August 2016
HKMA Responses to the Consultation on
Proposed Margin and Risk Mitigation Standards
for Non-Centrally Cleared OTC Derivatives
Contents
Introduction
After much anticipation, the Hong Kong Monetary Authority (the “HKMA”)
published on 22 August 2016 its response (the “HKMA Response”) to the
industry comments on its December 2015 consultation paper (the
“Consultation Paper”) on proposed margining and risk mitigation standards
1
for non-centrally cleared OTC derivatives . On the same day, the Australian
Prudential Regulation Authority (“APRA”) and the Monetary Authority of
Singapore (“MAS”) each made announcements to the market regarding their
proposed timelines for implementation of margin requirements for noncentrally cleared derivatives. All three Asian regulators have indicated that,
given the recently announced changes in the implementation schedules of
other major markets, they have decided to defer the implementation of margin
requirements in their respective jurisdiction beyond the 1 September 2016
deadline, without announcing a firm start date. . So while it is clear that the
Asian regulators had in view the delay in the European Union in arriving at
their decisions, it remains to be seen whether they will adopt an
implementation schedule for Asia which is aligned with that of the EU.
The HKMA has adopted a pragmatic approach in addressing the issues
raised by the industry on its proposals, and has clearly attempted to offer the
industry practical solutions to deal with some of the difficulties in
implementing margin requirements. This is very much to be welcomed by the
industry participants as they continue to prepare for the implementation of
global requirements.
The HKMA has asked for comments on the HKMA Response by 12
September 2016.
Introduction ....................... 1
Major changes and
refinements in the HKMA
Response .......................... 1
Detailed discussion on the
margin requirements ......... 2
In-scope entities................ 2
In-scope products ............. 4
Substituted compliance .... 5
Non-netting jurisdictions
and no-margin jurisdictions6
Margin standards: variation
margin ............................... 7
Margin standards: Initial
margin ............................... 7
Treatment of IM posted: ... 8
IM model approval ............ 8
Margin call and transfer
timing ................................ 8
Phasing-in schedule ......... 9
Risk Mitigation Standards
(RMS) ............................... 9
Conclusions .................... 11
Major changes and refinements in the HKMA Response
We set out in this Bulletin a detailed analysis of the Hong Kong margin
requirements. Before we do that in the next section, here are the most
significant changes from the HKMA proposals in the Consultation Paper:
1
See our client bulletin Hong Kong Proposes Margin and Risk Mitigation Standards for NonCentrally Cleared OTC Derivatives for our discussion on the Consultation Paper.
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
1
>
Cross border transactions – as proposed in the Consultation Paper, the
HKMA permits substituted compliance to be applied to cross-border
transactions where the HKMA has made a comparability determination
with respect to the overseas jurisdiction. To ensure that substituted
compliance will be available by the initial implementation date, the
HKMA is prepared to deem the WGMR jurisdictions (Australia, Canada,
the European Union, India, Japan, Republic of Korea, Mexico, Russia,
Singapore, Switzerland and the United States) as comparable from the
date such jurisdictions implement margin requirements until a full
assessment is completed by the HKMA. The complex concept of partial
compliance will be removed from the Hong Kong regime.
>
Non-netting and no-margin jurisdictions – margin requirements will not
apply to non-cleared OTC derivative transactions entered into with
counterparties in non-netting jurisdictions. Instead, authorized
institutions (“AIs”) are expected to monitor their exposure to these
counterparties through regulatory capital requirements, internal risk
limits and other appropriate risk mitigation techniques. AIs have to
identify the non-netting jurisdictions/counterparties on the basis of
independent legal advice and industry opinions may be relied on.
>
IM model approval – the HKMA has simplified the approval process for
the use of industry-wide standard IM models. AIs can notify the HKMA
of its intention to use industry-wide standard models and the HKMA no
longer requires individual approval applications to be made by AIs for
the use of such standard models.
