RepoClear has a robust and proven risk and default management framework.
RepoClear’s risk management aims to ensure that any member default can be handled with the existing resources and with minimal disruption to the market.
In order to be confident that it can maintain the safety and stability of Clearing Members and clients, the service has built a framework of safeguards, underpinned by state-of-the-art risk models.
The various layers of protection ensure that we have adequate financial resources to fulfil these obligations in all circumstances - most importantly, to protect cleared trades at our clearing house and the collateral posted against them.
Risk management and settlement is at the core of everything we do at here at RepoClear.
It starts with the onboarding process where we assure that a new Clearing Member has the capabilities to participate in the market and risk managing their positions.
That philosophy then runs through every step of the clearing process at our CCP and all the way to the settlement of a Clearing Member default.
As our first line of defence, RepoClear sets stringent and transparent eligibility requirements for prospective Clearing Members.
The Margin Framework
A comprehensive Margin framework covers the Initial and Additional Margin requirements, the mark to market in form of Variation Margin.
Initial and Additional Margin
The risks associated with the close out of a member’s position are covered through the Initial Margin and Additional margins. The core Initial Margin uses a SPAN-like model based on historical market moves. Additional Margin covers various forms of concentration risks, idiosyncratic risks and positions with high stress losses compared to the mutualised resources.
In the event of a Clearing Member default, these pre-emptive safeguards dramatically limit the impact arising from the failure. The defaulted portfolio is hedged with the guidance of the Default Management Group to reduce its risk, and then auctioned off.
Following the Clearing Member failure, our default waterfall model dictates that the entity’s posted margin and default fund contributions are the first resources to be consumed. Only after these resources are exhausted across all services and LCH’s own ‘skin-in-the-game’ is consumed would non-defaulting Clearing Members begin to experience losses.
Below, we go into more detail about precisely how we would manage a member default.
RepoClear maintains a rigorous default management process.
The process is tested regularly in Firedrills which involve members.
Our default management process follows three steps to reduce the risk of the defaulted firm’s outstanding positions without impacting other non-defaulting Clearing Members:
Risk Neutralisation: After a member default the Default Management Group, which apart from the LCH staff also includes representatives of members in an advisory role, is convened. This group decides on the hedge/pre-liquidation which are executed to minimise the portfolio’s risk.
Portfolio Auction: After that step, RepoClear splits the remainder of the defaulter’s portfolio into auction portfolios. An auction is then conducted for each portfolio with members who are major participants in the respective markets.
Loss Attribution: In the event that losses are greater than the financial resources of the defaulting member and of LCH, the funded Default Fund contributions of solvent RepoClear members are used.
Losses arising are attributed pro-rata.
RepoClear’s default waterfall establishes the order in which the financial resources of a defaulted Clearing Member, solvent Clearing Members and the resources of LCH itself are consumed during a default resolution.
A defaulting Clearing Member’s posted margin is the first asset to be consumed in managing the default, followed by the defaulter’s contribution to default funds.
If these assets prove insufficient to settle the default, LCH’s own capital is next in line for losses. It is only after all of these resources are exhausted that default fund contributions from non-defaulting Clearing Members are used to close out the portfolio.
In the extreme event that all waterfall resources are consumed and defaulted positions have not been fully auctioned, we will enter a service continuation phase and, after a member ballot, potentially a service closure phase.