Template:M comp disc EUA Annex Close-out Cost of Carry Rate

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The comparison between the drafting for Close-out Cost of Carry Rate and ordinary Cost of Carry Rate illustrates the extent to which standards slipped for this project:

It is here: comparison.

simplifying them down to idiomatic and consistent English, the differences appear to be as follows:

Cost of Carry Rate Close-out Cost of Carry Rate
The Floating Rate between the scheduled Payment Date and the Delayed Payment Date if the Reset Date were the Delayed Payment Date and the Floating Rate Option were “EUR-EONIA-OIS-COMPOUND” The Floating Rate between the scheduled Payment Date and the Early Termination Date if the Reset Date were the Final Delivery Date and the Floating Rate Option were “EUR-EONIA-OIS-COMPOUND”

So the differences are only the length of the period (and this is really a mutatis mutandis sort of thing: For a Suspension Event, the delay comes, Q.E.D., to an end earlier than for a Failure to Deliver); and the Reset Date (i.e., the date you determine the Floating Rate), and that also is a mutatis mutandis thing, seeing as the rate is determined not at the beginning of the period but its end, and you don’t know how long the period will be.

In any case: there is no kind of penalty rate or anything like that. It is just that the levers you need to calculate the cost of carry for a failure to pay — where there are intervening Reconciliation Deadlines and so on — are subtly different. Different enough to justify all this verbiage? You decide.