Detailed discussion on the margin requirements
In-scope entities
Margin requirements will apply to both Hong Kong incorporated AIs
(irrespective of where the trades are booked) and overseas incorporated AIs
(with respect to trades booked in its Hong Kong branch only) when they enter
into in-scope non-centrally cleared OTC derivatives with a covered entity.
2
“Covered entities” are “financial counterparties” and “significant non-financial
3
4
counterparties” that are not excluded entities .
2
3
The following entities are “financial counterparties” as defined in the Consultation Paper:
(i)
AIs;
(ii)
Type 1, 2, 3, 4, 5, 6, 8, 9, 11 or 12 licensed corporations (“LCs”);
(iii)
Mandatory provident fund schemes;
(iv)
Occupational retirement schemes;
(v)
Insurers;
(vi)
Remittance agents and money changers;
(vii)
Money lenders;
(viii)
Entities carrying on business outside Hong Kong that would require licensing under
one of the above categories (i) to (vii) if it were carrying on business in Hong Kong;
(ix)
(True sale or synthetic) securitisation special purpose entities as defined in the
Banking (Capital rules);
(x)
Collective investment schemes; and
(xi)
Private equity funds.
“Significant non-financial counterparties” as defined in the Consultation Paper are entities
other than financial counterparties which have (either on an individual or a group basis) an
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
2
In the Consultation Paper, the HKMA was considering whether to narrow the
definition of “financial counterparties” by setting a threshold by reference to
the trade volume of such counterparty. This idea is now dropped and in the
HKMA Response, the HKMA has also said that no end-user exemption will be
extended under the Hong Kong margin regime for non-financial
counterparties and smaller financial institutions using derivatives for hedging
purposes. Non-financial counterparties can, however, avail themselves of the
HK$60 billion threshold which is used to identify whether a non-financial
counterparty is a “significant non-financial counterparty”; the quantum of such
threshold remains unchanged post-consultation.
In the HKMA Response, the HKMA proposes to exclude true sale
securitisation special purpose entities (“SPE”) from the definition of “financial
counterparty” provided that the SPE enters into the derivative transactions for
the sole purpose of hedging. Synthetic securitisation SPEs will, however, still
be “financial counterparties” for the purpose of the Hong Kong margin rules.
Other structured finance special purpose vehicles will be in-scope entities if
such an entity falls under the definition of a “significant non-financial
counterparty”.
Despite requests from the industry, collective investment schemes and
private equity funds remain in-scope. The industry also requested that
sovereign wealth funds be excluded from the definition of covered entities.
This has been rejected by the HKMA and sovereign wealth funds will be inscope unless they fall under any of the categories of excluded entities (e.g. a
public sector entity).
Counterparty identification: the HKMA has helpfully clarified that an AI can
rely in good faith on representations made by its counterparties as to its
status (including those made in industry-standard self-disclosure documents)
and the AI is not required to independently substantiate the information
provided by counterparties.
Intragroup exemption: The intragroup exemption has been clarified in the
HKMA Response and it is now clear that intragroup transactions between an
AI and an affiliate which is not supervised by the HKMA (e.g. a LC or an
insurer) will be able to benefit from the intragroup exemption. The AI and the
affiliate have to be accounted for on a full basis in the consolidated financial
statements of the holding company of the group of companies to which they
belong, and there has to be centrally managed risk control procedures and
internal risk management policies and procedures.
4
average aggregate notional amount of non-centrally cleared derivatives exceeding HK$ 60
billion. Whether an entity is a significant non-financial counterparty is determined for a one
year period from 1 September to 31 August of the following year by reference to the average
of the total gross notional amount of month-end positions of non-centrally cleared derivatives
for March, April and May preceding the 1 September starting date in a relevant year.
Excluded entities as proposed in the Consultation Paper are: sovereigns, central banks, public
sector entities, multilateral development banks and the Bank for International Settlements.
