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05/03/2020
1
The countdown to the end of LIBORElizabeth Armitage, Goldman Sachs Nelly Terekhova, Legal and General Investment Management
Wednesday 11 March 2020
Wednesday 11 March 2020 2
Key date
1986How does it work?
What is LIBOR & why is it important?
What’s the problem with LIBOR?
So what is the solution?
05/03/2020
2
Wednesday 11 March 2020 3
What is LIBOR & why is it important?
1 Source: 2014 ISDA
0 20 40 60 80 100 120
US Dollar
Euro
British Pound
Japanese Yen
Swiss Franc
Tibor (Yen)
The Legacy of LIBOR (£tril)1
It's still used to benchmarkover $350 trillion financial
derivatives
Wednesday 11 March 2020 4
How does it work?
0.7000
0.70000.7200
0.7200
0.72500.7300
0.73000.7310
0.7600
0.76000.7750
0.7800
0.79000.8100
0.81000.8400
0.8625
0.9000
0.7000
0.70000.7200
0.7200
0.81000.8400
0.8625
0.9000
Rabobank
JPMorgan Chase
Societe Generale
Royal Bank of Canada
Citigroup
Bank of America
HSBC
UBS
Bank of Tokyo-Mitsubishi
Credit Suisse
Royal Bank of Scotland
Barclays
Sumitomo Mitsui Financial Group
Norinchukin
BNP Paribas
Lloyds
Credit Agricole
Deutsche Bank
For that day, LIBOR = 0.7591
05/03/2020
3
Wednesday 11 March 2020 5
What’s the problem with LIBOR?
Relevance Limitations in the relevance of LIBOR as a benchmark rate
Sustainability & Stability
Lack of active and liquid underlying market:• Banks reluctant to lend unsecured overnight• Element of bank credit risk/volatile
LIBOR Manipulation
• LIBOR manipulation in the 2008 financial crisis• 2012 LIBOR scandal
Wednesday 11 March 2020 6
So what is the solution?
0.0
0.2
0.4
0.6
0.8
1.0
1.2
1.4
1.6
1.8
2.0
%
3M £ LIBOR SONIA
1 Data from Bloomberg LLC
05/03/2020
4
Wednesday 11 March 2020 7
SONIA
0
1
2
3
4
5
6
7
%
3M SONIA 3M LIBOR BoE Base Rate
What is SONIA & reformed SONIA?
Why is it better than LIBOR?
How does it work & how is it measured?
1 Data from Bloomberg LLC
The countdown to the end of LIBOR
Wednesday 11 March 2020 8
Key events –A timeline of historic
events
How big is the problem? How are people transitioning?
Derivatives
Bonds
Loans
The rest of the world
XCCY
Past Present Future
Future timeline
What to watch out for?
05/03/2020
5
0
5
10
15
20
25
30
35
40
Jun 2016 Oct 2016 Jan 2017 May 2017 Sep 2017 Dec 2017 Apr 2018 Aug 2018 Dec 2018 Mar 2019 Jul 2019 Nov 2019 Feb 2020
SO
NIA
vs
3M L
IBO
R S
pre
ad,
Bp
s
Basis narrows as fallbacks calculated from a historical mean, on the event LIBOR is discontinued, implies a
tighter spread
Timeline: Historic events in the LIBOR transition
Wednesday 11 March 2020 9
Market flow drives the basis wider as LDIaccounts transition and hedge funds position
themselves for the transition
Sep 2018: FCA and
PRA issue “Dear CEO
Letter”
Jul 2014: FSB publishes “Reforming Major
Interest Rate Benchmarks” kickstarting creation of working groups to select
alternate risk-free rates (RFRs)
Apr 2017: Reformed SONIA
selected as preferred £ RFR
Jun 2018:First SONIA Floating
Rate Note (FRN) Issued & SONIA
futures begin trading
Nov 2019:Fallbacks announced into
final spread applied to RFRswhen LIBOR ceases to exist
Jul 2017: Andrew Bailey
announced banks will not be required to submit LIBOR after YE 2021
Past Present Future
1 Data from Bloomberg LLC
Feb 2020:The FCA sends “Dear CEO
letter” to asset managers in the UK + ISDA releases a
re-consultation on pre-cessation
Derivatives – How big is the problem?
