Template:M summ 2018 CSD 3(c)(iii): Difference between revisions

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The {{imcsd}} proposes three ways of solving this:
The {{imcsd}} proposes three ways of solving this:
*'''Distinct Margin Flow Approach''': you pay IM under the {{imcsd}} and pay the whole IA whack, separately, to the counterparty under the {{imcsdprov|Other CSA}}. Obviously enough, customers are not going to like this.
*'''[[Distinct Margin Flow (IM) Approach - IM CSD Provision|Distinct Margin Flow Approach]]''': you pay IM under the {{imcsd}} and pay the whole IA whack, separately, to the counterparty under the {{imcsdprov|Other CSA}}. Obviously enough, customers are not going to like this.
*'''Allocated Margin Flow Approach''': you pay the Reg IM portion of the IA under the {{imcsd}}, and pay any excess over that in the IA to the counterparty under the {{imcsdprov|Other CSA}}. To the JC’s way of thinking, this is the only one that makes any sense;
*'''[[Allocated Margin Flow (IM/IA) Approach - IM CSD Provision|Allocated Margin Flow Approach]]''': you pay the Reg IM portion of the IA under the {{imcsd}}, and pay any excess over that in the IA to the counterparty under the {{imcsdprov|Other CSA}}. To the JC’s way of thinking, this is the only one that makes any sense;
*'''Greater of Margin Flow Approach''': You pay the ''whole'' of the IA (or the IM, if it is greater) under the {{imcsd}} and ''nothing'' under the {{imcsdprov|Other CSA}}. We don’t think the broker will ever give up the right to reuse excess IA by steering that to a third party custodian, and nor, really should the client, since their implied financing rates will surely rise.
*'''[[Greater of Margin Flow (IM/IA) Approach - IM CSD Provision|Greater of Margin Flow Approach]]''': You pay the ''whole'' of the IA (or the IM, if it is greater) under the {{imcsd}} and ''nothing'' under the {{imcsdprov|Other CSA}}. We don’t think the broker will ever give up the right to reuse excess IA by steering that to a third party custodian, and nor, really should the client, since their implied financing rates will surely rise.
 
In a nutshell, we think that almost all punters will go for the [[Allocated Margin Flow (IM/IA) Approach - IM CSD Provision|Allocated Margin Flow]] approach: render unto CESR what is due to CESR;<ref>This was ALMOST an awesome pun. It doesn’t ''quite'' work, seeing as (a) the [[Committee of European Securities Regulators]] was formally disestablished in 2011 and replaced by [[ESMA]]; and (b) you render your Reg IM unto a custodian, not to ESMA (or CESR) anyway. But still, it was close enough to roll the dice on it anyway Hope you like it. {{hawf}}</ref> pay any excess over that to your counterparty.
 
It leaves one rather arid and academical dispute that one may quickly tire of having, as to whether the excess should be over one’s {{imcsdprov|Credit Support Amount (IM)}} — being the amount one is ''obliged'' to post to the {{imcsdprov|Custodian (IM)}} by way of [[regulatory margin]] or ones {{imcsdprov|Posted Credit Support Amount (IM)}} — being the amount one actually ''has'' posted to the {{imcsdprov|Custodian (IM)}} and we consider this further below.