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
3
The HKMA has helpfully agreed to remove its proposed wide powers to bring
intragroup transactions within scope of the HKMA margin rules. Instead, the
HKMA can add additional criteria on when an intragroup transaction will/will
not qualify for the exemption if prudential concerns arise.
In-scope products
In the Consultation Paper, it was proposed that margin requirements be
applied to all OTC derivative products not cleared through a qualifying central
counterparty (“CCP”), with certain exemptions for (i) physically-settled FX
forwards and swaps (exempt from IM but not VM requirements), (ii) “FX
transactions” embedded in cross-currency swaps associated with the
exchange of principal (exempt from IM but not VM requirements), (iii)
indirectly cleared derivatives and (iv) repos and stock lending transactions.
In the HKMA Response, the HKMA has added FX security conversion
transactions to the list of exempted products – these are physically settled FX
forwards for the sale or purchase of a currency which are entered into for the
purpose of settling a sale or purchase of securities and are essentially treated
as spot contracts. A T+7 days cap on the settlement period is however
imposed.
The treatment on single stock equity options and index options will be aligned
with the proposed rules in the EU – a three-year phase-in period will be
provided for these products.
An area of uncertainty remains with swaps associated with structured finance
transactions, securitisations and covered bonds. The clarification from the
HKMA in the HKMA Response that securitisations and covered bonds fall
outside the definition of OTC derivative products (and hence does not require
margin) does not address the swaps entered into by securitisation vehicles or
covered bond issuers and cover pools. The exclusion of true sale
securitisation SPEs from the definition of “financial counterparties” (see our
discussion on “In-scope entities” above) is helpful and it is clear that hedging
swaps entered into by true sale securitisation SPEs are not subject to margin
requirements since the SPE is not a covered entity. Synthetic securitisation
SPEs fall under the definition of “financial counterparty”; covered bond
issuers or cover pools and other structured finance special purpose vehicles
may be covered entities if they fall under the definition of “significant nonfinancial counterparties”. When these vehicles enter into in-scope noncentrally cleared OTC derivatives as part of the transaction, Hong Kong
margin requirements may potentially apply if the vehicle is facing an AI (if
incorporated in Hong Kong, irrespective of where the trades are booked and if
incorporated overseas, if the trades booked in its Hong Kong branch).
Guaranteed transactions: The HKMA has agreed to take out the proposed
requirements for margin to be imposed on “guaranteed transactions” – i.e.,
non-centrally cleared OTC derivatives between two non-AI covered entities
with one of the counterparties benefiting from a guarantee from an AI.
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
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Substituted compliance
To avoid duplicative margin requirements in cross-border derivative
transactions, the HKMA proposed in the Consultation Paper a regime which
allows for “substituted compliance” and “partial compliance” where the HKMA
has issued a comparability determination in respect of the margin rules of the
overseas jurisdiction. Substituted compliance works by allowing an entity that
is otherwise subject to Hong Kong margin requirements to satisfy such
requirements by complying with equivalent standards in another jurisdiction.
Partial compliance was proposed as a limited form of substituted compliance
under which certain aspects of the margin requirements (in particular, with
respect to timing of exchange of margin, eligible assets and haircuts) are
carved out for substituted compliance purposes. The issue of comparability
determinations by the HKMA was envisaged to occur only if requested by an
AI or a foreign supervisory authority.
Partial compliance: In light of industry comments on the complexity of partial
compliance, the HKMA has agreed to remove such concept from the Hong
Kong margin regime. This is very much to be welcomed as no other major
jurisdiction has proposed such an approach to deal with cross-border
derivative transactions. Substituted compliance continues to be available in
the Hong Kong regime.
Substituted compliance: Substituted compliance is permitted to be applied to
cross-border transactions with (i) a deemed comparable jurisdiction until such
time as a comparability assessment has been completed for that jurisdiction
or (ii) a jurisdiction for which the HKMA has issued a comparability
determination. Note that if an overseas AI wishes to follow the margin
framework of its home jurisdiction (provided that it is deemed comparable), it
has to notify the HKMA by 31 December 2016. The HKMA also confirmed
that if, under the overseas requirements, a counterparty is exempt from the
margin requirements then no margin would need to be exchanged for
transactions with such a counterparty.
