2016年-FSB全球金融稳定委员会_Public_responses_to_the_February_2016_report_‘Possible_Measures_of_Non_4页_170kb

Amundi's Answer to the FSB Consultation on Non-Cash Collateral Re-Use

Core Content

Amundi, a leading European asset manager with over €985 billion in assets under management at the end of 2015, participated in the FSB consultation on non-cash collateral re-use. The firm emphasizes the importance of understanding the risks associated with collateral re-use but also highlights the need for proportionality and practicality in regulatory measures.

Main Views and Key Points

Amundi outlines several key points in its response:

• Support for Systemic Risk Analysis: Amundi supports the FSB's analysis that collateral re-use may carry systemic risks and agrees that data collection is necessary to assess these risks.
• Reassessment of Scope: The firm believes that the current scope, which focuses on SFTs, should be reassessed. It argues that collateral in SFTs is more complex than in OTC non-cleared derivatives.
• Opposition to Overestimation: Amundi strongly opposes the third option (indirect approximation of re-use), as it leads to overestimation and potentially misleading regulatory decisions.
• Use of Existing Data: The firm advocates for the use of preexisting data collection processes, such as TRs introduced under EMIR, to reduce the burden on the industry.
• Limited Use of Leverage: Amundi notes that asset managers, except for hedge funds, rarely use SFTs to leverage their portfolios. UCITS funds are explicitly prohibited from re-use under ESMA guidelines.
• Efficient Reporting: The firm suggests that a "light regime" of reporting is appropriate for European UCITS and AIFs that do not use significant leverage.
• Cost Considerations: Amundi highlights the high cost of reporting and stresses the importance of engaging with the industry to develop a cost-effective framework.

Detailed Responses to Consultation Questions

Q1: Scope of Transactions for Data Collection

• Amundi agrees with a step-by-step approach but believes the final objective should be a broader scope.
• It notes that reporting on SFTs is operationally complex and suggests that a carve-out should apply to entities (e.g., funds without significant leverage) rather than operations.

Q2: Practical Issues with the Three Measures

• Option 3 is considered inadequate due to its overestimation of re-use, leading to wrong analysis.
• Option 1 is preferred for its exact reporting of collateral status, but it requires considering the pool of collateral rather than individual transactions.
• Option 2 is also valid, but Amundi emphasizes the need to consider aggregation at different levels (jurisdiction, collateral type, counterparty type).

Q3: Reporting of Collateral Type

• Amundi finds the reporting of collateral type as "own assets" or "re-used assets" manageable but highlights the complexity of managing collateral pools.
• It supports the FSB’s recommendation for single-sided reporting to reduce costs and improve efficiency.

Q4: Other Measures for Financial Stability

• Amundi suggests that data could be aggregated at the level of the NCA (Non-Central Authority) for each counterparty to capture concentration among home member states.

Q5: Views on Metrics

• Amundi supports the use of collateral re-use at the jurisdiction level, the re-use rate, and the collateral multiplier for assessing leverage.
• It finds the re-use reliance rate useful for counterparty risk but notes that the collateral circulation length is not relevant as collateral is not intended to circulate.

Q6: Additional Metrics

• Amundi proposes aggregating data at the NCA level for each counterparty to better understand concentration of collateral re-use among home jurisdictions.

Q7: Appropriate Data Elements

• Amundi agrees with the data elements in Table 1 but suggests that the approximated measure (option 3) should be disregarded.
• It also recommends that regulators obtain data on top 5 counterparties from TRs or central registers rather than requiring reporting entities to provide them.

Q8: Practical Issues with Data Elements

• No specific issues are mentioned, but Amundi reiterates the need for a cost-effective and efficient data collection process.

Q9: Collateral Types Alignment

• Amundi supports the use of collateral types as defined in the November 2015 global securities financing data standards.

Q10: Data Architecture and Statistical Issues

• Amundi raises a concern regarding Table 3, where entity B is reported to re-use 35 when it only posted collateral for 30, indicating a possible inconsistency.

Q11: Other Views

• Amundi emphasizes the high cost of multiple reporting obligations and advocates for a single-sided reporting approach to reduce administrative burden.
• It argues that broader coverage is more important for financial stability than the accuracy of peripheral data.

Conclusion

Amundi advocates for a balanced, practical, and proportionate approach to regulating non-cash collateral re-use, emphasizing the need for accurate data and cost-effective reporting. It supports the FSB's initiative but calls for adjustments to the scope and measurement methods to ensure they are appropriate and effective for the asset management industry.