Global Custody Forum The Evolution of Segregation Models 29 November 2016 BB

Global Custody ForumCCP: The Evolution of Segregation Models Has The Potential to Fundamentally Change the Role of Clearing Members

Eurex Clearing AG29th November 2016

Deutsche Börse Group 1

Agenda

• Segregation Before the 2008 Lehman Default

• Segregation Under EMIR for Mandatory OTC Clearing

• Innovation in Segregation at the CCP – ISA Direct – Direct Access for the Buy Side

• Appendix

Segregation before the 2008 Lehman Default

1


Before the Lehman Default - Omnibus Segregated Account (OSA)

• Fellow customer risk• Porting available. Any excess collateral

will be returned for the benefit of clients.

• 4 percent risk weight for trade and collateral exposures, in Eurex Clearing‘s view

• Leverages historical operational Clearing Member process

• Positions of disclosed clients and positions of undisclosed clients are segregated and covered by a single collateral pool.

• OSA by Value - One collateral pool (cash and securities) with pro rata allocation by value (as a percentage)

• OSA by Asset - Allocation of securities collateral by Clearing Member to CBF, SIX SIS Ltd., CBL accounts Allocation of cash collateral by Clearing Member through pool ID

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OSA under UK CASS

Eurex Clearing‘s CASS Net Omnibus Clearing Model additionally allows Clearing Members located in the United Kingdom to apply the CASS rules when providing segregation to its clients

Positionaccount

Collateralaccount OSA

Cl1 Cl2 All otherCM clients

Cl Client

Client Asset Protection

Segregation under EMIR for Mandatory OTC Clearing

2


Segregation and Portability has become increasingly important under EMIR for Mandatory OTC Clearing

EMIR article 39 requires CCPs and Clearing Members to offer at a minimum omnibus and individual segregation models.

After the Lehman and MF Global defaults, the demand for segregation increased as clients have faced issues around uncertainty of porting, double funding, mutualisation of client and CM risks from co-mingling of assets and potential misuse of client collateral.

Individual models are intended to secure the positions and the collateral assets at all times in the event of default of a Clearing Member or other clients of the clearing member.

Some local investment laws require asset managers to segregate assets at the fund level to prevent co-mingling of positions and assets between the clearing broker, other clients and funds of the same fund company.

Both buy-side and sell-side clients are requesting protection from additional risks including transit and liquidation risk.

ESMA finally provided clarity that individual client segregation requires that the actual assets of the client are segregated and available for porting. Models which merely segregate the value of collateral due to the accounts of clients, 'do not meet the requirement to offer individual client segregation’ (ESMA Q&A 5 August 2013).


The Individual Segregated Account (ISA)

• No fellow customer risk• Highly likely porting• Actual assets protected• Allows full segregation at sub-fund

• 2 percent risk weight for trade and collateral exposures• Asset tagging (optional)• Direct transfer of collateral (optional)• Later cash withdrawals for EUR and CHF

• All actual assets provided to Eurex Clearing are protected against the default of another market participant

• This differs from value-based models where only a value equivalent is protected instead of the client‘s actual assets

• Should there be a default, clients can choose to port immediately to a Replacement Clearing Member or become an Interim Participant, directly facing Eurex Clearing until a Replacement Clearing Member is identified and accepts the port.

• Alternatively, clients can elect to closeout and directly receive their collateral back

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Protection of assets and portability ensures

• No replacement risk

• No liquidity risk

• No liquidation risk in case of a Clearing Member default

Positionaccount

Collateralaccount

Cl Client

Cl1

ISA

Deutsche Börse Group 7The Multiple Omnibus Segregated Account (MOSA) - provides the possibility to segregate ‘group accounts’ in a single separate collateral account

• Limited and accepted fellow customer risk• Likely porting• Actual assets can be protected with Clearing Member agreement• Optional U.K. CASS protection available

• 4 percent risk weight for trade and collateral exposures, in Eurex Clearing‘s view