Comparability: In order to ensure that substituted compliance will be available
by the initial implementation date, the HKMA is prepared, as a transitional
arrangement, to deem the margin requirements of WGMR member
jurisdictions (Australia, Canada, the European Union, India, Japan, Republic
of Korean, Mexico, Russia, Singapore, Switzerland and the United States, the
“deemed comparable jurisdictions”) as comparable from the day such
jurisdictions implement margin requirements until a full assessment is
completed by the HKMA. The HKMA will also consider the comparability of
jurisdictions other than the deemed comparable jurisdictions following a
request by an AI; comparability determinations made by the HKMA will be
made public so the industry as a whole will be able to rely on them. In making
comparability determinations, the HKMA can impose additional conditions if it
considers that the regulatory framework of the overseas jurisdiction leads to
outcomes which are not comparable to the HKMA rules.
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
5
The deeming of WGMR jurisdictions by the HKMA as comparable for the
purpose of substituted compliance is a practical transitional arrangement and
will be welcomed by the industry as they prepare for implementation of the
margin requirements in various jurisdictions. As the first regulator to propose
such a deeming arrangement, the HKMA also demonstrates a pragmatic
approach for Hong Kong as an international finance centre host to a large
number of global financial institutions.
Non-netting jurisdictions and no-margin jurisdictions
In the Consultation Paper, it was proposed that when trading with a covered
entity which is located in a jurisdiction where netting is not legally enforceable
(“non-netting counterparties”), an AI should exchange (i.e. post and collect)
VM on a gross basis and collect IM on a gross basis. Where an AI trades with
a covered entity which is not subject to margin standards, it was proposed in
the Consultation Paper that the AI exchanges (i.e. post and collect) VM and
collects IM, the rationale being that the covered entity may not have
appropriate infrastructure to segregate IM properly. When an AI trades with a
locally incorporated covered entity (other than an AI), as the market is still
expecting draft rules from the other regulatory authorities, it was proposed
that the AI exchanges VM and collects IM. Posting of IM by the AI is only
needed as long as the AI is satisfied that the covered entity’s arrangements
sufficiently protect the posting AI in the event of the collecting party’s
insolvency.
Acknowledging the practical challenges with its proposals, the HKMA
concluded in the HKMA Response that margin is not required to be
exchanged when AIs trade with non-netting counterparties. Instead, AIs
should manage and monitor their exposure to these counterparties through
regulatory capital requirements, internal risk limits and other appropriate risk
mitigation techniques. To establish whether a counterparty is a non-netting
counterparty, AIs will have to obtain independent legal advice to the effect
that (A) netting is not likely to be effective under (i) the law of the jurisdiction
in which the counterparty is incorporated and, where a branch is involved, the
law of the jurisdiction in which the branch is located, (ii) the law which
governs the individual transactions and (iii) the law which governs the
agreement; and (B) arrangements for the protection of the posted collateral
are questionable or not legally enforceable upon default of the covered entity.
AIs are expected to identify the non-netting jurisdictions/counterparties on the
basis of this independent legal advice; industry legal opinions are permitted to
relied upon.
It is hoped that the HKMA will clarify the legal review requirements to assist
the industry in identifying these non-netting counterparties/jurisdictions. The
current requirements as set out in the HKMA Response seem to envisage
negative opinions to be obtained. Typical netting or enforceability opinions
obtained by firms (whether industry standard opinions or bespoke opinions)
will confirm that netting is effective or that the relevant agreement is
enforceable and will set out the reservations to the opinion, which are the
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
6
circumstances in which counsel cannot be certain that netting would be
effective. It is very difficult for counsel to issue negative opinions stating that
netting is not likely to be effective. The current legal review requirements also
appear to relate to two separate legal issues. Limb (A) above seeks to assess
whether
a
particular
counterparty/jurisdiction
is
a
non-netting
counterparty/jurisdictions, whereas Limb (B) above seeks to assess whether
the collateral protection (i.e. segregation) arrangements are enforceable upon
default of a counterparty. It is submitted that only Limb (A) is relevant for VM
purposes and both Limbs (A) and (B) are relevant for IM purposes.