Wednesday 11 March 2020 10
1 https://www.fsb.org/wp-content/uploads/r_140722b.pdf. Data from 20142 Source: PRA Returns 2015
LIBOR-Linked Derivatives Notional Summary (£bn)2
90.246.3
33.327.527.025.7
24.218.8
8.47.7
6.32.01.81.71.00.50.2
0 20 40 60 80 100
PACAvivaLGAS
Scottish WidowsPIC
PhoenixRLAM
RothesayStandard Life
Friends LifeScottish Equitable
Sun LifePartnership Life
JustLV
Canada LifeZurich
LIBOR-linked Derivatives
= £323bn
Past Present Future
New Hedging
• Bilateral vs Cleared
Backbooks
• Market participants -Legacy positions
• Transition strategies
Loans (1%)
ETD Derivatives
(10%)
OTC Derivatives
(85%)
Securitsation(2%)
Bonds (1%)
Total £26,145bn1
IR Swaps
IR Futures
IR Options
X-Cur. Swaps
IR Options
FRAs
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Derivatives - New Hedging The steady growth of cleared £ LIBOR swaps
Wednesday 11 March 2020 11
Source: https://www.bankofengland.co.uk/bank-overground/2019/how-prepared-are-markets-for-the-end-of-libor1 https://www.fca.org.uk/news/speeches/libor-preparing-end
August 2019
April 2018
Outstanding stock referencing LIBOR
The stock of contracts has increased
Commitment to maintain LIBOR ends
0
5
10
15
20
25
2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
£ T
rill
ion
s
Past Present Future
SONIA accounted for 45% of
notional swaps trading in GBP
in H1 20191
1y 2y 3y 4y 5y 6y 7y 8y 9y 10y 12y 15y 20y 25y 30y 40y 50y12
13
14
15
16
17
18
Ba
sis
cu
rve
-3
M L
IBO
R v
s S
ON
IA
Corporate Treasuries
Hedge Funds
Insurers
Pension Funds
Bank Treasuries
Yield
Tenor: 5y – 20y
Corporate TreasuriesHedge LIBOR / SONIA
risk arising from issuance, or outright
risk vs LIBOR
Hedge Funds Speculative &
structural positioning that benefit from
strong carry
Tenor: 1y – 5y
Bank TreasuriesMortgages,
Deposits, Liquidity buffer asset swaps,
Bond Issuance
Tenor: 20y+
Pension Funds Transact hedging
(ASW buying / Rec Fixed vs LIBOR) in
the 20y+ bucket
Insurers Dispose of assets gained from BPA
activities on ASW vs LIBOR, with profits
Derivatives - Legacy positions
Wednesday 11 March 2020 12
Past Present Future
Half way house
• Some backbook in SONIA• All new trades in SONIA• Good liquidity• Some hit at a future time
SONIA and
LIBOR
• LIBOR liabilities (regulatory)– Have to hold
some capital
Switch from LIBOR to SONIA Exposure
• No hit at a future time• Increasing liquidity
SONIA
• LIBOR liabilities (regulatory)– Have to hold extra
capital for basis risk
Do Nothing • Rely on fallbacks• Diminishing liquidity• No transaction costs
LIBOR• LIBOR liabilities (regulatory)
– No need for extra capital
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7
5
10
15
20
25
30
35
0y 5y 10y 15y 20y 25y 30y 35y 40y 45y 50y
6ML
IBO
R v
s S
ON
IA -
Bp
s
2016 2017 2018 Mar 2020
Derivatives - Fallback Analysis Fallback LIBOR = SONIA + spread
Consultation on the final parameters applicable to RFRs if derivative fallbacks are triggered
Wednesday 11 March 2020 13
Decision was announced 15th November 2019, ISDA expects to implement a historical median spread adjustment over a five-year lookback period
ISDA narrowed the final spread adjustment approach to: 5Y median vs 10Y trimmed mean
Past Present Future
1 Data from Bloomberg LLC
Spread adjustment will likely be the same across IBOR rates
- Minimize risks of distortion in cross-currency hedging
- Avoid creating unnecessary dislocations in the basis market
- Limit regulatory arbitrage across jurisdictions.