• Increased collateral efficiency by pooling in a single account

• Allows a Clearing Member and clients to decide which clients are allocated to which collateral pool

• This enables the clients to determine their acceptable fellow customer risk

• Both disclosed and undisclosed client accounts are available

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Multiple OSA (MOSA)

It is possible to segregate all funds of a Fund Manager into a single separate collateral pool while maintaining flexibility on separated or combined position accounts

Positionaccount

Collateralaccount

Cl Client

Cl1 Cl1

MOSA

Client Asset Protection


88

Agency position accounts

CM Prop

account

RC/NCMposition

accounts

Individual Segregated

Accounts (ISA)OSA by Value

RC/NCMposition accounts

RC/NCM collateral pool

CCP MR net for all

P & M accounts

CCP MR per A

account

CCP MR per

RC/NCM

CCP MR per RC/NCM

Posi

tion

acco

unts

Mar

gin

calc

ulat

ion

Eure

x C

lear

ing

Col

late

ral

pool

s A single collateral pool is maintained which dynamically

records proprietary and OSA by value client collateral

OSA by Asset And /or OSA under CASS*

Multiple OSAs*Requires OSA by asset and is available under CASS


RC/NCMposition

accounts

CCP MR per A

account

CCP MR per

RC/NCM

Collateral pool for OSA by asset

Collateral pool for OSA under CASS


CCP MR per A account

CCP MR per

RC/NCM

MOSA collateral pool by asset

MOSA collateral pool under CASS

MOSA collateral pool by asset

MOSA collateral pool under CASS

CCP MR per A account

* Securities collateral under omnibus segregation is held under pledge whilst ISA collateral is full title transfer to Eurex Clearing**The OSA by asset and OSA under CASS models are operationally identical. The only difference is the later affords clients CASS protection.

OSA by value is the default segregation model at Eurex

Clearing. Segregation is achieved through reporting on

the books and records of Eurex Clearing rather than on the CSD

level

When OSA by asset is chosen, a separate collateral pool is opened at Eurex Clearing and an account on

the CSD level. Specific securities and cash are designated to the collateral

pool for all OSA by asset clientsand/or OSA under CASS.

When OSA by asset is chosen, CMs have the option to open multiple omnibus collateral pools at Eurex Clearing. This enables CMs to group clients together. It is possible to have multiple

collateral pools protected under UK Client money rules (OSA under CASS) or not (OSA by

asset).

Full physical segregation of positions and

collateral per client.



CM calls each client on a gross basis and can either post net or gross to Eurex Clearing. For the CM, disclosed clients (RC/NCM) are gross margined

Standard Omnibus Segregated Accounts (OSA)

Overview of Segregation Models at Eurex Clearing

Innovation in Segregation at the CCP – ISA Direct –Direct Access for the Buy Side

3

Concentration of risk in the US OTC Derivatives Clearing Business 1 Challenges

TOP 5~70%

TOP 10 ~95%

1 Source: http://www.cftc.gov/MarketReports/FinancialDataforFCMs/index.htm - *as of 30.09.2015

• Concentration is increasing. US market structure is likely to arise in Europe as well

• Limited balance sheet capacity of many clearing brokers and poor economics for client clearing

• Porting of clients in crisis massively at risk given constraints of clearing brokers to pick up clients

Significant negative implications including domino effects can be expected in a crisis, as long as neither the capital rules nor the market structure changes

Derivatives market structure shows a strong concentration of risk to the Top 10 Clearing Brokers

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

Credit Suisse

Morgan Stanley

J.P. Morgan

Citigroup Global

Barclays Capital

Wells Fargo Securities

Goldman Sachs

Merrill LynchDeutsche BankUBS

TOTAL Initial Margin: ~ 56 BN US $*


http://www.cftc.gov/MarketReports/FinancialDataforFCMs/index.htm

Innovation in Segregation at the CCP - ISA DirectISA Direct model combines elements of direct clearing membership and the traditional service relationship in client clearing, tailored specifically for the Buy Side.