The HKMA appears to have dropped its proposals with respect to no-margin
jurisdictions – a sensible approach which brings Hong Kong in line with the
other major jurisdictions.
Margin standards: variation margin
AIs are required to exchange VM with a covered entity on a net basis to
collateralise the mark-to-market exposure of the non-centrally cleared OTC
derivatives in a netting set. The HKMA has clarified that the obligation is to
exchange (i.e. post and collect) as opposed to just collect. To address the
issue with inconsistent scope of products across different jurisdictions, the
HKMA has clarified that an AI can agree with its counterparty to include
products in the netting set that are otherwise out of scope from the margin
standards to which either the AI or the counterparty is subject, as long as this
is done consistently and on an ongoing basis. Netting will be permitted within
the broader product set. Legacy trades may also be included in the netting
set if it done on a continuous basis.
The HKMA has also helpfully clarified that there can be more than one Credit
Support Annexes (for example, one governing legacy trades entered into
before the relevant implementation date and one governing new trades which
are subject to regulatory margin requirements) under an ISDA Master
Agreement.
Margin standards: Initial margin
Subject to the crossing of the relevant thresholds by both counterparties, AIs
are required to exchange (i.e. post and collect) IM with a covered entity on a
two-way gross basis to collateralise the potential future exposure that could
arise from future changes in the mark-to-market value of the derivatives
during the time it takes to close out and replace the position in the event of a
counterparty default. The amount of IM to be posted and collected may be
determined by a standardised margin schedule or a quantitative margin
model.
The position on IM thresholds (HK$375 million to be internally allocated to all
group entities) and minimum transfer amounts (no greater than HK$3.75
million to be shared between IM and VM) remains unchanged.
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
7
Treatment of IM posted:
Rehypothecation: The HKMA has affirmed its position on rehypothecation of
posted IM (i.e. that rehypothecation is prohibited), although it may review its
policy at a later stage.
IM segregation: IM collected has to be held pursuant to legally enforceable
collateral arrangements in such a way that: (i) it is available to the collecting
party in a timely manner in the event of the posting party’s insolvency and (ii)
the posting party is protected in the event of the collecting party’s insolvency.
With respect to cash IM, the HKMA clarified that cash IM should be deposited
with a third party custodian or with a central bank and held in a separate
account in the name of the posting party. The cash account is then secured to
the collecting party. Cash IM may be reinvested by the custodian in eligible
securities although this is not a regulatory obligation under the Hong Kong
margin rules.
Legal reviews for segregation arrangements: In the Consultation Paper, the
HKMA proposed to impose on AIs an obligation to perform independent legal
reviews to verify that the IM collected or posted can be promptly returned to
the surviving counterparty in the event of the insolvency of the AI or its
counterparty. Taking into account comments from the industry, the HKMA has
agreed to modify such requirement as an independent legal review to verify
that the segregation arrangements for IM meet the standards in the HKMA
margin rules. Such independent legal review may be an industry legal opinion
obtained on an industry-wide basis.
IM model approval
The HKMA has again adopted a pragmatic approach for the use of IM models
by simplifying the model approval process for industry-wide standard models.
Instead of having to submit individual applications for approval to the HKMA,
AIs can use an industry-wide standard model (such the SIMM developed by
ISDA) after it has notified the HKMA. Formal approval application from the
HKMA is still required for internally developed IM models (including third-party
models other than industry-wide standard models).
Margin call and transfer timing
VM has to be calculated at least on a daily basis. IM has to be re-calculated
when the relevant netting set changes, when the IM model has been
recalibrated and at least every 10 Hong Kong business days.
