? — are all too ghastly for the JC to presently get into, other than to say the tiny peripheral benefits you get from gaming the fractal edges of the system of rules are most likely not worth it and it is probably better to have a single, maximally conservative, theory of the game: all that being well and good, of course, if your counterparties have a different view of the world, or a different idea what is the maximally conservative theory of the game.

This is what happens if you try to standardise and centralise a market that was designed to be unstandardised and decentralised, but still.

The dark side of margin

On the subject of pained exegeses which no-one will heed, the JC also has an impassioned essay about why bilateral variation margin may have a destabilising effect on the broader financial system, potentially weakening swap dealers’ liquidity and risk positions — a risk which was admirably demonstrated during the Archegos fiasco.

But no-one listens to the JC, so you should treat this as extended universe fan fiction only.