2021/2022 Implied Fallback: 17.7/17.8
Bonds – Floating Rate Note debt (FRN)
Wednesday 11 March 2020 14
1 https://www.fsb.org/wp-content/uploads/r_140722b.pdf. Data from 20142 Data from Bloomberg LLC
Past Present Future
Loans (1%)
ETD Derivatives
(10%)
OTC Derivatives
(85%)
Securitsation(2%)
Bonds (1%)
Total £26,145bn1
‘Lag’ mechanism - interest observation period lags the SONIA rate reference
period by 5 London banking days
FiveLondon banking
days
FiveLondon banking
days
Observation period for SONIA
Issue Date/ interest payment date
Interest period
Interest payment date/ maturity date
SONIA observation period vs. interest period
• Q1: SONIA-referencing FRN tranches surpassed LIBOR-referencing ones by volume
• New public issues of £ LIBOR FRNs maturing beyond the end of 2021 have all but ceased
• >£30bn of UK LIBOR FRN debt with maturities beyond 2021.
0255075
100
M J J A S O N D J F M A
2018 2019
%
SONIA LIBOR
FRN issuance 2018-20192
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8
Bonds – Key Events
Wednesday 11 March 2020 15
H2 2018-H1 2019£20.5bn of SONIA FRNs were issued in H1 2019,
compared with £6.9bn in H2 2018
H2 2018-H1 2019There were 35 new FRN transactions referencing
SONIA in H1, up from 12 in H2 of 2018
April 2019 Securitisation referencing SONIA
Nationwide Building Society issued the first distributed SONIA UK RMBS using SONIA-linked FRN conventions. It also converted its balance sheet to a SONIA-referencing
basis
June 2019Associated British Ports - ABP replaced LIBOR
with compounded SONIA + a fixed spread on £65m FRNs due in 2022.
A meeting of the noteholders on 11 June 2019 passed the extraordinary resolution
June 2018 EIB pioneered the move to SONIA-linked issuance
with a 5 yearFRN
Past Present Future
Loans – Key Events
16
Q3 TargetFCA want to see all new
lending in SONIA not LIBOR
2nd July 2019 NatWest delivers first bilateral SONIA
loan for its corporate customer, National Express Group PLC.
7th August 2019LMA published a guidance note on
credit spread adjustments when moving from LIBOR to SONIA
Past Present Future
Loans (1%)
ETD Derivatives
(10%)
OTC Derivatives
(85%)
Securitsation(2%)
Bonds (1%)
Total £26,145bn1
Wednesday 11 March 2020
1 https://www.fsb.org/wp-content/uploads/r_140722b.pdf. Data from 2014
Term Rates
• Weighted average midpoint of firm bid and offer quotes for listed SONIA products
Compounding
• Entirely in advance of the interest period
• In arrears i.e. 5 day lag mechanism
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9
What happens if LIBOR ceases to exist?
Wednesday 11 March 2020 17
Past Present Future
BondsDerivatives Loans
1. ICE Reduced Submissions Policy
– When 4 or fewer complete submissions, ICE re-publishes the previous day’s rate
2. Public statement that LIBOR will cease permanently or indefinitely by,
– The benchmark administrator (ICE)
– A public sector official with authority over the benchmark administrator or the central bank for the relevant currency
3. Statement by the FCA that LIBOR is no longer "representative”
Triggers
Existing Fallbacks
Proposed Fallbacks
Rate from previous period ~ FRN
= fixed rate note
“screen rate”
No fallback language contained in ISDA
documentation
Lender’s
cost of funds
Consent solicitation to amend terms
- Liability management exercises to buy back
bonds
New fallback language market participants can
sign up for via a protocol
LMA Replacement “screen rate” clause
What about the rest of the world? – USD
Wednesday 11 March 2020 18
Past Present Future
1 https://www.oliverwyman.com/content/dam/oliver-wyman/v2/publications/2019/jun/Time-To-Switch-Rates-LIBOR-Transition-FINAL.pdf2 Data from Bloomberg LLC
USD
• SOFR (Secured Overnight Financing Rate) - measure of the cost of borrowing cash overnight collateralized by US Treasury securities
• CME/LCH (clearing houses) started clearing SOFR swaps in 2018
• Trading in SOFR swaps and futures has increased but volumes are still very modest
• Issuance $265bn SOFR vs $811bn LIBOR in 2019.
