2012年-FSB全球金融稳定委员会_Public_responses_to_April_2012_consultative_document_Interim_Report_on_Securities_Lending_and_Repos_2页_47kb

Securities Lending and Repos: Market Overview and Financial Stability Issues

Amundi, a leading French asset manager with €658 billion under management at the end of 2011, ranks second in Europe and among the top ten global asset managers. It manages approximately 2,500 funds across various investment strategies and countries. In response to the Financial Stability Board’s Interim Report on Securities Lending and Repos, Amundi highlights key considerations for regulatory frameworks that impact the use of these instruments in fund management.

Core Content

The report primarily outlines the risks associated with securities lending and repos, particularly in relation to systemic financial stability. Amundi, however, emphasizes that the report may not fully reflect the nuanced use of these instruments by asset managers and suggests that certain regulatory approaches could have unintended consequences.

Main Views

Amundi supports the following main views:

• Collateralised Transactions are Safer: Amundi believes that collateralised transactions, such as repos and securities lending, are inherently less risky than non-collateralised ones. It advocates for the continuation of the collateralisation approach used in EMIR and Dodd Frank regulations for standardised and liquid OTC derivatives.

• Distinction Between Fund Management and Shadow Banking: Amundi argues that the proper use of repos and securities lending by heavily regulated funds should not be equated with the improper use by non-regulated shadow banking entities. It suggests that while shadow banking should be regulated, it should not be outright forbidden.

• Appropriateness of Regulation: Amundi highlights the need for a principle of appropriateness when implementing new regulations. It warns that introducing collateral requirements in certain contexts could reduce investor protection and increase costs, potentially leading to the development of non-guaranteed formula funds.

• Systemic Risk Considerations: Amundi notes that some issues discussed in the report are not specific to repos and securities lending and should be evaluated in their own context. It argues that the report’s focus on certain aspects may overlook the broader implications of collateral concentration and liquidity management.

Key Information

• Collateral Transparency and Accessibility: Collateral received in a reverse repo is more transparent and accessible, allowing investors to directly sell it in case of default.

• Bilateral Repo Advantages: Bilateral repos offer greater flexibility and protection compared to tri-party repos, as they allow for tailored collateral criteria and direct access to securities in case of counterparty failure.

• Formula Funds and Collateral Recourse: Formula funds, which guarantee performance through a guarantor, already have a secondary recourse mechanism. Introducing additional collateral requirements could reduce their effectiveness and lead to less protection for investors.

• Systemic Risk and Collateral Concentration: Amundi warns that concentrating collateral on a limited number of high-quality assets could increase systemic risk during financial crises, potentially leading to a sovereign debt crisis. It suggests that allowing flexibility in collateral choice and using evolving haircuts could help mitigate this risk.

Conclusion

Amundi advocates for a balanced regulatory approach that recognizes the legitimate use of repos and securities lending by regulated funds, while addressing the risks posed by shadow banking. It emphasizes the importance of appropriateness in regulation and the need to consider the broader implications of collateral concentration on financial stability.