Transaction management

Cash management

Collateral management

• Default fund contribution• Default management obligation

Client Clearing Member

ISA Direct client

Clearing Agent

Traditional client clearing ISA direct model

Optional transaction processing services betweenClient and Clearing Member resp.

ISA Direct client and Clearing Agent

Clearing agent and clearing member core tasks

Direct contractual relationship


ISA Direct – Direct Access for Client Clearing

ISA Direct client

Clearing Agent

CCPDirect contractual relationship

Provision of operational services* by Clearing Agent to ISA Direct client

• Default Fund contribution

• Bidding obligation

TransactionManagement

Cash Management

Collateral Management

The solutionISA Direct delivers a framework that isoperationally similar to a traditionalsegregated client clearing relationshipunder a different legal relationship.

1. Client becomes principal to the CCPand directly clears trades

2. Clearing Agent facilitates operationalservices*, and specific defaultobligations

3. ISA Direct clients have to meetadmission criteria equivalent toregular Clearing Members

In addition to improving market safety andintegrity, this results in a number of keybenefits to both parties:

Benefits for Clearing Agent• Capital costs substantially reduced (LR, RWA)• Allows maintenance of client relationship and delivery of

a range of clearing services• Increased default fund contributions for ISA Direct

Member and Eurex Clearing’s dedicated amount create layers of protection before loss mutualisation

Benefits for ISA Direct Client• No default fund contribution • Assets are segregated, securities under pledge• Collateral eligibility >17,000 ISINs• Porting issues removed, appointment of new Clearing

Agent in default scenario• Relieves concentration of CMs offering client clearing

Giving Significant Benefits to both the Buy Side & Sell Side

*operational services can be performed by the Agent or the ISA Direct client


Capital costs for providing client clearing services can be substantially reduced via ISA Direct

Capital cost of clearing agent (bps of IM)

Clearing agent CCPClient

Exposure

IMDF

IM

Exposure

~80%+

Capital costs for providing default fund (only applies if clearing agent provides default fund, otherwise this is a direct

costs for the client)

Client clearing

Direct clearing

Leverageratio

RWA

Leverageratio

RWA

Banks can take on a range of roles, enabling them to retain and service client relationships

CCPClientExposure

IM

DF

Trading activityClearing

agent

Derivatives clearing models and corresponding annual capital costs for a clearing agentExample based on ~5 year duration, directional EUR IRS swap portfolio

~85%-95%+

~25-701

~14

~3

~3

1. Depends on final leverage ratio rule (use of SA-CCR with collateral offset leads to reduced costs of ~25 bps vs. ~70 bps based on current proposal with CEMNote: Requirements are foreseen to only allow direct access for clients of high credit quality (requiring credit assessments required for each new clearing license, discussed within the Eurex Clearing Credit Committee, signed-off by the Eurex Clearing Executive board)


Client Clearing & Asset Segregation Models

Source: Jan Grunow, Swiss Life Asset Managers, 'Buy Side experience: New Access Models through direct contractual relationships to CCPs', 10th Annual Collateral Forum, Amsterdam, October 2016'.


Different Trading Opportunities for Buy Side Clients

1 Introduction planned in Q3-20162 Indication of Interest

Eurex Repo Buy Side Trading Permissions

Select Invest Specific Lender§ Access to GC Pooling (basket

trading)§ Net cash provider in EUR§ Best-price execution with

Request-for-Quote (RFQ) –1:1 and/or 1:n § Eurex Clearing steps in as

Central Counterparty (CCP) by novation (pre-funding)§ Simplified access requirements § Specific Clearing Membership

(no default fund contribution, no margin requirements; no Clearing Agent)§ No trading and clearing fees

§ Access to GC Pooling, Repo and SecLend Market (basket & single ISIN trading)§ Cash provider and cash taker in