Asset Estimate of Liquidity1
SOFR SONIA
Swaps
Futures & Forwards
Bonds
Loans
Sufficient liquidity for all activity to take place in RFR market
No liquidity in RFR markets
0
1
2
3
4
5
6
Jul-2018 Jan-2019 Jul-2019 Jan-2020
%
SOFR²
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10
What about the rest of the world? – EUR
Wednesday 11 March 2020 19
Past Present Future
Source: https://www.clarusft.com/ester-what-you-need-to-know/
EUR
• €STR (Euro Short-Term Rate) published for the first time on 2 Oct 2019
• EIB also printed the market’s first €STR bond
• Reflects wholesale € unsecured overnight borrowing costs of € area banks, based entirely on actual individual transactions.
0
10
20
30
40
50
60
70
80
90
EUR USD GBP
Mil
lio
ns
≤ 2 years 2-5 years 5+ years
Bond Issuance vs OIS – SONIA, EONIA (EUR), SOFR/FF
EUR markets are the only OIS market that see substantial activity longer than 2 years
XCCY – What are the options?
GBP
LIBOR• Current standard for XCCY
swaps• Decommissioned after 2021
SONIA• Reference Benchmark• New standard for GBP swaps• Hasn’t taken off for XCCY
swaps yet due to lack of liquidity in non-LIBOR rates in other currencies
EUR
EURIBOR• Current standard for XCCY
swaps• Will be reformed to become
benchmark-compliant by end 2021
• Transaction volumes have fallen dramatically
EONIA• Reformed to become
ESTR+8.5bps on 2 Oct 2019 until end 2021 to allow the market to change over to ESTR
ESTR• Reference Benchmark• Published from 2 Oct 2019
USD
$ LIBOR• Current standard for XCCY
swaps• Decommissioned after 2021
Fed funds• Target rate for monetary policy• Unsecured overnight rate• Volumes of loans via Fed
Funds are getting lower
SOFR• Reference Benchmark• Secured overnight rate• High transaction volumes• High volatility• Low liquidity so far
Wednesday 11 March 2020 20
Past Present Future
Loans (1%)
ETD Derivatives
(10%)
OTC Derivatives
(85%)
Securitisation (2%)
Bonds (1%)
Total £26,145bn2
X-Cur. Swaps
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11
Timeline: Future events in the LIBOR transition
Wednesday 11 March 2020 21
Past Present Future
1 January 2022Banks no longer compelled by the
FCA to make LIBOR submissions
Q2 2020Agreed upon derivatives fallback language to be
included in updated 2006 ISDA Definitions
Q4 2020Expected clarification
from EIOPA on adoption of new RFRs
within Solvency II
Q3 2020Expected creation
of term SONIA reference rate
Q2-Q4 2021Expected
creation of term SOFR reference
rate
2 Mar 2020Banks to
change market convention for
£ IRS
25 Mar 2020Consultation on How
to Implement Pre-Cessation Fallbacks
closes
30 Apr 2020EIOPA
discussion paper on IBOR
transitions closes
“Some say only two things in life are guaranteed: death and taxes.But I say there are actually three: death, taxes and the end of LIBOR”
John Williams,New York Fed President
The countdown to the end of LIBOR
Wednesday 11 March 2020 22
Will the market make the deadline?
Days Hours Minutes Seconds
59585756555453525150494847464544434241403938373635343332313029282726252423222120191817161514131211100908070605040302010014 59585756555453525150494847464544434241403938373635343332313029282726252423222120191817161514131211100908070605040302010013 59585756555453525150494847464544434241403938373635343332313029282726252423222120191817161514131211100908070605040302010012 59585756555453525150494847464544434241403938373635343332313029282726252423222120191817161514131211100908070605040302010011660 11