2013年-FSB全球金融稳定委员会_Public_responses_to_August_2013_Proposed_Regulatory_Framework_for_Haircuts_on_Non_3页_217kb

AIMA Response to FSB Shadow Banking Policy Document

Core Content

The Alternative Investment Management Association (AIMA) has provided a detailed response to the Financial Stability Board's (FSB) proposed regulatory framework for haircuts on non-centrally cleared securities financing transactions, as outlined in the Policy Document titled Strengthening Oversight and Regulation of Shadow Banking - Policy Framework for Addressing Shadow Banking Risks in Securities Lending and Repos.

AIMA supports the general objective of the FSB to address shadow banking risks, particularly those related to procyclical margin calls. However, they express concerns about the specific proposals for numerical haircut floors and their potential impact on market participants.

Main Views and Key Points

1. Numerical Haircut Floors

• AIMA does not believe that numerical haircut floors will meaningfully reduce procyclicality due to the lack of comprehensive data for calibration.
• They argue that such floors could limit the ability of hedge fund managers to negotiate haircuts on a contractual basis.
• AIMA suggests that if numerical floors are introduced, they should apply to "regulated intermediaries" only, as defined in the Proposals, to avoid competitive distortions and regulatory arbitrage.
• They emphasize that sovereign bonds should not be exempt from numerical floors since they carry default risk and can contribute to procyclical risk premia.

2. Minimum Standards for Haircut Methodologies

• AIMA supports the establishment of minimum standards for methodologies used to calculate haircuts, provided they are globally consistent to reflect the international nature of repo markets.
• They advocate for synchronized national and regional rules with high convergence in substance to prevent regulatory arbitrage.
• AIMA supports the inclusion of specific factors in haircut methodologies, such as:
  • The length of the repo/financing transaction
  • Counterparty credit risk
• These factors should be described in high-level terms, allowing individual firms to apply them according to their own business models.

3. Phase-in Period for Policy Recommendations

• AIMA recommends that the phase-in periods for implementing the minimum standards and numerical haircut floors should be consistent with the other policy recommendations in the Policy Document.
• They also suggest that the phase-in should align with the BCBS-IOSCO margin requirements for non-centrally cleared derivatives to ensure coherence and avoid unnecessary disruptions.

4. Cash-Collateralised Securities

• AIMA supports minimum standards for cash collateral reinvestment, but only if they are sympathetic to the characteristics of securities lending and repo transactions.
• They highlight the importance of stress testing for securities lenders and repo counterparties to ensure they can meet calls for the return of cash collateral.
• AIMA acknowledges the value of more stringent requirements, but stresses the need to balance them against the potential impact on clients' financing needs.

Conclusion

AIMA encourages the FSB to consider the broader implications of any policy measures related to shadow banking, including the potential effects on global credit contraction, market liquidity, and the availability of unencumbered assets. They believe that measures not properly calibrated could harm the functioning of securities financing markets and, by extension, economic activity.

They also express a willingness to discuss the submission in greater detail and offer contact information for Jiri Król, Adam Jacobs, or Wesley Lund.