The HKMA has affirmed and clarified the proposed timing for margin calls and
margin transfers: VM and IM should be called by the end of the business day
following (in the case of VM) the trade date and (in the case of IM) the date
the event warranting a IM recalculation occurred (T+1), and collected within
two business days after the call date. Counterparties can agree on their own
definition of business days. For cross-border transactions, the trade date (T)
will refer to the calendar day of the time zone that is closer to the western
side of the International Date Line and which is a business day for both
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
8
counterparties. Market participants will welcome the proposals on timing for
margin calls and transfers, which is more generous than that in other
jurisdictions.
Phasing-in schedule
The HKMA indicated that it will issue the final rules (and a revised phase-in
schedule) on margin requirements for non-centrally cleared OTC derivatives
in the coming months and expects financial institutions to continue their
preparation for the implementation.
Risk Mitigation Standards (RMS)
In the Consultation Paper, the HKMA proposed the following risk mitigation
standards for non-centrally cleared OTC derivatives to be implemented with
same timeline as the introduction of VM requirements:
>
Execution of written trading relationship documentation;
>
Confirmation of the material terms of the non-centrally cleared OTC
derivative after the transactions are executed;
>
Valuation of non-centrally cleared derivatives in an objective manner;
>
Regular reconciliation of the material terms and valuations of all
transactions in a non-centrally cleared derivatives portfolio; and
>
Resolution of disputes in a timely manner.
Implementation timeline: Despite request from the industry to decouple from
the implementation of the margin requirements and to postpone the
implementation of the RMS, the HKMA confirmed that the implementation of
the RMS will follow the same implementation schedule as margin
requirements.
Substituted compliance: The HKMA has helpfully clarified that the crossborder framework for RMS will be kept in line with that for margin. When local
AIs enter into non-centrally cleared OTC derivatives with foreign
counterparties, the AI will be able to fulfil its RMS obligations by complying
with the requirements under the foreign rules if the HKMA has made a
comparability determination in respect of the foreign jurisdiction. Overseas
AIs can follow the RMS of its home or its counterparty’s jurisdiction in lieu of
the Hong Kong rules if the HKMA has issued a comparability determination in
respect of that home or counterparty’s jurisdiction.
The HKMA is also prepared to deem the RMS of WGMR jurisdictions (i.e.
same list as that for margin: Australia, Canada, the European Union, India,
Japan, Republic of Korean, Mexico, Russia, Singapore, Switzerland and the
United States) as comparable from the day they implement the RMS until a
full assessment is completed.
Scope of RMS: In the Consultation Paper, the RMS was said to be primarily
applicable to AIs when they trade with a covered entity, but AIs are
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
9
encouraged to adopt the RMS in relation to derivatives counterparties to the
extent practicable. The HKMA has clarified that the adoption of RMS with
counterparties that are not covered entities is a regulatory recommendation
only.
The HKMA has also clarified that RMS apply also to intragroup transactions.
HKMA Responses to the Consultation on Proposed Margin and Risk Mitigation Standards for
Non-Centrally Cleared OTC Derivatives
10
Conclusions
Contacts
With the implementation of the EU margin rules being delayed, the pragmatic
approach adopted by the HKMA in deferring the Hong Kong margin
requirements is very much to be welcomed. The practical solutions offered by
the HKMA in dealing with non-netting jurisdictions, approval of industry
standard IM models and the transitional arrangement of deeming WGMR
jurisdictions as comparable for substituted compliance purposes demonstrate
the HKMA’s willingness to listen to the industry’s concerns in its
implementation of margin requirements.
For further information
please contact:
Andrew Malcolm
Partner
(+852) 2842 4803
[email protected]
Chin-Chong Liew
Partner
(+852) 2842 4857
[email protected]
Victor Wan
Partner
(+852) 2901 5338
[email protected]
I-Ping Soong
Counsel
(+852) 2901 5181
[email protected]
Karen Lam
Counsel
Author: Jenny Wong
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