EUR, USD, CHF, GBP§ Securities financing in EUR,

GBP§ Best-price execution with

Request-for-Quote (RFQ) –1:1 and/or 1:n § Eurex Clearing steps in as CCP

immediately after execution§ Fulfillment of all membership

requirements § Direct access to CCP via CA

§ Access to SecLend Market(single ISIN trading)§ Securities financing with

individual collateral schedules, standardized baskets or cash (EUR/USD)§ Quotes/IOIs2 sent to borrowers§ Eurex Clearing steps in as CCP

immediately after execution§ Simplified access requirements § Specific Clearing Membership

(no default fund contribution, no margin requirements; no Clearing Agent)

Select Finance1

Electronic trading => bilateral trade negotiation (OTC) and straight-through-processing (STP)

Direct access to Eurex Clearing (CCP)

Mitigated trading risk through comprehensive risk and collateral management of Eurex Clearing

Corporates, Insurance Companies Pension Funds, Asset Managers, Insurance Companies

Beneficial Owners, Agent Lenders, (Pension Funds, Asset Managers ...)


Example of an Integrated Collateral Management Solution using ISA Direct Repo / Select Finance & Re Use GC Pooling Collateral Facility

The Challenge• Cash variation margin for pension funds and

similar long term liability driven portfolios inOTC Clearing is challenging

• New capital rules impede the Buy Side’saccess to liquidity

• The ability to transform the fund’s range ofhigh quality assets is required

The Solution• ISA Direct Repo / Select Finance facilitates

access to the Repo platform for the buy sidevia a ‘request for quote’ process.

• Pension funds can reuse the cash receivedunder the repo to facilitate VM for theirliability driven strategies.

• Clearing Member A can re use the GCpooling collateral received to meet initialmargin requirements for listed and OTCderivative products further increasing theefficiency of collateral.

Benefits• Increased access to liquidity• Directly connect market participants with existing infrastructure• Targeted and rapid delivery of liquidity in times of stress provided by

central banks and government agencies

ISA Direct Member

IM

VM

Repo / GC Pooling

Repo / GC Pooling

Securities Securities

Cash Cash

Cash / VM Cash / VM

Re-use cash for VM

IM

VM

Clearing Member A

OTC OTC

Clearing Member B

Eurex RepoRFQ Re use securities for IM


Appendix4

Average outstanding volume: Breakdown by market & segment

20 day moving average/single counted

§ Daily outstanding volume record € 245.9 bn reached on June 12, 2014

§ Average outstanding volume in May 2016: € 142.6 bn

§ Special Repo:Daily average 2,000-3,000 special repo quotes uploaded for inventory trading

Key Figures & News

All Eurex Repo Markets

Eurex Repo Dealer-to-Dealer Liquidity


Tri-Party Repo

360T

mandatoryoptional

Client

Eurex RepoTrading

Clearstream Banking/Euroclear

Select Finance

CCPEurex Clearing

ProvisionMargin assets

FulfillmentMargin call

Access CCP systemsRegistration Clearing staff

Default Management

Clearing Agent

Clearing FundContribution

Collateral or cash

Collateral or cash

Collateral or cash

Collateral or cash

§ The Select Finance participant may actas:§ Cash provider/cash taker in EUR,

USD, CHF and GBP and/or§ Buyer/seller in securities financing

in EUR and GBP

§ The Select Finance participant needs tohave a basic clearing membership

§ Fulfillment of all clearing membershiprequirements

§ Signature of a trilateral clearingagreement with the Clearing Agent toobtain transaction, risk and collateralmanagement services

§ The Clearing Agent is required to provideat least the clearing fund contribution andDefault Management Bidding Obligationson behalf of the Select Finance participant

Operational Concept of ISA Direct Repo / Select Finance


Bank

Eurex Clearing Eligible Collateral – circa 17,000 ISINSYield Shift =

Yield ShiftMarket

Price RiskCredit Risk

Liquidity Risk

Government and Short Term Issues (Bubills) Bonds BBUN 3.2% 3.2% 0.8% 0.80% 0.0% 1.00 State Issues BLAN 3.1% 3.2% 0.8% 0.80% 0.0% 1.00 City and Municipality Bonds BSTA 5.0% 5.4% 1.3% 0.80% 0.4% 1.14 State Agencies BAGE 5.0% 5.5% 1.3% 0.80% 0.4% 1.11 Corporates & Other Bonds BIND, BOTH 11.2% 12.1% 3.1% 0.80% 1.6% 1.28 Bank Bonds BBAK 11.1% 13.3% 3.0% 0.80% 1.4% 1.36 Federal Bonds and Bills (GMBF), Loan obligations BCNF 3.2% 3.1% 0.8% 0.80% 0.0% 1.00 Kantonal Obligations, Bonds, Bills (GMBF) BCAN 3.1% 3.0% 0.8% 0.80% 0.0% 1.00 City and Municipality Bonds BSTA 5.0% 5.4% 1.3% 0.80% 0.4% 1.14 State Agencies BAGE 5.0% 5.5% 1.3% 0.80% 0.4% 1.11 Corporates & Other Bonds BIND, BOTH 11.2% 12.1% 3.1% 0.80% 1.6% 1.28 Bank Bonds, Mortgage Bonds (Pfandbriefzentralen) BBAN 11.0% 13.3% 3.0% 0.80% 1.4% 1.36

USD, GBP, DKK, NOK, SEK, AUD, CAD, JPY

1) Exchange listing2) Admissible proportion of the issued capital is 25%3) High credit quality - investment grade

Government Bonds

BAUS, BABP, BADK, BANK, BASK, BAAD, BACD, BAJY

3.2% 3.1% 0.8% 0.80% 0.0% 1.00

EUR, CHF, USD, GBP, DKK, NOK, SEK, AUD, CAD, JPY

1) Marketable assets as announced by ECB2) ECB Liquidity Classes I-IV3) Exchange listing4) Admissible proportion of the issued capital is 25%5) High credit quality - investment grade

Spanish, Polish, Czech and Hungarian Government BondsBBSL 8.7% 9.2% 2.3% 0.80% 1.3% 1.13



Italian Government Bonds BABS 11.4% 11.0% 3.2% 0.80% 1.9% 1.19



Irish Bonds BPOS 6.3% 6.8% 1.9% 0.80% 1.0% 1.06

Equities EUR, CHF1) Issuer <> Clearer or seg. NCM if applicable2) Admissible proportion of the free float is 1% 3) maximum 30% of required daily collateral

DAX, EuroStoxx 50, SMI constituents SAKT 23.1% 23.1% - - - 1.00

ETF EUR

1) Issuer <> Clearer or seg. NCM if applicable2) Admissible proportion of the NAV is 10% (max 500 mio EUR)3) Maximum 30% of required daily collateral

Fully replicated ETFBased on the DAX, EuroStoxx 50 and Stoxx Europe 50 index

SETF 16.1% 16.1% - - - 1.00

Collateral Type Currency Admission Criteria

Bond Collateral

EUR, DEM

1) Marketable assets as announced by ECB2) ECB Liquidity Classes I-IV3) Issuer <> Clearer or seg. NCM if applicable4) Exchange listing & price (except Bubills)5) Admissible proportion of the issued capital is 25% 6) High credit quality - investment grade

CHF

1) SNB Repo eligible2) Issuer <> Clearer or seg. NCM if applicable3) Exchange listing & price4) Admissible proportion of the issued capital is 25%5) High credit quality - investment grade

Yield Shift(M arket Price Risk + Credit Risk) x Liquidity Risk

Security Type Code New Minimum

Haircut

Old Minimum

HaircutSecurity Sub-Group


ISA Direct & ISA Direct Repo / Select Finance and Select Invest - Further Information

Links: http://www.eurexclearing.com/clearing-en/markets-services/isa-directhttp://www.eurexrepo.com/repo-en/buyside-services


http://www.eurexclearing.com/clearing-en/markets-services/isa-direct

http://www.eurexrepo.com/repo-en/buyside-services

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Documents

Global Custody Forum The Evolution of Segregation Models 29 November 2016 BB